From: Helmer, Stephen < Stephen.Helmer@odh.ohio.gov > Date: Tue, Jan 21, 2014 at 12:51 PM Subject: RE: Public Records Request - Frack Waste - Solids and Fluids - Norm and Tenorm To: Leatra Harper < wewantcleanwater@gmail.com >



### L ea,

S ee%a' ached%for%lab%results%in%the%past%2%years.

I ncluded%is%a%summary%document%that%explains%the%samples%taken.

P lease%let%me%know%if%you%have%any%further%quesA ons.



# Ste phen Helmer

S tephen% H elmer

P rogram% A dministrator

B ureau% R adiaA on% P rotecA on

O hio% D epartment%of% H ealth

35% E

.% C hestnut% S t.,%7 th F loor

C olumbus,% O hio%43215

O ffi ce:% 614T728T3611

F ax:%%%%% 614T466T0381

# P P lease&consider&the&environment&before&printing&this&email.



### From: Leatra Harper [mailto: wewantcleanwater@gmail.com ] Sent: Tuesday, January 21, 2014 12:19 PM To: Helmer, Stephen Subject: Public Records Requeset - Frack Waste - Solids and Fluids - Norm and Tenorm

Dear Mr. Helmer,

We are making a public records request for the results of sampling done in the fi eld over the past two years that examined levels of radioactivity in drill muds, cuttings and fl uids. We understand it is not a large amount of sample data and thank you in advance for your time and effort to provide this information on these materials.
Best regards,
Lea Harper

www.FWAPOH.com
(419) 450-7042

-- "Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has." Margaret Mead
This e-mail is intended for the sole use of the intended recipient and may contain privileged, sensitive, or protected health information. If you are not the intended recipient, be advised that the unauthorized use, disclosure, copying, distribution, or action taken in reliance on the contents of this communication is prohibited. If youhave received this e-mail in error, please notify the sender via telephone or return email and immediately delete this e-mail-- "Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has." Margaret MeadThe! Ohio! Department! of! Health! (ODH)! was! requested! to! analyze! for! radioactive! materials! that! could! possibly!be! found!in! the!various!processes!involved!in!deep!well!injections! related! from! the!Oil!&!Gas! industry.! Included! are! radiological! sample! results! as! of! February! 15,! 2013! analyzed! by! the! ODH! Laboratory.!A! number!of! states! have! sampled!and!analyzed! for! radioactive!content! from! this!industry! and! these! samples! include! results! from! the state! of! Ohio.! There! is! naturally! occurring! radioactive! material! (NORM)! in! the! earthen! materials! extracted! from! the! various! drilling! industries! including! the! deep!well!injection!process.!NORM,!by!definition,!is!naturally!occurring!and!can!be! found!everywh ere! and!as!a!result!has!been!exempted!from!regulation!by!the!U.S.!Department!of!Energy,!the!U.S.!Nuclear! Regulatory!Commission,!and!the!State!of!Ohio.

When!NORM!is!used! for!commercial!purposes,!processed,!separated,!or!in!some!other!manner!has!its! radioac tivity!concentrated!(intentionally!or!unintentionally),!it!becomes!another!category!of!radioactive! material!called!Technologically!Enhanced!Naturally!Occurring!Radioactive!Material! (TENORM).!In!Ohio,! TENORM! is! regulated! by! ODH! and! the! regulations! can! be! fo und! at! the! following! url:! http://www.odh.ohio.gov/en/rules/final/3701_1

Z 43

Z TENORM.aspx .! TENORM! includes! the! same! group! of!NORM!radionuclides,!but!the!material!has!been!modified!or “technologically!enhanced”!resulting!in!a!

man

Z made! concentration! higher! than! NORM.! There! are! concerns! with! a! number! of! drilling! related! wastes!generated!from!the!Oil!&!Gas!industry!that!can!generate!TENORM.!

