Adding-- “The DEP understands that there are and will continue to be environmental and public health concerns related to the potential impacts of oil and gas brine spreading in Pennsylvania.”
The hearing was organized by Sen. Katie Muth (D-Chester), Chair of the Committee, and Sen. Carolyn Comitta (D-Chester), Minority Chair of the Senate Environmental Resources and Energy Committee, to examine the environmental and public health impacts associated with disposing of conventional oil and gas wastewater on public roads.
Unauthorized Practice
DEP said, “Road spreading of brine is currently not an authorized practice in
Pennsylvania and DEP takes enforcement action in instances where it becomes aware of unauthorized spreading.”
DEP’s written testimony did not offer examples of the enforcement action DEP has taken related to road dumping conventional oil and gas wastewater..
Public Asked To Report Dumping
“DEP encourages members of the public who observe potentially unauthorized road spreading of brine to report the activity to their closest DEP Regional Office.”
[Note: Citizens can also call DEP’s 24-hour statewide complaint line 800-541-2050 or submit a complaint online. Citizens can also text locations and photos of conventional wells to: 717-788-8990.]
Studies Raise Concerns
“Recent studies raise questions about the safety of the application of these brines due to potential runoff of contaminants of concern contained in the brines—as compared to pure salt brine used for de-icing roads—and potential impacts to the waters of the Commonwealth and drinking water supplies.
“Concerns have also been raised about the effects of brine salinity on the water quality of bodies of water into which brines may enter.”
No Successful Co-Product Determinations
DEP’s statement notes conventional oil and gas well owners attempted to use the Residual Waste Regulation “co-product” determination process to have their wastewater approved for road dumping by comparing it to a commercial “product.” [25 PA Code Chapter 287.8]
DEP said its Waste Management Program reviewed responses from 27 conventional operators in 2022 to determine if any complied with the “co-product” regulations and none did.
DEP identified three more operators from waste reports who reported road dumping their wastewater and requested “co-product” documentation from them.
“The DEP has sent letters requesting documentation from these operators and is awaiting their responses.
“The Department will take appropriate regulatory action once responses are received.”
DEP’s written testimony did not include examples of enforcement actions against any of the conventional well owners who failed to comply with the “co-product” regulations and therefore were road dumping wastewater illegally.
Doesn’t Matter If It Doesn’t Work
DEP’s testimony argues that conventional oil and gas well owners are not required to prove their wastewater actually works to be considered a “co-product.”
“For persons making a co-product determination where they are comparing a waste to a product or produced raw material, there is not a required evaluation of the ability of the waste to function effectively for its intended use, or at the same level of efficacy as the product or produced raw material it is replacing.”
“The information in the [Penn State] study about the efficacy of the oil and gas brines doesn't appear to be something that is required to be considered when performing a coproduct determination that compares a waste to a product or produced raw material.
“As a result, if a valid coproduct determination can be made that adequately compares brine to a commercially available product, even if it may not be as effective as other road-spreading products, it’s possible that oil and gas waste brine may continue to be spread as a dust suppressant (emphasis added).”
DEP’s testimony did not mention the other criteria in 25 PA Code Chapter 287.8 co-product determination process--
-- “A proposed coproduct may not present a greater threat of harm to human health and the environment than use of an intentionally manufactured product or produced raw material.”
-- ”A person performing a coproduct determination shall demonstrate that the proposed coproduct does not present a threat of harm to human health and the environment and the hazardous or toxic constituents are not biologically available.”
In fact, the Penn State referenced found the amounts of at least 25 of the chemicals they tested for in conventional oil and gas wastewater exceeded environmental and health standards and radioactive radium exceeded industrial waste discharge standards. Read more here.
Another Penn State study released last August, found “commercial product” brine water pumped from played-out conventional oil and gas wells and used for dust suppressants and winter road treatments also significantly exceeded environmental and health standards for 11 major chemical contaminants, including radioactive radium, just like brine water from conventional oil and gas wells regulated by DEP. Read more here.
A third Penn State study found conventional oil and gas wastewater fails to meet the US Environmental Protection Agency beneficial reuse criteria. Read more here.
Click Here for a copy of DEP’s written testimony submitted to the Committee.
A video of the hearing is posted on Sen. Muth’s website.
Resource Links:
-- Photos Of Typical Road Dumping: See Photos Here + See Photos Here
Hearing Testimony
-- Dr. William Burgos, Penn State Professor of Environmental Engineering. Written Testimony + Journal Article/Research Paper Showing Conventional and Shale Gas Wastewater Very Similar
-- David Hess, Former Secretary of DEP under Governors Ridge and Schweiker. Written Testimony.
-- Siri Lawson, Warren County resident, significantly impacted by road dumping. Written Testimony
-- Karen Feridun, Better Path Coalition, who has done important research into waste reporting and related issues on conventional road dumping. Written Testimony
-- Department of Environmental Protection Written Testimony Only
Related Articles - Road Dumping Hearing:
-- 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]
PA Oil & Gas Industry Public Notice Dashboards:
-- Attorney General Henry Files Charges Against Shell Falcon Pipeline For Failure To Report Drilling Issues That Caused Industrial Waste, Potential for Water Pollution [PaEN]
-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - April 20 [PaEN]
-- DEP Posted 74 Pages Of Permit-Related Notices In April 20 PA Bulletin [PaEN]
Related Articles This Week - Gas:
-- PA Marcellus Shale Gas Coalition Doubles-Down On Support For Exporting PA Natural Gas To China, Our Economic, Military Competitor [PaEN]
-- Bloomberg: Europe’s Demand For LNG Gas Set To Peak In 2024 As Crisis Fades
-- Commonwealth Court Affirms EHB Ruling Sen. Muth Lacks Standing To Appeal A DEP Permit For Eureka Resources Oil & Gas Wastewater Treatment Facility [PaEN]
-- Protect PT Hosting April 30 Webinar On How Your Municipality Can Protect Itself From The Dangers Of Oil & Gas Wastewater Injection Wells [PaEN]
-- Susquehanna River Basin Commission Holds May 2 Hearing On Water Use Requests, Including 7 Shale Gas Drilling Uses In Lycoming, Susquehanna, Tioga, Wyoming Counties [PaEN]
-- Guest Essay: Claims That Only Thermal Energy Resources Can Ensure Electric Grid Reliability Don’t Pass The Laugh Test - By John Quigley, Kleinman Center For Energy Policy, University of Pennsylvania [PaEN]
NewsClips - Gas:
-- Environmental Health Project: Gov. Shapiro’s Record On Shale Gas And Health - A Look At The Grand Jury Recommendations One Year In
-- The Allegheny Front - Reid Frazier: Attorney General Files Criminal Charges Against Shell Falcon Pipeline On Whistleblower Reports Over Pipeline Spills
-- PA Capital-Star: Democratic State Senators Want To End Road Dumping Conventional Oil & Gas Wastewater
-- MyChesterCounty.com: PA Senators Call For Ban On Spraying Conventional Oil & Gas Wastewater On Roads
-- Post-Gazette - Anya Litvak: PA Oil & Gas Wastewater Treatment/Disposal Company Was Building A Conglomerate; What’s Left Is A Pile Of Waste
-- Warren Times Editorial: Government Too Quick To Use Taxpayer Money To Plug Abandoned Conventional Wells
-- Chesapeake Bay Journal - Ad Crable: Power, Pipeline Corridors Becoming Wildlife Habitat
-- The Guardian: Carbon Dioxide Pipeline Leak Exposes Carbon Capture Safety Gaps In Louisiana April 3
-- The Energy Age Blog: PA Oil & Gas Well Terminology From DEP
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