DEP’s Oil and Gas Technical Advisory Board is scheduled to meet on July 25 to hear a presentation by Dr.  William Burgos, lead author of a new Penn State University study released in May which found runoff from spreading conventional oil and gas wastewater on unpaved roads contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards.

The study also found the wastewater doesn’t work any better than rainwater at controlling dust, but is worse for the environment.

The bottomline-- “The ineffectiveness and potential pollution of wastewater spreading make the practice an unsuitable alternative for dust suppression on Pennsylvania roads, the team reported to the DEP’s Office of Oil and Gas Management.”

Table 5.1 (page 39) shows the results of the analysis done for the study on 32 chemicals and parameters and which of those results exceed health and environmental standards.

The Board’s agenda also includes--

-- Update on regulations covering conventional oil & gas drilling, including new draft waste disposal regulations

-- New General Permit WMGR163 covering ‘temporary’ oil & gas waste processing facilities [Read more here]

-- Unconventional drilling spill policy

-- Erosion & Sediment Control General Permit Update

-- Update on new federal Orphan & Abandoned Well Plugging Program

The meeting will be held in Room 105 of the Rachel Carson Building in Harrisburg starting at 10:00 a.m.  Click Here to register to participate by WebEx.  The meeting will also be available by conference phone: 415-655-0003 Access Code: 2630 012 0194.

For available handouts and more information, visit DEP’s Oil and Gas Technical Advisory Board webpage.  Questions should be directed to Todd Wallace twallace@pa.gov or 717-783-6395.

Background On Road Dumping

From Penn State’s new study--

Using oil and gas wastewater from conventional wells to control dust was considered a beneficial use of the residual waste on the state’s 25,000 miles of dirt and gravel roads, since it was thought to have a chemical composition and behavior similar to commercial dust suppression products.

A previous 2021 study, also conducted by Penn State researchers, indicated otherwise.

This new study, partly funded by the DEP, reinforced those conclusions in the 2021 study, while also finding that the rain runoff from roads treated by any dust suppression method contained contaminants that could pollute nearby water sources.

“We know that road dust poses both a safety hazard for people driving through it and a health hazard for people breathing it in, so dust suppressants are absolutely needed,” said co-lead author Dr. William Burgos, professor of environmental engineering. “While we must be willing to accept the tradeoffs between the benefits of dust suppression and the drawback of the environmental impacts, this research has found that oil and gas wastewaters only provide drawbacks.”

[Note: The conclusions in this new report and others point to the fact that the only real purpose of road dumping this wastewater is for waste disposal by the industry.

[DEP already designates the 84 municipalities that allow dumping of conventional oil and gas wastewater on their roads as “waste facilities.”  Read more here.]

Methodology

The report summarized the results of two laboratory-scale studies comparing samples of oil and gas wastewater from conventional wells to the commercially available calcium chloride dust suppressant and the organic alternative of soybean oil.

In one set of laboratory experiments designed to study the impact of rain runoff after dust suppression, researchers found that every suppressant tested leached contaminants in proportion to its chemical composition.

The runoff from roadbeds treated with calcium chloride, a commercial suppressant, contained the highest concentrations of chlorides and other potential contaminants related to the salinization of freshwater resources.

The runoff from roadbeds treated with oil and gas wastewater also contained chlorides, as well as high concentrations of sodium and even radium — a known carcinogen that is often pulled to the surface through wastewater when oil and gas is extracted from the Earth.

Human Health Concerns

“After a dust suppressant is applied to a road, the first rainfall begins to wash it off the surface,” said co-lead author Nathaniel Warner, assistant professor of environmental engineering. “The research found that the runoff contains high concentrations of whatever is put on the road and could cause problems in nearby water — the sodium, chlorides and particularly the radium are all of serious concern.”

“First-flush concentrations of barium, strontium, lithium, iron, and manganese in the runoff exceeded corresponding human-health based criteria.” 

“Contaminants of interest related to salinization of freshwater resources include electrical conductivity, total dissolved solids (TDS), chloride, and bromide.

Contaminants of interest related to human health include combined radioactive radium (226Ra + 228Ra), barium, strontium, lithium, iron, and manganese.”

The report said--

-- Barium: The EPA and DEP Primary Drinking Water Standard for barium is 2 mg/L Ba. Maximum barium concentrations in the runoff from OGPW-treated roads ranged from 5 – 18 mg/L Ba.  [OGPW is oil and gas production wastewater.]

-- Strontium: The USGS Human-Based Screening Level for strontium is 4 mg/L Sr.  Maximum strontium concentrations in the runoff from OGPW- treated roads ranged from 10 – 32 mg/L Sr.

