Welcome to Watershed Wednesday #4
January 5, 2022!
Each week, the Delaware River Frack Ban Coalition Organizing Committee will focus on a different aspect of the DRBC draft regulations pertaining to the import of wastewater produced by fracking and the export of water from the Delaware River Watershed for fracking outside of the Basin. (email for coalition: DRFrackBan@gmail.com). The public comment period is open now and will close February 28, 2022.
To comment: Go to the DRBC online portal, fill in the form and cut and paste some or all of these suggested points into the template, adding a line about your personal interest in a full ban. Alternatively, you can write your own comment and insert it or attach a document. Personalizing your comment is always the most powerful; it’s best to put the sentences that are in your own words FIRST. Make certain that you review your submission when prompted and click the final button that delivers your comment. You should receive a delivery receipt from DRBC.
Each week, the Watershed Wednesday from the prior week is added to a public google doc. In case you want to comment using a past topic or get references we have provided, you can get access here: http://go.pardot.com/e/176172/3siWvcN/x1zxt/277069726?h=-ju89w13cUoWwHSp7ccOyrSbQZJAV2Q0SE2uU8YFjgw The materials can be copied and are there for your use. AND remember you can make as many comments as you want!
Go here to submit a comment: http://go.pardot.com/e/176172/-id-x2K8A/x1zxw/277069726?h=-ju89w13cUoWwHSp7ccOyrSbQZJAV2Q0SE2uU8YFjgw
This week’s comment focuses on why wastewater produced by fracking MUST BE COMPLETELY and CATEGORICALLY BANNED! The fracking industry is looking for places to dump its wastewater and is targeting the Delaware River Basin. The DRBC’s draft regulations would allow wastewater produced by fracking to be imported into the watershed. DRBC is banning the discharge to water or land of fracking wastewater, which is essential, but is not banning its importation. This means the wastewater can be moved into the watershed to be handled and used in other ways that will pollute.
The DRBC’s draft import/export fracking regulations pose intolerable dangers to the watershed from fracking wastewater pollution. Fracking waste processing plants that emit pollution to the air; storage and transfer stations; uses/reuses of fracking wastewater; leaks and spills from transport, transloading, and handling; intentional dumping; are some of the ways that this toxic and radioactive wastewater can pollute once it is allowed to be brought here.The following are suggested points that you can copy and submit to DRBC, with references if you’d like to delve deeper into the subject and submit more detailed comments. You can also check out Talking Point #1-10 for more information.
- I am concerned that the draft regulations allow wastewater produced by fracking to be imported into the Delaware River Basin. The continuing trend in the Marcellus shale to drill supersized wells, with horizontal wellbores up to 4 miles long, has increased volumes of wastewater produced by each fracked well[i]. Approximately 10-15% of the 10 to 20 million gallons of water injected for fracking comes back to the surface as flowback. That means between 1-1.5 million gallons of wastewater (at 10M gal. of water) to between 2 and 3 million gallons of wastewater (at 20M gal. of water) per well, increasing the volumes three to four times over what fracked wells produced just a few years ago. This adds a glut of wastewater that has to go somewhere, and the Delaware River Watershed’s proximity to one of the most productive regions of the Marcellus Shale play, in the northeastern portion of the Susquehanna Watershed, makes it especially attractive.
- Even though the discharge of fracking wastewater is proposed to be prohibited, there are other systems that could operate in the watershed using fracking wastewater. These include incineration, thermal oxidation, air-drying systems, and other waste processing and storage facilities that could avoid discharge to water and land but allow emissions to air (which is not regulated by the DRBC). The wastewater could also be repurposed in what is euphemistically called “beneficial reuse” such as in closed-loop cooling water systems and cement manufacturing. The pollution emitted by these processes, although perhaps not technically discharged to water under DRBC’s Water Code, would still be an import of fracking pollution that would endanger human health and the environment[ii].
- The draft regulations would also allow for the storage of fracking wastewater. This is concerning because storage, transfers/transloading and the requisite transportation around the watershed of these toxic and radioactive fluids, will result in leaks, spills, and accidents. Fracked wastewater contains toxic contaminants like selenium, thallium, radium, and ammonium, all of which are dangerous to human health and the environment[iii].
- Additionally, I am concerned that allowing fracking wastewater into the Basin will go hand-in-hand with more transportation and handling of fracking wastewater. This poses tremendous risks of leaks, spills, accidents, sabotage, or intentional dumping. It is impossible to prohibit leaks or spills because accidents are a matter of ‘when’, not ‘if’. Intentional illegal dumping will also occur if there is an opportunity. That is why these draft regulations must be updated to completely ban the import, processing, discharge, reuse and/or disposal of wastewater produced by fracking.
- Finally, I am concerned that fracking wastewater may be injected into disposal wells here. Although not mentioned in the proposed rulemaking, injection wells are possible, depending on how “disposal to water or land” is defined, which is unclear. Injection of wastewater does not remove contaminants, it simply moves the potential for the toxic wastewater to cause environmental and water resource pollution and water quality degradation from one place and time to another. It also risks the migration of untreated wastewater to aquifers and surface water through leaks from the injection well and spills and accidental releases while being handled[iv]. Injection wells are causing earthquakes in Ohio and Oklahoma as well as other locations and are not leak-proof, exposing groundwater and aquifers to contamination from the toxic mix that constitutes frack wastewater.
[i] These days, oil and gas companies are super-sizing their well pads, Pittsburgh Post-Gazette, 2018. http://go.pardot.com/e/176172/well-pads-stories-201801140023/x1zy1/277069726?h=-ju89w13cUoWwHSp7ccOyrSbQZJAV2Q0SE2uU8YFjgw
[ii] The impacts of fracking on the environment: A total environmental study paradigm, Science of the Total Environment, 2017. http://go.pardot.com/e/176172/-scott-lab-images-Meng2017-pdf/x1zy3/277069726?h=-ju89w13cUoWwHSp7ccOyrSbQZJAV2Q0SE2uU8YFjgw
[iii] Toxic chemicals from fracking wastewater spills can persist for years, Chemical & Engineering News, 2021. http://go.pardot.com/e/176172/racking-wastewater-spills-html/x1zy5/277069726?h=-ju89w13cUoWwHSp7ccOyrSbQZJAV2Q0SE2uU8YFjgw
[iv] Akob, D.M., Mumford, A.C., Orem, W., Engle, M.A., Klinges, J.G., Kent, D.B., & Cozzarelli I.M. (2016). Wastewater Disposal from Unconventional Oil and Gas Development Degrades Stream Quality at a West Virginia Injection Facility. Environ. Sci. Technol. 50, 5517−5525.