To!help!clarify! the!differences! from!NORM!and! TENORM,! the!Ohio!Department!of!Health!generated!a! NORM/TENORM! Information! Sheet.! This! can! be! found! at! the! following! url:! http://www.odh.ohio.gov/~/media/ODH/ASSETS/Files/rp/Raducation/Module%203%20

Z %20NORM%20TENORM%20Information%20Sheet.ashx

The!Ohio!Department!of!Health,!through!coordination!with!the!Ohio!Department!of!Natural!Resources! (ODNR),! has! been! provided! access! t o! some! drilling! sites! in! Ohio.! ODNR! is! the! Oil! &! Gas! industry’s! primary! regulator.! Samples! have! been! obtained! based! on! the! available! medium! at! the! time! of! the! drilling! process.! A! number! of! samples! are! taken! during! the! “exploration”! phase! and! some! are! taken during! the! “production”! phase.! These! samples! have! been! analyzed! primarily! for! the! combined! total! radioactivity! for! Radium

Z 226! and! Radium

Z 228.! ! For! questions! concerning! these! results! please! contact! the!Ohio!Department!of!Health!Laboratory ,!Dr.!Ram!Chandras ekar! at!614

Z 466

Z 5600!or!Larry!King!at!614

Z 752

Z 9064

. The! samples! included! are! limited! in! number! and! therefore! offer!minimal! conclusive! information.! The! results! do! show! the! expected! radiological! content! (naturally! occurring! radium)! in! each! of! the! typical!

wa ste! streams! found!in!Ohio! from! the!Oil!&!Gas!deep!well!injection!process.!For!questions! related! to! radioactive!materials,!including!TENORM,!please!contact!the!Bureau!of!Radiation!Protection!at!614

Z 644

Z 2727.ODH!Lab! Sample!Index

Lab!sample!# Matrix units
R6462

Z 01 Unused!Sand pCi/g

R6462

Z 02 Flow!Back!Water pCi/L

R6462

Z 03 Cuttings pCi/g

R6462

Z 04 Cuttings!Utica pCi/g

R6462

Z 05 Cutting!Utica pCi/g

R6462

Z 06 Mud pCi/L

R6481

Z 01 Production!Water pCi/L

R6481

Z 02 Unused!Sand pCi/g

R6486

Z 01 Vertical! Cuttings pCi/g

R6486

Z 02 Horizontal!Cuttings pCi/g

R6486

Z 03 Vertical!Mud pCi/L

R6486

Z 04 Horizontal!Mud pCi/L

R6486

Z 05 Flow!Back!Water pCi/L

R6486

Z 06 Used!Sand pCi/g

R6489

Z 01 Cuttings pCi/g

R6489

Z 02 Mud pCi/L

R6489

Z 03 Cuttings pCi/g

### Analysis of Environmental Samples for Gamma Ray Producing Nuclides
Ohio Department of Health Laboratory Radiation Chemistry 8995 East Main Street Building 22 Reynoldsburg, Ohio 43068

Introduction
This is a summary of the work flow for the analysis of the environmental samples to support the Bureau of Radiation Protection (BRP) investigation of samples from the oil and gas industry to determine the extent of naturally occurring radioactive materials (NORM). It is anticipated that the lab would expect t o analyze 30

- 40 samples over a month long period. The samples could include the following matrices:

1. Drill Cuttings 2. Drill fluids/muds 3. Frac Sands 4. Flowback Fluids 5. Production Fluids Additional samples for possible consideration include any new media found on site to check on their initial background levels (new sands, new drilling mud, etc.).
Sample Receipt
Six samples were received at the Ohio Department of Health Laboratory on October 1, 2012 at approximately 1600 hours. (A copy of the Laboratory Analysis Request Form is attached). The samples were delivered by Mr. Robert Leidy and were received at room temperature. Upon receipt the sample information was input into the l aboratory’s sample receipt data base, and chain of custody signed. The following samp le identifiers were provided by Mr. Leidy:
1) BRP

- 01

- 734

- 001

- US

– Unused Sand 2) BRP

- 01

- 734

- 00 2

- F

– Flow Back 3) BRP

- 01

- 721

- 001

- C

– Cuttings 4) BRP

- 01

- 721

- 00 2

- CU

– Cutting Utica 5) BRP

- 01

- 721

- 00 3

- CU

– Cuttings Utica 6) BRP

- 01

- 721

- 004

- M

- MudSample Preparation
Samples were stored at room temperature until analysis. No additional sample preparation methods were used on the samples.
Sample Analysis
On the date of analysis
, the entire sample (unused sand, flow back and mud) or a homogenized aliquot of the sample ( e.g. cuttin gs) was the n transferred to an air tight container for analysis.
The samples were analyzed for gamma ray producing nuclides using high purity germanium detectors (HPGe). Samples were distributed among the four (4) gamma detectors in the labora tory.

