PA Environment Digest Blog: On-Site Conventional Oil & Gas Drilling Waste Disposal Plans Making Hundreds Of Drilling Sites Waste Dumps

Randomly selected individual on-site drill cutting and wastewater disposal plans submitted by conventional oil and gas drillers call for drilling wastes to be “dispersed directly to the environment,” according to a review by PA Environment Digest.

The plans are authorized under DEP’s existing oil and gas regulations and approved by the agency. Read more here.

Five of the six companies in the sample used the very same language to describe their on-site disposal plans-- regardless of their location, topography, surrounding vegetation or forest cover.

The sixth company used the very same format as the others, only copies of those submissions did not include the actual description of their on-site disposal plan.

Through a Right To Know request, PA Environment Digest reviewed 12 randomly selected alternative on-site waste disposal plans submitted by conventional oil and gas operators from the 721 conventional operator plans DEP approved between 2016 to 2021. Read more here.

The request asked for plans using the practice of “dusting” -- the decades-old practice of forcefully removing drill cuttings from the well borehole by dispersing them directly to the environment. Read more here.

Plan Contents

The form DEP asks conventional operators to fill out to authorize on-site disposal of waste through “dusting” is two pages long.

Of the 12 submissions reviewed, the completed plans submitted by operators were no more than five pages long, including some that featured maps showing well locations.

The actual description written by the operators of on-site disposal plans using “dusting” and surface disposal of wastewater were only four short paragraphs long and used the very same language.

Each of these four paragraph written by operators started the same way-- “Drill cuttings and top-hole water will be dispersed directly to the environment, rather than into a pit.”

“Where the drilling operation is located in proximity to a watercourse and “dusting” is to be employed, the water will be contained by a temporary drill pit or steel tank, if enough vegetative filter strip does not exist to prevent discharges to the ground from flowing overland and directly reaching the watercourse.

“When implementation of a temporary drill pit or steel tank is necessary, fluid will be pumped directly from the pit or tank through pipe for a sufficient distance away from the stream prior to discharge to insure that sufficient vegetative filter strip is provided.

“Dispersal lines will be employed as necessary to prevent the discharge from creating channels and flowing directly to surface waters.

[Note: Regardless of whether pits or tanks are actually used, the wastewater is still pumped over the surface of the ground for disposal.]

“Fluid handling will be performed in a manner to insure sufficient distribution to prevent erosion as a result of discharge. Drill cuttings will be incorporated into the soil.

“Ph and conductivity will be tested and reported according to regulations.”

Warnings To Farmers

Residents where conventional oil and gas drilling occurs said conventional drillers sometimes warn dairy and livestock farmers not to graze their animals or raise crops where they have buried drill cuttings or covered over wastewater lagoons.

84 Townships Already Listed By DEP As Waste Facilities

The Department of Environmental Protection’s Current List Of Oil And Gas Waste Facilities identifies 84 municipalities in 13 counties where conventional oil and gas wastewater is disposed of by road spreading as “waste facilities.” Read more here.

DEP Advised 18 Municipalities Against Road Dumping Drilling Wastewater

On April 13, the Department of Environmental Protection advised 18 municipalities in four counties the road dumping of conventional oil and gas drilling wastewater is illegal and considered waste disposal. Read more here.

Randomly Selected On-Site Waste Disposal Plans

The randomly selected plans included--

-- Cameron Energy: Forest County, Howe Township. 7.30.21

-- Curtis Oil, Inc.: Forest County, Howe Township. 7.28.21

-- Howard Drilling: McKean County, Wetmore Township. 10.8.21

-- Johnson Well Services: Warren County, Mead Township. 9.6.21

-- PennHills Resources: McKean County, Wetmore Township. 8.19.21 [Disposal Plan Not Provided, Same Format]

Practice Is Pervasive In Conventional Drilling

As previously reported by PA Environment Digest, the practice of “dusting” and on-site surface disposal of wastewater is pervasive in the conventional industry. Read more here.

As of April 20, 2022, 529 of the 721 wells covered by alternative on-site drill cuttings disposal plans were “spud” or drilled, according to DEP-- meaning at least 76 percent of the conventional wells drilled from 2016 to 2021 disposed of their drill cuttings on-site by “dusting” and surface wastewater disposal. Read more here.

Health Impacts

Witnesses to “dusting” operations frequently see clouds of drill cuttings-- dust and rock shards of various particulate sizes-- blown from the drilling site and move away from a well pad, sometimes for hundreds and thousands of feet.