-- Lithium: The USGS Human-Based Screening Level for lithium is 0.01 mg/L Li.  Maximum lithium concentrations in the runoff from OGPW-treated roads ranged from 0.18 – 1.3 mg/L Li (up to 130-times the standard).

-- Iron: The EPA and DEP Primary Drinking Water Standard for iron is 0.3 mg/L Fe. Maximum iron concentrations in the runoff from calcium chloride brine-treated roads ranged from 0.30 – 0.80 mg/L Fe (up to 2.7-times above the standard).

-- Manganese: The DEP Regulated Substances in Groundwater Standard for manganese is 0.3 mg/L Mn and the EPA and DEP Secondary Drinking Water Standard is 0.05 mg/L Mn. Maximum manganese concentrations in the runoff from OGPW-treated roads ranged from 0.23 – 0.82 mg/L Mn.

-- Total Dissolved Solids: “Roadbeds treated with OGPWs also produced runoff with high TDS (up to 19,000 mg/L), chloride (up to 12,000 mg/L Cl), and bromide (up to 300 mg/L Br) concentrations.”

-- Radioactive Radium: “Combined radium activities in the three OGPWs when applied to the roadbeds ranged from 84 to 2,500 pCi/L, within the anticipated range for OGPWs from western Pennsylvania. Combined radium activities in runoff from the OGPW-treated roadbeds exceeded 60 pCi/L, the effluent standard for industrial wastewater discharges, during both the ‘first flush’ and the ‘maximum flush’ parts of the rain event.

The report added-- “Maximum constituent concentrations in the runoff were related and essentially proportional to constituent concentrations in the dust suppressants.”

Dust Generation/Destabilizing Roadways

In experiments testing dust generation, conducted with compacted “pucks” of gravel road material subjected to a laboratory analogue of traffic abrasion, calcium chloride and soybean oil were shown to be highly effective at suppressing dust.

The oil and gas wastewater performed “essentially no better than rainwater,” likely due to its high concentration of sodium, according to Warner.

He added that the amount of sodium relative to calcium and magnesium, called the sodium absorption ratio or SAR, can be used to help evaluate dust suppression efficacy.

Sodium, calcium and magnesium are all positively charged, but calcium and magnesium have a higher charge and stick more easily to the negatively charged dust particles. The researchers developed the SAR metric in their 2021 study.

In addition to lessening effectiveness, the sodium in wastewater can also destabilize the road, leading to more dust, as well as increased long-term maintenance costs, according to Eric Chase, research assistant with Penn State’s Center for Dirt and Gravel Road Studies and co-author of the report.

“There’s a fair bit of literature out there showing that sodium will actually cause your road to fall apart,” Chase said.

Additional contributors to this study included Xiaofeng Liu, associate professor of civil and environmental engineering; Hassan Ismail, postdoctoral research associate, and Andrew Kearney, research assistant, both in Penn State’s Department of Civil and Environmental Engineering; and James Farnan and Andrew Eck, graduate students in environmental engineering.

The DEP funded the runoff experiments. Penn State funded the brine efficacy experiments.

Click Here for a copy of the study.  Click Here for the database, dust testing, radium testing results.

[Note: The summary of the report above was reprinted in large part from Penn State News as written by Tim Schley and Ashley J. WennersHerron.]

Other Studies Show Road Dumping Threatens Health, Environment

This study adds to the growing body of research by Penn State University and others in  finding conventional oil and gas drilling wastewater being dumped indiscriminately on Pennsylvania’s dirt and gravel roads every year is a threat to the environment and human health.

Major studies reported in peer-reviewed journal articles have concluded spreading wastewater from conventional oil and gas drilling on dirt and gravel roads can harm aquatic life, poses health risks to humans and damages the roads.  Read more here.

Preliminary results from a new Penn State research study by a team led by Dr. Nathaniel Warner found road dumping of conventional oil and gas drilling wastewater results in increased cancer risks for people living along those roads, especially children.  Read more here.

The study found increased cancer risk from arsenic, lead and nickel in road dust contaminated by wastewater that is above the one in a million risk threshold.

According to these studies, conventional wastewater contains harmful contaminants like lead, radioactive radium, bromine, barium, radioactive strontium, chromium, cadmium, arsenic, copper, benzine, Diesel-Range organics and Gasoline-range organics.  Read more here.

Next Steps

“I’d like to thank the researchers at Penn State for putting this report together and for the important information it contains,” said Patrick McDonnell, Secretary of the DEP. “We will evaluate this data for use in decision making about brine spreading on Pennsylvania roadways.”

DEP is in the process of scheduling a presentation on this report by Dr. Burgos to members on the Oil and Gas Technical Advisory Board and DCED’s PA Grade Crude [Oil] Development Advisory Council.

A point of controversy in the past has been the lack of representatives of the public or environmental groups in the oil and gas regulatory development process and on these advisory groups.

