I have a dried plant I keep in my freezer. It is an invasive weed
imported from China to Tennessee because it is one of the few plants
that will grow where toxic minerals from coal formations have been
released on the surface (pyrite, cobalt, etc. take on toxic forms when
exposed to air and water). This boring and invasive plant is used when
"restoring" land after surface mining such as mountaintop removal.
Frack water will often contain these same toxic minerals.
This is not a pretty plant. Do we want it replacing Queen Anne's
lace, asters, goldenrod, milkweed, and our other lovely roadside
flowers?
These minerals--which geologists say will be in spent frack water--
should not be released in anyone's ecosystem.
Margaret
PS I'm bringing the plant with me to Bioneers. I'll have it at the
forum on MTR and fracking.
On Oct 12, 2009, at 11:42 AM, George Frantz wrote:
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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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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_______________________________________________
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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