{"id":435,"date":"2010-08-17T14:25:39","date_gmt":"2010-08-17T18:25:39","guid":{"rendered":"http:\/\/sootypaws.net\/blog\/?p=435"},"modified":"2022-04-29T14:27:16","modified_gmt":"2022-04-29T18:27:16","slug":"fracture-waste","status":"publish","type":"post","link":"http:\/\/sootypaws.net\/blog\/2010\/08\/fracture-waste\/","title":{"rendered":"Fracture Waste"},"content":{"rendered":"\n

\nIn West Virginia, under the current General Permit<\/a>,\n wastes from fracturing a well can be land applied. This waste comes in \ntwo forms — unused fracturing chemicals dumped into the pit and \nfracture flowback discharged from the well into the pit.<\/p>\n\n\n\n

According to the General Permit unused fracture chemicals cannot be dumped into a pit but it’s hard to tell if the operators’ crews know this. The state’s Discharge Monitoring Report (DMR) shows the decision tree for determining under which pit category pit waste falls and indicates that chemicals and flowback can be in a pit: <\/p>\n\n\n\n

\"\"<\/figure>\n\n\n\n

\nOnly category 1 pits do not have fracture flowback or chemicals. Of the \nsmall number of DMRs we’ve examined, all have been for category 2 or 4 \npits.<\/p>\n\n\n\n

The EPA’s exemption<\/a>\n of oil and gas wastes does allow the land application of drill waste, \nflowback, and even chemicals, but the exemption does not allow the \naddition of unused chemicals to production waste that is covered by the \nexemption (drill waste and flowback) if the chemicals exhibit certain \nhazardous characteristics and if the pit waste then assumes those \ncharacteristics. These hazardous characteristics are reactivity, \ncorrosivity, ignitability and toxicity. Or, if the chemicals are listed \nin 40CFR261<\/a>, subpart D, then the waste is no longer exempt.<\/p>\n\n\n\n

Almost\n nothing is known about the chemicals used for fracturing in West \nVirginia. The Office of Oil and Gas website publishes an incomplete list of chemicals<\/a>.\n The list is incomplete in that it does not show all the chemicals used \nin a typical fracture job (the biocide is missing, for instance), nor \ndoes it show the proprietary chemicals which manufacturers won’t \ndisclose. For the Material Safety Data Sheets (MSDSs) I’ve seen, these \nproprietary, unnamed chemicals, can form 10% to 60% of a product.<\/p>\n\n\n\n

Proprietary\n chemicals may be innocuous or they may be toxic. They may be those \nlisted in 40CFR261, which makes disposal costly because the waste is no \nlonger exempt.<\/p>\n\n\n\n

These unknown proprietary chemicals must be \nassumed to fall in a worst case scenario — are hazardous in one way (by\n their characteristic) or another (are listed).<\/p>\n\n\n\n

The Office of Oil\n and Gas has allowed this waste to be land applied without knowing what \nmakes up this waste — the products or chemicals used. But even if the \nOffice had full disclosure from the operators, it would not be getting \nfull disclosure from the manufacturers.<\/p>\n\n\n\n

It’s our belief that \nfracture flowback should not be land applied and that fracture chemicals\n should not be dumped into drill waste pits. Unused fracture chemicals \nshould be disposed of otherwise and properly.<\/p>\n\n\n\n

The MSDS evidence \nis, as I mentioned above, sparse. Three products known to have been used\n in West Virginia create particular concern. These Halliburton products \n(though Halliburton is not the only company making fracturing and \ndrilling products) are: BC-140<\/a> (a cross linker); BE-3S Bactericide<\/a>; and SP Breaker<\/a> (a post-fracture gel breaker). Clicking on the product names will produce the applicable MSDS Adobe Acrobat document. We have a page on our website that explains the purpose of some of these chemicals.<\/a><\/p>\n\n\n\n

These\n products weren’t used in exceptionally large quantities. Their hazards \nare noted on the MSDS sheets (sections 2, 3, 5, 7, 10, 11, 12 and 15) \nand include ecological, human health, storage and regulatory issues. \nOnly the SP Breaker exhibits a hazardous characteristic (two in the MSDS\n version when the product was used — ignitability and reactivity). \nWaste should, if exposed to this product, according to the EPA \nexemption, be tested to determine if it is still exempt.<\/p>\n\n\n\n

A quick addendum: The Office of Oil and Gas has just decided that fracture flowback from Marcellus wells cannot be land applied.<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

In West Virginia, under the current General Permit, wastes from fracturing a well can be land applied. This waste comes in two forms — unused fracturing chemicals dumped into the pit and fracture flowback discharged from the well into the pit. According to the General Permit unused fracture chemicals cannot be dumped into a pit […]<\/p>\n

Read More…<\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[8],"tags":[],"class_list":["post-435","post","type-post","status-publish","format-standard","hentry","category-gaswellstudy"],"_links":{"self":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/435","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/comments?post=435"}],"version-history":[{"count":1,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/435\/revisions"}],"predecessor-version":[{"id":437,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/posts\/435\/revisions\/437"}],"wp:attachment":[{"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/media?parent=435"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/categories?post=435"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/sootypaws.net\/blog\/wp-json\/wp\/v2\/tags?post=435"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}