Is "Recycling Waste Fluids" Just Another Name for Disposal?

pumping water from Susquehanna at Ulster, PA

Three weeks ago I posted a brief review on how Range Resources is re-using flowback and frack waste fluids in their drilling process. The idea sounds great: re-use, recycle and reduce the need for pumping millions of gallons of water from our streams and rivers.

But while industry engineers rave about the technology, some people living near recycling operations aren’t so ecstatic. Since that post, I heard from one woman living in the Barnett Shale play who described a local recycling facility.

Fountain Quail, a partner in the Williamsport Eureka facility (which is the one Range currently uses to clarify their frack fluids) operates a similar facility located in the midst of drilling sites just north of the Dallas-Fort Worth area.

“It stinks,” said the Texas resident. She described the odor as an offensive mix of diesel and chemicals that smells like stagnant water. The idea of using well-site recycling might work in isolated, rural areas she said, but the odors are evident from as far away as 1,000 feet.

“You wouldn’t want to live nearby,” she said. Already many people have raised concerns about the cumulative impact of emissions from compressors and other facilities; we should add recycling facilities to that list.

Then there is the question of whether diluting and reusing flowback to drill wells is a legitimate use for drilling waste fluids. “Why isn’t re-injecting flowback fluids into a well regulated under UIC?” asks Dr. Anthony Ingraffea, professor of civil and environmental engineering at Cornell University.

UIC refers to the Environmental Protection Agency’s Underground Injection Control program which regulates disposal of oil and gas drilling wastes in deep disposal wells.

“Congress established the UIC program to protect drinking water,” Ingraffea emphasized in a recent phone conversation. Under the UIC program, drilling wastes are injected into class II disposal wells. EPA regulates these class II wells, limiting the pressure and volume of waste fluid injected into disposal wells.

More importantly, EPA requires the company to demonstrate that injected wastes will not come into contact with any groundwater. That means the company has to identify all abandoned wells in the area and make sure they are plugged properly – otherwise injected waste fluids may find a pathway to contaminate drinking water.

So here’s the conundrum, says Ingraffea: while the EPA strictly regulates how fluids are injected into a deep disposal well, no one is regulating how those same fluids are being reused in drilling.

“This is what happens when technology outpaces regulations,” says Ingraffea. “It’s the same process with a different name.”

Add recycling to the long list of things EPA needs to look at in their new hydro-fracking study.

Communities need to Think about Drilling Waste Disposal before Drilling Begins

A couple weeks ago three area experts spoke in Ithaca about drilling waste disposal. One of these was attorney Rachel Treichler. 

Even though horizontal drilling in Marcellus shale has yet to begin in New York state, some communities are finding themselves faced with questions about how to handle drilling waste. A couple Pennsylvania Marcellus wells are already sending their drill cuttings to landfills in NY and at least one municipal wastewater treatment facility is accepting drilling waste fluids from vertically drilled wells. Over the past year, representatives from EPA and Penn State have suggested that underground injection wells may be the "safest" method for disposal of frack flowback and brine from Marcellus wells.

Currently there are six active injection wells in NY, and eight in PA. Ohio, with 159 active state-regulated injection wells, is concerned about the amount of wastewater expected from increased Marcellus drilling; the state is considering a 20-cents/barrel tax on out-of-state brine. 

The good news, says Treichler, is that local governments have some say in where disposal wells can be sited. That is, if municipalities already have such laws in place. If they don't, then "they should waste no time in developing local legislation to regulate disposal wells," Treichler says. 

Injection wells are regulated by EPA under the Safe Drinking Water Act. In addition, DEC has its own list of criteria. While companies can drill a disposal well, a cheaper option may be to convert an existing deep well into an underground injection well. According to USGS geologist William Kappel (he's the guy in the middle), the geologic formations most likely to accept injected waste are the Oriskany and Medina sandstones and the Potsdam layer. But non-producing Trenton-Black River wells make good candidates, too, as they have larger spaces for liquids to fill.

What hydro-geologists need to know, Kappel says, are how porous the formation is, how permeable the layer is, and the thickness of the layer. They also need to know the locations of abandoned gas or oil – or even drinking water – wells in the area before injecting waste, because any unplugged wells could provide a conduit for waste fluid to contaminate groundwater.

“It is important that they do an injection test prior to any sustained liquid injection and observe the limits of injection capacity,” Kappel stressed. In one case a company tied to inject too much fluid into their wells. As the wells filled, they increased the pressure. Eventually their injections set off seismic activity.

For the municipal officials attending the forum, the most encouraging news is that they have the power to regulate disposal wells. Before a company may drill a disposal well – or convert an abandoned deep well to that use – it must apply for a number of permits. These include: an EPA permit for a Class IID injection well; a DEC State Pollutant Discharge Elimination System (SPDES) permit for brine disposal; a SPDES permit for stormwater runoff; a DEC MRB well permit to drill a brine well or convert a well to that purpose;  a Municipal Special Use permit if required by local law; a State Environmental Quality Review (SEQR) for a brine disposal facility; and permission of the landowner.

“Municipalities may issue permits if their local laws require it or if zoning requires it” Treichler said. She encouraged all municipalities to adopt local laws without delay, as Marcellus drilling will produce a huge demand for disposal wells.