Adding-- “the use of O&G PWs on Program funded [Dirt & Gravel Road] projects is in opposition with not only the fundamental goals of the Program, but the law that created the Program.”
Chase made the comments before a House Environmental Resources and Energy Committee hearing on legislation that would ban road spreading oil and gas wastewater.
“In my position at the Center, I coordinate all aspects of research to support Pennsylvania's $35-million Dirt, Gravel and Low-Volume Road Maintenance Program (Program),” Chase said.
“The Program’s goal is to implement Environmentally Sensitive Maintenance Practices aimed at reducing the environmental impacts of public roads while reducing long-term maintenance costs.”
“My research in support of the Program focuses on road surface aggregate selection, road maintenance and dust/sediment production from unpaved roads in collaboration with agencies such as the US Forest Service, US Fish and Wildlife Service, Susquehanna River Basin Commission and Trout Unlimited.”
“In recent years I have collaborated with the [Penn State] Department of Civil and Environmental Engineering at Penn State on research evaluating the environmental impacts of oil & gas produced water disposal practices, including brine spreading in Pennsylvania. I have been a co-author and advisor on several papers that have been published in well regarded peer-reviewed scientific journals.
“As assistant director of the Center, I coordinate the product approval process for the Program, which is responsible for reviewing and approving products such as soil stabilizers and dust suppressants for Program funding eligibility.
“The Program’s product approval process started more than 20 years ago with the goal of testing products used on roads in a rigorous manner which can support a conclusion that use of the product is reasonably certain to cause no harm to the environment.
“This goal aligns with Section 9106 of the motor vehicle code that established the Dirt, Gravel and Low-Volume Road Maintenance Program which states that counties must adopt “standards that prohibit use of materials or practices which are environmentally harmful.””
“On the topic of effectiveness, our research has shown through bench scale testing that O&G PWs do not perform as well as commercially available dust suppressants due to the high sodium content.
“The high sodium content decreases the dust suppression effectiveness compared to commercial calcium based brines and can also destabilize the road.”
Chase noted their studies shows oil and gas wastewater “did not perform significantly better than rainwater in suppressing dust and did not significantly reduce sediment runoff compared to rainwater.
“In contrast, commercial calcium based brines and other commercially available dust suppressants did reduce dust generation and sediment runoff.”
“[Oil and gas wastewaters] raise potential environmental concerns due to the chemicals found in the waters. One study on the chemical composition of conventional O&G PWs spread on roads in Pennsylvania published in 2018 found elevated concentrations of total dissolved solids (TDS), chloride, bromide, radium, barium, and in some cases, petroleum hydrocarbons [Tasker et al 2018].”
“This study showed that the median chloride concentration was 183,000 mg/L, as compared to the drinking water standard for chloride of 250 mg/L, which is used in the Program’s Product approval process testing requirements as a maximum concentration limit (for reference chloride in seawater is around 20,000 mg/L).
“This Program’s product approval limit of 250 mg/L chloride has been in place for over 20 years and no chloride-based dust suppressants have ever been used within the Program because of the difficulty meeting this criteria.”
“Additionally, the Program’s Product approval process includes aquatic toxicity testing for rainbow trout and chloride concentrations have been shown by the USEPA to be toxic to trout species at levels 20 times lower than found in O&G PW [oil and gas wastewater].”
“Finally, five O&G PWs from Pennsylvania contained radium levels from 84 to 2,500 pCi/L, which fall above the Program’s product approval process limit of 15 pCi/L,” Chase said.
“Therefore, O&G PWs would not qualify for use or funding within the program due to failing multiple environmental testing protocols and posing a potential environmental harm which are counter to the Program’s goals.”
Conclusion
“In summary, O&G PWs are not effective at suppressing dust and pose potential environmental harm and due to high levels of chloride and radium would not pass the testing requirements to be eligible for Program funds.
“Ultimately, the use of O&G PWs on Program funded projects is in opposition with not only the fundamental goals of the Program, but the law that created the Program.”
Click Here for Eric Chase’s written testimony.
Click Here to watch a video of the hearing.
Hearing Key Takeaways On Road Dumping
Here are a few of the key takeaways from the Committee’s June 10 hearing on road dumping--
-- Water Is Just As Effective: The Penn State Center for Dirt and Gravel Road Studies said studies show plain water is just as effective as oil and gas wastewater at dust suppression, without the negative environmental and health side effects. What’s cheaper than water?
-- Dirt Road Construction/Maintenance Critical: Putting liquids on roads that dry out in a few hours will not solve the dust problem or do anything to protect residents. Using proper road construction and maintenance techniques and the right materials will go a long way to significantly reduce dust and improve the traveling surface.
The Penn State Center for Dirt and Gravel Road Studies has worked on these issues for decades and pioneered the use of techniques and materials that work effectively. Call them, they can help!
-- Wastewater Dumping Has Moved To Paved Roads: Local citizens report oil and gas wastewater dumping has moved from dirt and gravel roads to paved roads because it’s faster to dump their loads with less evidence they are doing this illegal practice. With this move, the justification for legalizing this disposal method for dust suppression has also evaporated. It is simply disposal.
-- Wastewater Dumpers Wait For Rain: Local citizens report wastewater dumpers typically wait until there is rain in the forecast to start dumping to help hide their tracks. As a result, the pretense the dumpers pay any attention to any guidelines for dumping wastewater also disappears. It is simply disposal.
