The article points out studies conducted in the last five years have cast doubt on the effectiveness of oil and gas wastewater as a dust suppressant, including several at Penn State by Dr. William Burgos and a team of researchers.
Those studies from Penn State and other universities include--
-- New Penn State Study: Brine Water Pumped From Played-Out Conventional Oil & Gas Wells And Used As Dust Suppressants, Winter Road Treatments Exceed Environmental, Health Standards, Just Like Conventional Oil & Gas Brine Water [8.2.23]
-- New Penn State Study Finds Runoff From Conventional Oil & Gas Wastewater Dumped On Unpaved Roads Contains Pollutants That Exceed Human-Health, Environmental Standards [5.27.22] [This study was supported by funding from the Department of Environmental Protection.]
-- Penn State: Potential Health Impacts Of Oil and Gas Wastewater On Roads [6.21.18]
-- Penn State Study: Using Oil & Gas Well Brine As Dust Suppressant Less Than Ideal [5.31.18]
Pennsylvania regulatory agencies do not know the full extent of the conventional oil and gas wastewater dumping problem because on average conventional operators fail to submit the required annual waste generation and disposal reports covering more than half of conventional wells-- 60,000 wells. Read more here.
The Department of Environmental Protection has advised 18 municipalities where road dumping of oil and gas wastewater has occurred the practice is illegal and considered waste disposal. Read more here.
DEP labels a total of 84 townships as “waste facilities” where road dumping of the wastewater has occurred. Read more here.
DEP prohibited the road dumping of shale gas drilling wastewater in 2016 regulations.
DEP has not outright prohibited road dumping of conventional oil and gas wastewater, however, no operator has yet to meet the beneficial use provisions of DEP’s Residual Waste Regulations to use their waste in place of commercial products and the practice is illegal. Read more here.
The concerns raised about road dumping oil and gas wastewater have lead the Penn State Center for Dirt and Gravel Roads Studies [Read more here]; the Department of Conservation and Natural Resources [Read more here]; and the Allegheny National Forest [Read more here] to all adopt policies encouraging the use of other alternatives and against the use of this waste as a dust suppressant.
A member of the Penn State Center for Dirt and Gravel Roads Studies participated in this study and was one of the Journal article authors.
The Office of Attorney General was reported to be investigating conventional operators for illegally road dumping their wastewater. Read more here.
The typical road dumping of oil and gas wastewater on dirt roads involves a vac truck making three or more passes on each section of road using a combination of an open value on the back of the truck and then a blanket pass with a homemade spreader bar that offers no control on the amount of brine spread.
See Photos Here - Read more here. See Photos Here - Read more here.
Journal Article
Testing by Penn State researchers summarized in this latest Journal article found conventional oil and gas wastewater exceeded federal standards for 11 major chemical contaminants, including radioactive radium, trace metals, strontium, barium, iron, and manganese and had two times the saline concentrations of seawater.
For example, the article points out radioactive radium is a naturally occurring metal, but a known hazard to human health, with a primary drinking water standard of 5 pCi/L and an industrial wastewater discharge standard of 60 pCi/L.
Conventional oil and gas wastewater tested in the study had a combined radium activity [radium 226 & 228] of 2,500 pCi/L.
The Journal article noted some previous studies of radiation on unpaved roads found little radiation, but this study suggests the reason was the radium was washed off the roadbeds during rain events.
Another example, the EPA guideline for chloride concentrations in freshwaters is 230 mg/L to protect the health of aquatic systems.
Runoff from dirt roads treated with oil and gas wastewater would require a 37-fold dilution to meet that standard. However, chloride has been shown to induce toxic effects on aquatic life at concentrations far below the current 230 mg/L standard.
Does Not Meet Beneficial Use Criteria
“For a waste product to be a suitable candidate for beneficial reuse, it should meet two criteria: 1) the waste product performs as well as or better than the product it is replacing and 2) use of the waste product presents no greater risk to human or environmental health.”
