Thanks Helen for raising a very important issue!
My comments with regard to road spreading were specific to use of flowback
waters during the actual drilling, not the potential use of the brine that gas
wells can produce while in production.
It's scary enough to think of what might be coming out of older wells that did
not undergo fracking, without having to think of the consequences of NYS-DEC
permitting the spreading of brine from Marcellus Shale formation production
wells.
I think that the new rules have to be very explicit in prohibiting the
spreading of brine from wells where fracking has been used.
George Frantz
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
>
>_______________________________________________
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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]
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Questions about the list? ask [email protected]
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