-- Filled With Harmful Contaminants: For nearly 30 years, studies have all shown the same thing-- oil and gas wastewater contains many harmful contaminants that exceed health and environmental standards. Penn State research found 25 contaminants in conventional wastewater exceeded health and environmental standards.
-- Conventional Wastewater Fails Product Testing: The Penn State Center for Dirt and Gravel Road Studies reported conventional oil and gas wastewater fails to meet its environmental testing standards, including for sodium, chloride and radioactive radium. Radioactive radium levels varied from 84 to 2,500 pCi/L, far above the 15 pCi/L standard.
-- Little Difference Between Conventional And Shale Gas Wastewater: Penn State reported there is very little difference between conventional and unconventional oil and gas wastewater, except the road dumping of unconventional shale gas wastewater was banned by DEP in 2016 regulations.
Rep. Greg Vitali (D-Delaware) serves as Majority Chair of the House Environmental Committee and can be contacted by calling 717-787-7647 or sending email to: gvitali@pahouse.net. Rep. Martin Causer (R-Cameron) serves as Minority Chair and can be contacted by calling 717-787-5075 or by sending email to: mcauser@pahousegop.com.
(Photos: Examples of how oil and gas wastewater impacts road stability, creating mini-potholes and not solving the dust problem..)
NewsClips:
-- PA Environmental Council Supports Bill To Ban Road Dumping Oil & Gas Wastewater [PaEN]
-- The Center Square - Anthony Hennen: Road Dumping Oil & Gas Wastewater For Dust Suppression Called Into Question
House Action/Hearing On Road Dumping:
-- House Committee Reports Out Bills To Ban Road Dumping Conventional Oil & Gas Wastewater; Prohibit Use Of PFAS 'Forever Chemicals’ In Consumer Products [PaEN]
-- House Hearing: Shapiro Administration Supports Bill Banning Road Dumping Oil & Gas Wastewater, Prohibiting Its Use As Coproduct Under Residual Waste Regulations [PaEN]
-- House Hearing: Penn State Expert Says ‘Pennsylvania Should Ban Road Spreading Of Oil & Gas Wastewater;’ Contaminants Exceed Health, Environmental Standards [PaEN]
-- House Hearing: Penn State Center For Dirt & Gravel Road Studies Says Road Spreading Oil & Gas Wastewater Is Not An Effective Dust Suppressant, Does Not Meet Environmental Testing Standards [PaEN]
-- House Hearing: 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]
-- House Hearing: Protect PT - Road Dumping Oil & Gas Wastewater ‘Is Disproportionately Responsible For Negative Impacts On Human Health,’ Especially From Radioactive Radium [PaEN]
-- House Hearing: On Road Dumping Oil & Gas Wastewater - ‘We Studied This For Nearly 30 Years And The Conclusions Are The Same - The Wastewater Contains Harmful Contaminants’ [PaEN]
-- House Hearing: PA State Assn. Of Township Supervisors Opposes Ban On Road Dumping Conventional Oil & Gas Wastewater Saying It’s Only Affordable Option For Dust Suppression [Plain Water Works Just As Well] [PaEN]
-- House Hearing: Conventional Oil & Gas Industry Trade Groups Oppose Bill Banning The Road Dumping Their Wastewater Saying It’s ‘Effective And Safe’ [PaEN]
Road Dumping Intimidation:
-- Week 10: Illegal Dumping Of Conventional Oil & Gas Wastewater Continues Unabated On Paved, Dirt Roads, Before It Rains, It Doesn’t Matter In Warren County [PaEN - 5.30.24]
-- Illegal Wastewater Dumping Continues, Even On Mothers Day, Conventional Oil & Gas Well Owners’ Campaign Of Intimidation Of Senate Witness; Now Dumping Before It Rains, On Paved Roads [PaEN - 5.14.24]
-- Two Months: Road Dumping Conventional Oil & Gas Wastewater Continues To Surround The Home Of A Senate Witness Who Opposes The Illegal Practice [PaEN - 5.7.24]
-- Road Dumping Continues At Will As Conventional Oil & Gas Well Owners Get Rid Of Their Wastewater [PaEN - 4.5.24]
-- Spring Road Dumping Season Underway As Conventional Oil & Gas Operators Get Rid Of Their Wastewater [PaEN - 3.19.24]
Resource Links - Senate Hearing On Road Dumping:
-- Senate Hearing: The Case For An Immediate, Total Ban On Road Dumping Conventional Oil & Gas Wastewater [PaEN]
-- Senate Hearing: Penn State Expert: ‘No More Research That Needs To Be Done’ To Justify A Ban On Road Dumping Conventional Oil & Gas Wastewater [PaEN]
-- Senate Hearing: First-Hand Account Of Health, Environmental Impacts From Road Dumping Conventional Oil & Gas Wastewater - ‘Inhaling Oil & Gas Wastewater 24-Hours A Day’ [PaEN]
-- Senate Hearing: 3.5 Million Gallons Of Conventional Oil & Gas Wastewater Dumped On PA Public Roads Since DEP’s ‘Moratorium’ On Dumping Started 6 Years Ago [PaEN]
-- Senate Hearing: DEP Still Evaluating The Data On Road Dumping Conventional Oil & Gas Wastewater; Asks Public To Report Road Dumping [PaEN]
-- DEP: 86% Of Conventional Oil & Gas Well Owners Did Not Comply With Waste Disposal, Production Reporting For 33,505 Wells In 2023 [PaEN - 3.29.24]
[Posted: June 10, 2024] PA Environment Digest
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