As the drill cutting cloud moves, the particulate covers cars, houses, swing sets, yards, and anything else in its path with a grit that is difficult to clean off and that can damage painted surfaces.

Smaller particulate matter from “dusting” can drift further in the air and presents a direct risk to health.

Human exposure to particulates may impair lung function, aggravate asthma symptoms, cause irregular heartbeat and heart attacks, and lead to premature death in those with heart and lung diseases, such as chronic obstructive pulmonary disease (COPD), according to the U.S. Environmental Protection Agency. Read more here.

The smaller the particulate matter, the greater the health risk. For example, ultrafine particulate can travel deep into the lungs causing inflammation and long-term, organ-related health issues. Read more here.

Similar health impacts can affect farm animals and pets.

On May 26, Penn State University and the Department of Environmental Protection released a new study of spreading conventional oil and gas wastewater on unpaved roads by Penn State researchers, who found the wastewater running off the roadways after spreading contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards. Read more here.

What’s Supposed To Happen

According to DEP, if “dusting” operations are done properly, “uncontaminated” drill cuttings are forcefully pushed out of the well by compressed air and travel through a “drill rig diverter” to be blown onto the ground around the well pad.

DEP said, “usually, there is only enough force generated by the rig to expel the cuttings approximately 100 feet.”

To help control fugitive dust emissions, DEP suggests spraying water on the wellbore while drilling is occurring, a practice also used by water well drillers.

“Any dust leaving the well site would be considered a violation under DEP’s Air Quality regulations,” specifically of 25 Pa Code Chapter 123, DEP said.

DEP said Bureau of District Oil and Gas Operations staff are supposed to receive a three-day electronic notification from unconventional oil and gas drillers prior to the start of “dusting” operations under 25 Pa Code Section 78a.61.

DEP asks residents to notify the agency of any suspected violations of these requirements: Call 1-800-541-2050 or Submit An Online Complaint.

DEP Taking 2nd Look At On-Site Waste Disposal

On April 25, Kurt Klapkowski, Acting DEP Deputy Secretary for Oil and Gas Management, told the DEP Oil and Gas Technical Advisory Board the new conventional oil and gas well plugging program funded by the federal Bipartisan Infrastructure Law is prompting a review of regulations allowing on-site disposal of radioactive and nonradioactive well plugging waste. Read more here.

“This is an issue that has been identified internally, it's actually even broader than just the radiation concerns [with waste], there's a broader waste management concern here, even for non-radioactive plugging waste,” explained Klapkowski.

“I think there are methods that were used in the past that didn't, may not quite work now. There are some options for waste management that involve on-site disposal.

“I'm concerned about creating, you know, 50 mini disposal sites across the Commonwealth-- is that actually like a sound waste management practice? Read more here.

Opportunity To Change Waste Regulations

DEP is now in the process of updating its regulations covering conventional oil and gas drilling and has the opportunity to reevaluate the practice of “dusting” and on-site disposal of drill cuttings and liquid wastewater. Read more here.

A new study of drilling wastewater released by Penn State on May 26 again found conventional drilling wastewater runoff contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards. Read more here.

On April 25, Kurt Klapkowski, Acting DEP Deputy Secretary for Oil and Gas Management, told the DEP Oil and Gas Technical Advisory Board he hopes to have a draft rulemaking covering conventional oil and gas waste processing and disposal ready for public review by the Board’s meeting on July 18. Read more here.

Klapkowski said the rulemaking changes will focus on requirements in 25 Pa Code Chapter 78, Subchapter C which covers the onsite storage, processing and disposal of drill cuttings and wastewater from oil and gas wells. Read more here.

(Photos: Conventional drilling rig during “dusting” operations; drill cuttings of various particulate sizes deposited on a car hood; formerly white paper filter from a high volume ambient air sampling showing dirty gray drill cuttings from “dusting.”)

Companion Article:

-- Conventional Oil & Gas Drillers Dispose Of Drill Cuttings By ‘Dusting’ - Blowing Them On The Ground, And In The Air Around Drill Sites

PA Environment Digest

-- Compilation of Articles Related To Impacts Of Conventional Oil & Gas Drilling

Monday, June 6, 2022

On-Site Conventional Oil & Gas Drilling Waste Disposal Plans Making Hundreds Of Drilling Sites Waste Dumps

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