- Canberra Model GC 2019

- Canberra Model BE2825 (2 instruments)

- Nuclear Data Model RG

- 11 BC The data generated was analyzed using the APEX Software (Canberra v 1.3, 2011).
Please note that the sample analysis procedure for Radium

– 226 and Radium

– 228 is not validated for these matrices. The indirect measurement method using progeny radionuclides is employed for the analyses of Ra

226 and Ra

- 228 isotopes. The quantitation of Ra

- 226 is inferred from the quantitation of Pb

- 214 and Bi

- 214. The Ra

- 228 qua ntitation is inferred from the quantitation of Ac

- 228. 1, 2, 3

Results
The results for the gamma ray analysis of the six BRP samples received on October 1, 2012 are summarized in Table 1. Day 1 for the analyses is when the samples were transferred to the ap propriate air tight containers. All the samples were counted on day 1 to measure the activity of radionuclides. These samples were then allowed to equilibrate for 21 days prior to counting to compare with the results obtained on Day 1. Samples were equilibrated t o allow the radium progeny radionuclides to reach equilibrium: an equal decay rate of the elements in the dec ay chain from radium downwards.

References

1. Gilday, W. M., Edick, R. G., "An Investigation of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Wells in New York State", New York State Department of Environmental Conservation, April 1999. 2. Chang, K. M., “Analytical Methodology for the Determination of Radium Isotopes in Environmental Samples”, International Atomic Energy Agency, Vienna, 2010, IAEA Analytical Quality in Nuclear Applications No. IAEA/AQ/19. 3. Rowan, E.L., Engle, M.A., Kirby, C.S., Kraemer, T.F., “Radium Content of Oil

- and Gas

- Field Produced Water s in the Northern Appalachian Basin (USA): Summary and Discussion of Data, Scientific Investigation Report 2011

- 5135 (US Geological survey).Contd. Table 1

### Analysis of Environmental Samples for Gamma Ray Producing Nuclides
Ohio Department of Health Laboratory Radiation Chemistry 8995 East Main Street Building 22 Reynoldsburg, Ohio 43068

Introduction
This is a summary of the work flow for the analysis of the environmental samples to support the Bureau of Radiation Protection (BRP) investigation of samples from the oil and gas industry to determine the extent of naturally occurring radioactive materials (NORM). It is anticipated that the lab would expect t o analyze 30

- 40 samples over a month long period. The samples could include the following matrices:

1. Drill Cuttings 2. Drill fluids/muds 3. Frac Sands 4. Flowback Fluids 5. Production Fluids Additional samples for possible consideration include any new media found o n site to check on their initial background levels (new sands, new drilling mud, etc.).
Sample Receipt

Two samples were received at the Ohio Department of Health Laboratory on November 20, 2012 at 10:20 am

. (A copy of the Laboratory Analysis Request Form is attached). The samples were delivered by Mr. Robert Leidy and were received at room temperature. Upon receipt the sample information was input into the l aboratory’s sample receipt data base, and chain of custody signed. The following sample identifier s were provided by Mr. Leidy:
1) BRP

- 0 2

- 019

- 001

- PW

– Production Water 2) BRP

- 0 2

- 067

- 001

- US

– Unused SandSample Preparation
Samples were stored at room temperature until analysis. No additional sample preparation methods were used on the samples.
Sample Analysis
On the date of analysis the entire sample ( production water ) or a homogenized aliquot of the sample (e.g. unused sand ) w as the n transferred to an air tight container for analysis. The samples were counted for two hours.
The samples were analyzed for gamma ray producing nuclides using high purity germanium detectors (HPGe). Samples were distributed among the four (4) gamma detectors in the laboratory.

- Canberra Model GC 2019

- Canberra Model BE2825 (2 instruments)

- Nuclear Data Model RG

- 11 BC

The dat a generated was analyzed using the APEX Software (Canberra v 1.3, 2011).
Please note that the sample analysis procedure for Radium

– 226 and Radium

– 228 is not validated for these matrices. The indirect measurement method using progeny radionuclides is e mployed for the analyses of Ra

226 and Ra

- 228 isotopes. The quantitation of Ra

- 226 is inferred from the quantitation of Pb

- 214 and Bi

- 214. The Ra

- 228 quantitation is inferred from the quantitation of Ac

- 228. 1, 2, 3

Results
The results for the gamma ray an alysis of the six BRP samples received on November20 , 2012 are summarized in Table 1. Day 1 for the analyses is when the samples were transferred to the appropriate air tight containers and sealed with shipping tape . All the samples were counted on day 1 t o measure the activity of radionuclides. These samples were then allowed to equilibrate for 21 days prior to counting to compare with the results obtained on Day 1. Samples were equilibrated t o allow the radium progeny radionuclides to reach equilibrium: an equal decay rate of the elements in the dec ay chain from radium downwards.