On April 25, Kurt Klapkowski, Acting DEP Deputy Secretary for Oil and Gas Management, told the DEP Oil and Gas Technical Advisory Board he hopes to have a draft rulemaking covering conventional oil and gas waste processing and disposal ready for public review by the Board’s meeting on July 18 [now July 25].  Read more here.

Klapkowski said the rulemaking changes will focus on requirements in 25 Pa Code Chapter 78, Subchapter C which covers the onsite storage, processing and disposal of drill cuttings and  wastewater from oil and gas wells.

That Subchapter also covers alternative methods of disposing of uncontaminated drill cuttings through use of “solidifiers, dusting, unlined pits, attenuation or other alternative practices for the disposal of uncontaminated drill cuttings.”

This new proposed regulation could address the issue of road dumping conventional oil and gas wastewater like the ban on road dumping wastewater from unconventional shale gas wells.  Read more here.

Klapkowski also said the federal Bipartisan Infrastructure Law that is funding a new conventional oil and gas well plugging program is prompting DEP to review its regulations for on-site disposal of solid and liquid drilling wastes as well as for radioactive waste disposal.  Read more here.

Not Allowed, But They Still Do It

As noted previously in PA Environment Digest, any conventional oil and gas operator now spreading drilling wastewater is doing so illegally because it does not meet the requirements of DEP’s Residual Waste Regulations-- but still could be allowed under these regulations. Read more here.

DEP outlawed road dumping of drilling wastewater from unconventional shale gas wells in regulations adopted in 2016.  Both conventional and unconventional wastewater come from essentially the same place and have similar chemical makeups.

The latest oil and gas waste reports filed with DEP bring the total amount of reported conventional drilling wastewater illegally road dumped to nearly 2.9 million gallons from 2018 to 2021.  Read more here.

Eyewitnesses report indiscriminate road dumping of conventional oil and gas wastewater continues in 2022.

While road dumping typically occurs on dirt and gravel roads, there were recent reports again of road dumping occurring on State Route 6 in Warren County and other paved roads on a clear day.

Operators who say it is not happening are simply wrong.

Attorney General Investigation

On April 21, a consultant for conventional oil and gas operators on DCED’s PA Grade Crude [Oil] Development Advisory Council reported the state Office of Attorney General is investigating the illegal disposal of conventional drilling wastewater through road dumping under DEP’s Residual Waste Regulations.  Read more here.

Typical Road Dumping

The typical road dumping of oil and gas wastewater on dirt roads involves a vac truck making three or more passes on each section of road using a combination of an open value on the back of the truck and then a blanket pass with a homemade spreader bar that offers no control on the amount of brine spread.

There are no state standards restricting the amount of wastewater that can be dumped on roads, no setbacks from streams or wetlands to avoid contamination and no requirements for testing the wastewater before it is disposed of in this way.  Read more here.

See Photos Here - Read more here.  See Photos Here - Read more here.

(Photo: left to right: Dr. William Burgos, professor of environmental engineering; Andrew Kearney, environmental engineering research assistant; and James Farnan and Andrew Eck, both environmental engineering graduate students.)

NewsClip:

-- Bay Journal: Penn State Study: Conventional Oil & Gas Wastewater Spread On Pennsylvania Roads Bad For Health, Land

PA Environment Digest:

-- Compilation Of Road Dumping Articles

Related Articles - Road Dumping:

-- Attorney General’s Office Reported To Be Investigating Conventional Oil & Gas Operators For Illegally Road Dumping Drilling Wastewater

-- Conventional Oil & Gas Operators Continued To Illegally Road Dump Over 580,000 Gallons Of Drilling Wastewater In 2021

-- Millions Of Gallons Of Conventional Oil & Gas Wastewater Spread Illegally On Dirt Roads, Companies Fail To Comply With DEP Waste Regulations 

-- Better Path Coalition Report: How To Close The Loophole Allowing Uncontrolled Road Spreading Of Conventional Oil & Gas Wastewater & Fix Oil and Gas Waste Reporting System

-- Preliminary Results From New Penn State Study Find Increased Cancer, Health Risks From Road Dumping Conventional Drilling Wastewater, Especially For Children

-- New Pitt-Duquesne Study Shows Higher Exposures To Radiation In Road Dumping Of Drilling Wastewater When Appropriate Exposure Scenarios Are Used

-- The Science Says: Spreading Conventional Drilling Wastewater On Dirt & Gravel Roads Can Harm Aquatic Life, Poses Health Risks To Humans - And It Damages The Roads

--  Penn State Center For Dirt & Gravel Road Studies: Road Dumping Of Oil & Gas Wastewater To Control Dust Is Environmentally Unsound Practice

[Posted: July 11, 2022]

7/18/2022