### Radioactivity

Radioactivity is the term used for the atomic particles by unstable elements as they decay into other
elements. The intensity of radiation depends upon the speed at which the element in question decays, and the energy level of atomic particl e produced.

Radioactivity is dangerous even at low levels because the emitted particles can cause damaging mutations in the DNA of cells. If the damage occurs to genes regulating cell division the result can be uncontrolled cell growth

, producing cancer. Radioactivity cannot be seen, felt or otherwise detected by humans without special instruments, but can nonetheless be extremely damaging

. There is no safe level of radioactivity, as damage is proportional to dose , and exposure is cumulative. Humans are constantly exposed to low level radiation in the environment, and any further exposure simply adds to the overall
burden. There is no truly safe level of exposure : permitted levels of exposure are simply based on cost

benefit analyses.

It is important to realize that r adioactive wastes cannot be decontaminated; they are radioactive essentially for ever, and will expose anyone near them or who breathes in the radioactive dust or gas. The only

“ treatment ” is to remove the solids (if they can be captured) a nd transport them , by road, to a radioactive materials holding site. The only treatment for radioactive gas is ventilation. T he co ntinuous release of radioactivity from solids, liquids or gas means continuous exposure.

Radium and Radon

The Marcellus shal e is known to contain radium, which is a product of the decay of uranium. Radium ( 226 Ra) is extremely radioactive, being over one million times more radioactive than the same amount of uranium. Its decay occurs in seven stages producing three kinds of radi ation: alpha particles, beta particles, and gamma rays

, as it decays to successive products

, which are themselves radioactive elements. The first product is the element r adon , which is a dangerously

- radioactive heavy gas, and the later products are radioa ctive solids . Radium loses about 1% of its activity in 25 years, being transformed into
elements with atomic weight s each a little lower than its predecessor, with lead being the final product of disintegration.

Radium is, chemically, an alkaline earth met al, as is calcium. Since radium is chemically similar to calcium, it has the potential to cause great harm by replacing calcium in bones

. This is because radium is
treated as calcium by the body, and deposited in the bones , where the radioactivity degrades marrow and
can mutate bone cells. Inhalation, ingestion or body exposure to radium can ca use cancer and other
disorders.

Radon is a highly radioactive , colorless, odorless, tasteless “ noble ” (or chemically un

- reactive) gas , occurring naturally as the dec ay product of radium . Radon is responsible for the majority of the public exposure to ionizing radiation . It is often the single largest contributor to an individual's background radiation dose, and is the most variable from location to location. Radon gas from natural sources can accumulate in buildings, especially in confined areas such as attics, and basements. It can also be found in some spring waters

. Epidemiological evidence shows a clear link between breathing high concentrations of radon and
incide nce of lung cancer. Thus radon is considered a significant contaminant that affects indoor air quality . According to the EPA

, radon is estimated to cause 21000 deaths per year in the US; radon is the second most frequent cause of lung cancer, after cigaret te smoking

. Radon emanates naturally from the ground, particularly in regions with soils containing granite or shale

, which have a higher concentration of uranium. I t usually migrates freely through faults and fragmented soils, and may accumulate in caves or water. G as from a gas well often contains radon. The radon decays
to form solid radioactive elements

, which form coatings on the inside of pipework , so that used pipework is frequently radioactive

.In the open air, radon concentration ranges from 27 to 27 00 pCi per cubic yard of air (one pico Curie (pCi)

is a unit of radiation represent ing 2.2 atomic disintegration per minute )

. Typical domestic exposure to radon in homes is approximately 27 00 pCi per cubic yard of air; in ill

- aerated houses over radioacti ve

ro cks its concentration can climb to 27 ,000 pCi per cubic yard. The EPA recommends that homes should be fixed if an occupant's long

- term exposure will average 4000 pCi per cubic yard or more , the equival ent to roughly 200 chest x

- rays per year . The li mits do not correspond to a known threshold of biological effect, but are determined solely by a cost

- efficiency analysis.

Radioactivity in the Marcellus Shale
In the gas industry, radioactive materials known as “Naturally Occurring Radioactive Materials ” or NORM, can be brought to the surface through gas wells. This can happen w hen fluids that are present in
the radioactive forma tion are pumped out of the well or from radon in t he natural gas

. It must be emphasized that such radioactive materials are no t normal just because they are naturally occurring at 3000 feet below the surface; on the surface they are not part of the normal environment and should be
treated as hazardous. Because the radioactive materials become concentrated on gas

- field equipment, the highest risk of exposure to oil and gas NORM is to workers who cut and ream oilfield pipe, remove solids from tanks and pits, and refurbish gas processing equipment.

T he Marcellus shale is considered to be “highly radioactive.” I n Onondaga County, NY, where the Marcellus shale is close to the surface, a ll of the homes underlain by Marcellus shale had indoor air levels
of radon above EPA’s “action level”

, with the average concentration in being more than twice that level.
T he Pennsylvania Bureau of Oil and Gas Management (BOGM) and Bureau of Radiation Protection
found that a concentration of r ad on in a gas sample was 1000 times the above level. The New York Departmen t of Environmental Conservation found 13 samples of returned drilling wastewater to con tain levels of radium as high as 267 times the limit for discharge into the environment, and thousands of times the limit for people to drink.

