Thanks for this information, Helen. I live on a dirt road in Steuben
County. The road is graded at least once a year. After it is graded,
the road is sprinkled with brine to harden the road. Heavier
applications of the brine are put near houses to help keep the dust
down. I am inquiring as to the source of the brine. Several months ago
I noticed that a dirt road in our area that had not been graded was wet
for about half a mile. I checked with the Steuben DPW and they had not
applied anything to the road.
Rachel Treichler
Hammondsport, NY
Helen Slottje wrote:
Roadspreading of "Brine" from Natural Gas Wells in NY
In NY this process is regulated by a section 364 permit. DEC presently
distinguishes between "flowback" fluids which may not be used for road
spreading and "production brine" which may be used for road spreading. This
is just one reason why figuring out when fracturing fluids actually come
back to the surface - is it during the "flowback" period or is it during
"production?" The DEC is regulation "flowback" fluids differently from
production fluids but it seems like industry hasn't made full disclosure of
the different composition of these fluids with Marcellus Shale high volume,
high pressure horizontal hydrofracing operations.
Road spreading is addressed in the original GEIS at chapter 15:
"Brines and other fluids are generated during the drilling , completion and
production of oil and gas wells. As discussed in Chapter 9, fluids produced
during drilling and completion operations may be stored temporarily at the
well site but must subsequently be properly disposed of in accordance with
State regulatory requirements. The characteristics of drilling and
completion fluids are such that they are not well-suited for use on roads
because of variable concentrations of salts due to dilution with freshwater,
rainwater and fluids from other operations.
Most production brine in New York comes either from shallow oil wells or
from deep gas wells. The characteristics of the brines from these wells
differ significantly as shown in Tables 15.3 and 15.4. Because of the long
history of waterflooding operations i n New York State shallow oil wells,
the concentration of brine in shallow oil production waters has been
significantly diluted with time. Production fluids from deep gas and Bass
Island wells, on the other hand, have extremely high brine concentrations.
Table 15.5 from a Pennsylvania study compares the chemical characteristics
of commercial road salt , undiluted shallow oil brine and deep gas brine.
The characteristics of gas well brines are sufficiently similar to those
of commercial road salt so make them attractive to local highway departments
for use in road maintenance operations. Additional factors stimulating their
use are the relatively low cost of brines and the need by producers for a
means to properly dispose of these fluids. Until recently, towns have used
commercial salts for such maintenance operations, but oil and gas brines
have been utilized increasingly as a substitute at a substantial monetary
savings. An estimated 90 percent of a l l brine produced in gas and new oil
fields in New York State is now hauled off site and spread over roads for
dust and ice control. The majority of brine used in road spreading in New
York is derived from deep gas well production; the diluted brines from the
old shallow waterflooded oil fields is not used.
Hauling of brines for use on roads is regulated by the DEC Division of
Solid and Hazardous Waste (DSHW) under 6 NYCRR Part 364, under which any
person who desires to transport any type of industrial waste must first
obtain a permit. Oil and gas drilling and production brines are considered
industrial waste and, as such, are subject to the requirements of Part 364
for transportation and use. Brine may be spread on paved and unpaved roads
under Part 364 permits, but approval from the locality is required on the
permit application. A standard condition for these permits is that the
applicant must receive written approval from the highway superintendent or
the town supervisor before road spreading salt brine. All oil must be
separated from the brine solution and a spreader bar or similar spray must
be used with the proper application rate to eliminate runoff. Spreading must
also be confined to daylight hours. Most permitted brine spreading is done
by commercial haulers or by oil and gas company haulers . Spreading of brine
for shoulder stablization or ice control is generally performed by the town,
and some towns utilize their own resources to spread brine for dust control
on unpaved roads. DEC records for 1986 show that statewide approximately 13
million gallons of brine were transported by 18 permitted haulers,
4 of which were municipalities. This is equivalent to some 16,000 tons of
dry highway salt in comparison to the 55,000 tons of salt used in DEC Region
9 just by the New York State Department of Transportation in the winter of
1981/82; counties and towns also used substantial amounts of road salt.
Towns which receive brine under Part 364 permits are shown in Figure 15.1.
Since 1985, thre has been a 40 percent increase in the muncipalities which
will accept production brine. (Table is attached.)
Road spreading is addressed in the draft sGEIS in Appendix 12. In January
2009, the DEC sent a letter to Section 364 permit holders (attached as
Appendix 12 to the draft SGEIS) informing them that "fracture fluids
obtained during flowback operations may not be spread on roads and must be
disposed at facilities authorized by the Department." Production brine may
still be spread for "road de-icing, dust suppression or road stabilization."
Helen Slottje
On 10/11/09 10:14 AM, Gxxxx wrote:
Kxxxxx,
My understanding is that the expectation that 10 percent of the fracking fluid
would be recycled was based on the experience of the industry in Texas and
Wyoming. The rate of water usage in the Barnett Shale formation in Texas was
also the basis of the Susquehanna River Basin Commission estimates of how much
water would be consumed by the industry.
The reality has been that fracking in the wells in Pennsylvania is taking much
less water than expected. It's being attributed to the apparent need for
higher salinity in their fracking fluids, and that as a result the drillers in
Pennsylvania are recycling much more water than they are in Texas.
Given the apparent 2nd- or 3rd-World level character of environmental
regulations in those states, and their respective rural road systems, the
spreading of used fracking fluids on dirt roads may well be legal in
Wyoming or Texas. The practice would certainly explain for me the extent of
the groundwater pollution and private water well contamination in Wyoming.
It may also be one of those practices that are exempt from the Federal Clean
Waters Act.
Pennsylvania however has very few dirt roads left and moreover has its own
version of the Clean Waters Act that the natural gas drilling industry is not
exempt from. As a result, unlike perhaps in Texas and Wyoming, the disposal
of the used water coming back out of the wells is tightly regulated in
Pennsylvania.
I'm thus pretty certain that in Pennsylvania (and hopefully in New York) the
practice of spreading used fracking fluids on roads is not legal..
I will however confirm this and report back if I am wrong.
Gxxxxx
--- On Sun, 10/11/09, xxxxx wrote:
From: Kxxxx
Subject: [SustainableTompkins] reuse of fracking fluid
To: [email protected]
Date: Sunday, October 11, 2009, 2:32 AM
At the Schlumberger Open House last month in Horseheads, I spent about 90
minutes in a 1-on-1 conversation with the man who heads up the whole operation
there. It was his contention that they would be recovering and recycling
approximately 10% of the fracking fluid, and the other 90% would either come
up gradually over time in the produced water, or be lost into the system, and
never recovered. I did not find this information at all comforting, especially
in light of the fact that produced water is far less tightly-regulated, and
may even be spread legally on roads, as I understand things currently.
------------------------------------------------------------------------
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_______________________________________________
For more information about sustainability in the Tompkins County area, please
visit: http://www.sustainabletompkins.org/
RSS, archives, subscription & listserv information for:
[email protected]
http://lists.mutualaid.org/mailman/listinfo/sustainabletompkins
Questions about the list? ask [email protected]
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