References

1. Gilday, W. M., Edick, R. G., "An Investigation of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Wells in New York State", New York State Department of Environmental Conservation, April 1999. 2. Chang, K. M., “Analytical Methodology for the Determination of Radium Isotopes in Environmental Samples”, International Atomic Energy Agency, Vienna, 2010, IAEA Analytical Quality in Nuclear Applications No. IAEA/AQ/19. 3. Rowan, E.L., Engle, M.A., Kirby, C.S., Kraemer, T.F., “Radium Content of Oil

- and Gas

- Field Produced Waters in the Northern Appalachian Basin (USA): Summary and Discussion of Data, Scientific Investigation Report 2011

- 5135 (US Geological survey).

### Analysis of Environmental Samples for Gamma Ray Producing Nuclides
Ohio Department of Health Laboratory Radiation Chemistry 8995 East Main Street Building 22 Reynoldsburg, Ohio 43068

Introduction
This is a summary of the work flow for the analysis of the environmental samples to support the Bureau of Radiation Protection (BRP) investigation of samples from the oil and gas industry to determine the extent of naturally occurring radioactive materials (NORM). It is anticipated that the lab would expect t o analyze 30

- 40 samples over a month long period. The samples could include the following matrices:

1. Drill Cuttings 2. Drill fluids/muds 3. Frac Sands 4. Flowback Fluids 5. Production Fluids Additional samples for possible consideration include any new media found o n site to check on their initial background levels (new sands, new drilling mud, etc.).
Sample Receipt

Six samples were received at the Ohio Department of Health Laboratory on November 30 , 2012 at 10: 47 am

. (A copy of the Laboratory Analysis Request Form is attached). The samples were delivered by Mr. Robert Leidy and were received at room temperature. Upon receipt the sample information was input into the l aboratory’s sample receipt data base, and chain of custody signed. The following sample identifier s were provided by Mr. Leidy:
1) BRP

- 0 2

- 01 3

- 001

- Vertical Cuttings 2) BRP

- 0 2

- 013

- 002

- Horizontal Cuttings Utica 3) BRP

- 0 2

- 013

- 003

- Vertical Mud 4) BRP

- 0 2

- 013

- 004

- Horizontal Mud Utica 5) BRP

- 01

- 029

- 001

- Split Flow Back Water 6) BRP

- 01

- 217

- 001

- Used SandSample Preparation
Samples were stored at room temperature until analysis. No additional sample preparation methods were used on the samples.
Sample Analysis
On the date of analysis the entire sample ( production water ) or a homogenized aliquot of the sample (e.g

. cuttings ) w as the n transferred to an air tight container for analysis. The samples were counted for two hours.
The samples were analyzed for gamma ray producing nuclides using high purity germanium detectors (HPGe). Sam ples were distributed among these gamma detectors in the laboratory.

- Canberra Model GC 2019

- Canberra Model BE2825

- Nuclear Data Model RG

- 11 BC

The data generated was analyzed using the APEX Software (Canberra v 1.3, 2011).
Please note that the sample analysis procedure for Radium

– 226 an d Radium

– 228 is not validated for these matrices. The indirect measurement method using progeny radionuclides is employed for the analyses of Ra

226 and Ra

- 228 isotopes. The quantitation of Ra

- 226 is inferred from the quantitation of Pb

- 214 and Bi

- 214. The Ra

- 228 quantitation is inferred from the quantitation of Ac

- 228. 1, 2, 3

Results
The results for the gamma ray analysis of the six BRP samples received on November 30 , 2012 are summarized in Table 1. Day 1 for the analyses is when the samples were transferred to the appropriate air tight containers and sealed with shipping tape . All the samples were counted on day 1 to measure the activity of radionuclides. These samples were then allowed to equilibra te for 21 days prior to counting to compare with the results obtained on Day 1. Samples were equilibrated t o allow the radium progeny radionuclides to reach equilibrium: an equal decay rate of the elements in the dec ay chain from radium downwards.