“Based on results of this study, O&G PW [oil and gas wastewater] does not meet either of the recommended criteria for beneficial reuse as a dust suppressant.”
“The chemistry of the O&G PW [oil and gas wastewater] likely explains why they were ineffective at suppressing dust compared to most of the commercial products.
“Though the O&G PW [oil and gas wastewater] were hypersaline, which is critical for dust suppression using brines, they had high SAR values, meaning sodium ions were more abundant than divalent calcium and magnesium ions.
“Divalent cations are critical for adequate dust suppression because they bridge negatively charged particles together, stabilizing the roadbed.
“Because sodium is monovalent, it does not bridge road particles together and instead can lead to destabilization of the roadbed.”
“Spreading O&G PW on roads could decrease roadbed stability because the high sodium concentrations present in O&G PW can cause clay dispersion. Destabilization of the roadbed was observed during the rainfall-runoff experiments.”
“O&G PW [oil and gas wastewater] also pose unique risks to environmental and human health compared to the commercial products.
“All the radium from O&G PW3 [oil and gas wastewater] that was added to the roadbed during application was mobilized in the runoff, suggesting that roadbeds treated with O&G PW could be a source of radium to adjacent freshwater resources or roadside soils following rain events.”
“It is important to note that roads treated with either CaCl2 Brine or O&G PW both generated runoff that poses risks to adjacent freshwater quality, either through salinization or transport of trace metals.
“Contaminant concentrations in runoff exceeded thresholds designed to protect human and environmental health for over 8 [hour] during the storm event.”
Journal Article Conclusions
“Results from this study demonstrate that O&G PW do not meet the recommended criteria for beneficial reuse as a dust suppressant.
“Though O&G PW did suppress PM10 [particulate matter] under high humidity conditions relative to rainwater controls, commercial brines and most commercial organic products consistently performed more effectively.
“Similarly, the high sodium concentrations present in O&G PW likely led to clay dispersion and destabilized the roadbed, which could exacerbate dust emissions during dry conditions or increase TSS concentrations in runoff during storm events.
“Both scenarios pose risks to human and environmental health.
“In road-runoff experiments, measured concentrations in runoff generally reflected the concentration of the dust suppressant originally applied to the road.
“The highest concentrations were usually measured in runoff from roadbeds treated with CaCl2 Brine, and runoff from these roadbeds could contribute to freshwater salinization in roadside waterbodies.
“Runoff from roads treated with O&G PW was similarly hypersaline, though less so compared to roads treated with CaCl2 Brine.
“O&G PWs from the Appalachian Basin often contain elevated radium, and all excess radium added to the roadbed during O&G PW application was mobilized during the storm event.
“Therefore, runoff from roads treated with O&G PW could be a significant source of radium to roadside ecosystems.”
Click Here for a copy of the complete Journal article.
DEP Updating Conventional Regulations
In spite of the fact it is illegal to dump conventional oil and gas wastewater on roads, it is still happening unabated in conventional oil and gas drilling areas of the state, according to local citizen reports.
It is not clear what, if any action is being taken to stop the illegal practices.
Conventional operators are still fighting to make road dumping their wastewater legal. Read more here.
DEP is in the process of updating conventional oil and gas environmental protection and waste disposal and handling standards, after the last comprehensive update was killed by the General Assembly in 2016. Read more here.
(Photo: Road dumping conventional oil and gas wastewater.)