In the DEC d s GEIS

, radioactivity receives detailed attention only in section 5.2.4.2 where radioactivi t y

measurem ents are reported in Table 5

- 2 for various rock core samples , and in section 6.8 . The radioactivity for the rock samples is claimed to be background, but calculations show that it is well above background (see footnote)

. It also reports that the EPA meas ured values of radioactivity for flow

- back
water of 9,000 picocuries per liter (pCi/l), or 9,000 times the natural radiation in normal well water (see

Eisenbud & Gesell )

, and >100,000 picocuries per gram ( pCi/g ) for pipe and tank scale , or about 1000 times the radiation level given off by normal concrete ( see Radioactivity in Nature )

. Given that samples measured were only 1 gram (1/28 of an ounce in size) or 1 liter (close to 1 quart) the conclusion can be made that
the radiation from tons of removed s hale or thousands of gallons of water would be proportionally higher, and thus significantly radioactive. A major concern is the radioactivity of recovered gas , but there is no mention of radon in the dsGEIS beyond n oting that it is a product of r a d ium decay

. Given that radon is of major concern this is a major deficiency of the dsGEIS.

As the Marcellus shale is developed it will be important to understand the radioactivity of the various

waste streams that are produced ( e.g., returning water, gas, pit/tank sl udge and drill cuttings ). D uring drilling there may be a large volume of radioactive shale rock removed in the drill cuttings

, especially
fr om horizontally drilled wells. It is therefore imperative that drilling wastes not be disposed of

, by either

on

- si te burial or landspreading

, in areas that are located close to residences or public facilities , or where it can contaminate water supplies . Radioactive wastes must be taken to a n appropriate facility that is designed to handle radioactive waste. Measure s must also be taken to ensure that the radioactive gas does not leak from wellheads, or that releases do not occur through generated fractures in the overlying rock

, or from well casings

, into the water supply.

"The findings [of high

- level radioactivity in the Marcellus shale] have several implications: The energy industry [must] face stiffer regulations ... Companies [will] need to license their waste handlers and test their workers for radioactive exposure, and possibly ship waste across the country [for di sposal] . And thestate [will] have to sort out how its laws for radioactive waste might apply to drilling and how the waste

could impact water supplies and the environment." (Lustgarten ).

The town of Dryden recommends to the DEC:

That no removal of fluids that have been injected into the Marcellus shale be permitted until there is a thorough analysis of the levels of radioactivity in both the fluids and the gas contained therein in every
well , and all potential withdrawals of liquid or gas be subject to the ru les of the EPA , and that surveys be conducted monthly thereafter.

Given that

, under New York State regulations

, any substance emitting twice the background radiation
should treated as radioactive , and disposed only in approved and licensed facilities, w e request that if such levels of radioactivity are detected:

1) All such radioactive fluids and the solids therein are not permitted to be disposed of on or in the locality of the site and must be transported to approved and licensed radioactive

- waste hand ing facilities.

2) That all workers dealing with any solid or fluid exceeding twice background be trained and licensed to
handle radioactive materials.

3) Given that radioactive deposits can accumulate on the inside of pipes and all e quipment involved in g as handling that all such pipes and equipment be monitored for radioactivity and if found to have a level exceeding twice background that they must not be left on or in the vicinity of the drilling site but must be transported to an approved and licensed r adioactive waste handling facility when no longer in use.

4) Given that radon, from the actual well, the gas, or potential fractures in the rock, in homes and other buildings is of major concern, that all homes and buildings within one mile of the drill si te are surveyed for radon prior to drilling, and annually thereafter, and that should the level of radon exceed the EPA action level the gas company shall either remedy the problem (e.g., by sealing the basement) or purchase the home and surrounding land a t the current market value, or the market value prior to drilling, whichever is the higher.

References: Brodsky, A. (1978) Handbook of Radiation Measurement and Protection, CRC Press 1978 and, Eisenbud, M and Gesell T. (1997) Environmental Radioactivity f rom Natural, Industrial and Military Sources Academic Press.
Environ mental protection Agency: Radon. http://www.epa.gov/radon/pubs/index.html Radioactivity in Nature. Iowa State University. http://physics.isu.edu/radinf/natural.htm Lustgarten, A. (2009) Is New York’s Marcellus Shale Too Hot to Handle? ProPublica. http://www.propublica.org/feature/is

- the

- marcellus

- shale

- too

- hot

- to

- handle

- 1109 Lustgarten, A. (2009) Is New York’s Marcellus Shale Too Hot to Handle? Albany Times Union. http://www.timesunion.com/AspStories/story.asp?storyID=863369 Radium. Wikipedia http://en.wikipedia.org/wiki/Radium Radon. Wikipedia. http ://en.wikipedia.org/wiki/Radon Sumi, L. (2008) Shale Gas: Focus on the Marcellus Shale. The Oil & Gas Accountability Project/Earthworks. http://www.earthworksaction. org/pubs/OGAPMarcellusShaleReport

- 6

- 12

- 08.pdf Note: Some quotes are taken directly from the above references without further attribution.

Peter J. Davies Professor of Biology , Cornell University
The author is a licensed handler of low

- level radioactive material.