PA DEP’s On-going Radiation Study for Oil and Gas Operations

One of the many environmental issues or concerns associated with shale gas development has been the level of radiation exposure associated with the variety of processes and equipment used to develop the resource.  While there is no current data to link shale gas development with elevated levels of radiation risk or exposure, the Pennsylvania Department of Environmental Protection in 2013 undertook a study to determine if there are any long term risks that need to be identified.  

Naturally Occurring Radioactive Material (NORM) is found in underground rock formations and in many environments today (think of radon in homes).  Shale gas operations bring underground rock to the surface in the form of drill cuttings as well as water that is injected into the shale rock formation during the fracing operation.  As the result, the DEP’s is looking at all aspects of the shale gas operation including drill cuttings, flowback water, produced water, water treatment plants and impoundments.  This study has been ongoing since mid 2013 and results should be released in late 2014.

Operational experience to date and some independent data collected by a few companies for internal use (but informally shared with the industry) has not raised any red flags that would indicate high or unexpected levels of radiation exposure associated with shale gas activities.  Likewise, the DEP indicated that if their sampling and analyses revealed any high levels of radiation, before the report was finalized, that they would notify the operator so he could take appropriate measures to rectify the concern.  So far no operators have been alerted by the DEP to take measures to mitigate levels of radiation exposure.

The industry is working with the DEP and its consultant to assure that samples can be collected at numerous points and locations at gas operations throughout the Commonwealth.  Additionally, industry, through a joint effort of the Marcellus Shale Coalition and the Pennsylvania Independent Oil and Gas Association, is conducting a parallel data sampling and analysis study.  Should either of these studies reveal a radiation exposure problem or problems with any phase of shale gas operations; the industry will work with the Department to initiate measures to alleviate the concern.

Recently, similar concerns about radiation were raised at a legislative hearing in West Virginia.  There researchers noted that a 2011 legislatively mandated study on potential pollution from shale gas development failed to include analyses of horizontal well drill cuttings.  While it is uncertain what actions may be taken in West Virginia, it is likely that the results of the Pennsylvania study will provide great insight into what if any radioactivity related concerns are associated with drill cuttings.

Gary Slagel, who most recently retired as the Senior Advisor of Environmental Affairs for CONSOL Energy, has joined the firm as a Government Affairs Specialist. Mr. Slagel is an engineering graduate from the University of Dayton and spent 35 years with CONSOL and CNX Gas in several capacities including Director of Environmental Regulatory Affairs and later Director of Government Affairs working on both coal and natural gas issues.
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