Related Articles - Road Dumping:
-- Conventional Oil & Gas Industry Still Fighting To Make Road Dumping Its Wastewater Legal; DEP Introduces Concepts Of A ‘Life Insurance Policy’ For Plugging Wells; Certified 3rd Party Inspectors [PaEN - 10.12.23]
-- Guest Essay: Take A Deep Breath! Now Think What You Just Inhaled. If You Live Along A Dirt Road You Could Be Inhaling Oil & Gas Wastewater - By Siri Lawson, Warren County [PaEN - 8.2.23]
-- Allegheny National Forest: Commercial Alternatives For Dust Suppression Makes The Practice Of Road Dumping Conventional Drilling Wastewater ‘Unnecessary’ On Roads [PaEN - 5.9.22]
-- Delaware River Basin Commission Clarifies New Regulations On Oil/Gas Fracking Wastewater Ban Road Spreading, Disposal From Conventional Wells [PaEN - 4.28.23]
-- Conventional Oil & Gas Well Owners Failed To File Annual Production/Waste Generation Reports For 61,655 Wells; Attorney General Continues Investigation Of Road Dumping Wastewater [PaEN - 2.22.23]
-- DEP Tells Citizens Advisory Council Road Dumping Conventional Oil & Gas Wastewater Still Does Not Meet Residual Waste Regulations; Remains Illegal [PaEN - 9.20.22]
-- DEP Advises 18 Municipalities Where Road Dumping Of Conventional Oil & Gas Drilling Wastewater Is Occurring The Practice Is Illegal And Considered Waste Disposal [PaEN - 5.31.22]
-- DEP Lists 84 Townships As ‘Waste Facilities’ Where Conventional Oil & Gas Wastewater Has Been Disposed Of By Road Spreading; Municipalities Need To Do Their Due Diligence [PaEN - 12.27.21]
-- Attorney General’s Office Reported To Be Investigating Conventional Oil & Gas Operators For Illegally Road Dumping Drilling Wastewater [PaEN - 4.22.22]
-- DCNR Bans Use Of Oil & Gas Wastewater On Its Over 6,500 Miles Of Dirt, Gravel Roads [PaEN - 1.25.22]
-- Better Path Coalition Report: How To Close The Loophole Allowing Uncontrolled Road Spreading Of Conventional Oil & Gas Wastewater & Fix Oil and Gas Waste Reporting System [PaEN - 12.13.21]
-- A First-Hand Account Of How Repeated, Unlimited Road Dumping Of Oil & Gas Drilling Wastewater Is Tearing Apart Dirt Roads And Creating Multiple Environmental Hazards [PaEN - 11.16.21]
-- Penn State Center For Dirt & Gravel Road Studies: Road Dumping Of Oil & Gas Wastewater To Control Dust Is Environmentally Unsound Practice [PaEN - 8.25.21]
-- Earthworks’ New Report, Interactive Map Tracks Disposal Of 380 Million Barrels Of PA Oil & Gas Drilling Wastewater, Including Road Dumping [PaEN - 9.11.19]
-- Op-Ed: Will Our Dirt Roads Again Be Used As Dumping Sites For Oil & Gas Well Wastewater - By Siri Lawson [PaEN - 3.22.19]
-- Op-Ed: The Story Behind Stopping Conventional Oil & Gas Brine Spreading On Dirt Roads - By Siri Lawson [PaEN - 6.26.18]
Related Articles This Week - Gas:
-- Penn State Study: Conventional Oil & Gas Wastewater Fails To Meet Beneficial Reuse Recommendations For Use As A Dust Suppressant [PaEN]
-- Western PA Residents Comment After A Year Of Shell Petrochemical Plant Operations [PaEN]
-- Citizen Complaint Leads DEP To Breakout Of Mariner East Pipeline Drilling Mud That Contaminated The Lake At Marsh Creek State Park, Chester County; Sunoco Pipeline Starts Cleanup [PaEN]
-- PUC Adopts Final Regulations Strengthening Operation, Construction Requirements For Intrastate Hazardous Liquids Pipelines [PaEN]
-- PJM, Electric Grid Operators Recommend Additional Steps To Overcome Vulnerabilities In Natural Gas Infrastructure To Ensure More Reliable Grid Operation [PaEN]
[Posted: February 20, 2024] PA Environment Digest
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