References

1. Gilday, W. M., Edick, R. G., "An Investigation of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Wells in New York State", New York State Department of Environmental Conservation, April 1999. 2. Chang, K. M., “Analytical Methodolog y for the Determination of Radium Isotopes in Environmental Samples”, International Atomic Energy Agency, Vienna, 2010, IAEA Analytical Quality in Nuclear Applications No. IAEA/AQ/19. 3. Rowan, E.L., Engle, M.A., Kirby, C.S., Kraemer, T.F., “Radium Content of Oil

- and Gas

- Field Produced Waters in the Northern Appalachian Basin (USA): Summary and Discussion of Data, Scientific Investigation Report 2011

- 5135 (US Geological survey).

### Analysis of Environmental Samples for Gamma Ray Producing Nuclides
Ohio Department of Health Laboratory Radiation Chemistry 8995 East Main Street Building 22 Reynoldsburg, Ohio 43068

Introduction
This is a summary of the work flow for the analysis of the environmental samples to support the Bureau of Radiation Protection (BRP) investigation of samples from the oil and gas industry to determine the extent of naturally occurring radioactive materials (NORM). It is anticipated that the lab would expect t o analyze 30

– 40 samples over a month long period. The samples could include the following matrices:

1. Drill Cuttings 2. Drill fluids/muds 3. Frac Sands 4. Flowback Fluids 5. Production Fluids Additional samples for possible consideration include any new media found o n site to check on their initial background levels (new sands, new drilling mud, etc.).
Sample Receipt

Three samples were received at the Ohio Department of Health Laboratory on December 06 , 2012 at 01 : 56 p m

. (A copy of the Laboratory Analysis Request For m is attached). The samples were delivered by Mr. Robert Leidy and were received at room temperature. Upon receipt the sample information was input into the l aboratory’s sample receipt data base, and chain of custody signed. The following sample identifi ers were provided by Mr. Leidy:
1) BRP

- 0 3

- 992

- 001

- Cuttings 2) BRP

- 0 3

- 992

- 002

- Mud 3) BRP

- 0 3

- 992

- 003

- CuttingsSample Preparation
Samples were stored at room temperature until analysis. No additional sample preparation methods were used on the samples.
Sample Analysis
On the date of analysis the entire sample ( mud ) or a homogenized aliquot of the sample (e.g. cuttings ) w as the n transferred to an air tight container for analysis. The samples were counted for two hours.
The samples were analyzed for gamma ray pr oducing nuclides using high purity germanium detectors (HPGe). Samples were distributed among these gamma detectors in the laboratory.

- Canberra Model GC 2019

- Canberra Model BE2825

- Nuclear Data Model RG

- 11 BC

The data generated was analyzed using the APE X Software (Canberra v 1.3, 2011).
Please note that the sample analysis procedure for Radium

– 226 and Radium

– 228 is not validated for these matrices. The indirect measurement method using progeny radionuclides is employed for the analyses of Ra

226 and Ra

- 228 isotopes. The quantitation of Ra

- 226 is inferred from the quantitation of Pb

- 214 and Bi

- 214. The Ra

- 228 quantitation is inferred from the quantitation of Ac

- 228. 1, 2, 3

Results
The results for the gamma ray analysis of the three BRP samples received on December 06 , 2012 are summarized in Table 1. Day 1 for the analyses is when the samples were transferred to the appropriate air tight containers and sealed with shipping tape . All the samples were counted on day 1 to measure the ac tivity of radionuclides. These samples were then allowed to equilibrate for 21 days prior to counting to compare with the results obtained on Day 1. Samples were equilibrated t o allow the radium progeny radionuclides to reach equilibrium: an equal decay ra te of the elements in the dec ay chain from radium downwards.

References

1. Gilday, W. M., Edick, R. G., "An Investigation of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Wells in New York State", New York State Department of Environmental Conservation, April 1999. 2. Chang, K. M., “Analytical Methodology for the Determination of Radium Isotopes in Environmental Samples”, International Atomic Energy Agency, Vienna, 2010, IAEA Analytical Quality in Nuclear Applications No. IAEA/AQ/19. 3. Rowan, E.L ., Engle, M.A., Kirby, C.S., Kraemer, T.F., “Radium Content of Oil

- and Gas

- Field Produced Waters in the Northern Appalachian Basin (USA): Summary and Discussion of Data, Scientific Investigation Report 2011

- 5135 (US Geological survey).