Brine Spreading Summary

Is Brine from Propane Storage Domes Any Safer Than Drilling Waste?

Emerging Trend to Spread Drilling Waste on Highways

More and more highway departments across the country are adopting the practice of spreading brine on the roads to suppress dust in the summer and to melt ice in the winter.  To a large extent this trend is fueled by the  ever mounting volumes of salty waste produced by the country’s high volume hydraulic fracturing boom.  Looking for ways to  dispose of the waste, many drilling companies are supplying this brine free of charge  to cash-strapped municipalities.

But is it safe to spread this on our roads and highways?

Citizens and local officials are beginning to have second thoughts.  They’re concerned about exposure to residual drilling chemicals,  toxic heavy metals and radioactivity often found in drilling waste  -especially waste coming from the Marcellus Shale.    On December 18^th  the Tompkins County Legislature voted to prohibit the disposal of fracking waste on county roads.  This past June, Assemblywoman Barbara Lifton  and 75 other New York State legislators from both sides of the aisle sent a letter to  Governor Cuomo urging him to ban the use statewide of drilling waste on our roads ⁽http://www.toxicstargeting.com/MarcellusShale/documents/letters/2012/06/13/legislators-letter) .

Alternative Sources of  Brine

Still, the inexpensive deicing efficacy of brine compared to the use of rock salt is very attractive to municipalities.   That’s why responsible  highway departments are seeking other sources of brine for road spreading.   Some are fabricating their own brine by mixing road salt with fresh water.    Others have found non drilling related sources of brine, hoping to eliminate the possibility that it could contain residual fracking chemicals. New York State Department of Transportation  Region 3 (http://www.ithaca.com/news/trumansburg/article_cb12da0e-5ce5-11e1-a920-0019bb2963f4.html  ) and many local municipalities are  using or are looking into using non drilling related brine from the former TEPPCO gas storage facility at Harford Mills which now belongs to Enterprise Products Partners (“one of the largest publicly-traded energy partnerships and a leading North American provider of midstream energy services” http://www.enterpriseproducts.com/corpProfile/businessProfile.shtm ).

This brine comes from two large salt domes used for storing propane.  The brine is kept in a large holding pond on the surface and is pumped   underground to stabilize the structure of the domes when gas is removed and sent to market.  When new gas is pumped back into the domes for storage,  brine is pushed out to the surface and stored again in the large holding pond.  This repetitive cycle of filling and removing liquid from the domes erodes the salt structure over time and  increases the capacity of the domes.  It also increases the volume of brine they produce, sometimes more than the holding pond can handle.  Enterprise Partnership sells this excess brine to the state and to municipalities for road spreading.

Is Enterprise Partnership’s  Brine Safe for Road Spreading?

Here are six things  worth researching in more detail.

1.      Proximity of the salt domes to the Marcellus shale.

According to DEC permits for the facility at Harford Mills (http://www.dec.ny.gov/enb2006/20060419/Reg7.html),  the salt domes are located approximately 3,000 feet below the surface.   And according to contour maps cited by the USGShttp://www.marcellus.psu.edu/resources/PDFs/USGS2005-1268.pdf,  the bottom of the Marcellus shale layer is also approximately 3,000 feet below the surface in the vicinity of Harford Mills.  Although  the geologic formation where the salt is located (the Salina)  is separated from the Marcellus by the  Helderberg and Tristates layers ,  is it possible that  fissures and cracks in those over lying layers  and the ever expanding size of the salt domes below could allow a comingling of Marcellus Brine with the Syracuse Salt Brine of the Salina layer?   If so, is the Harford Mills Facility producing a brine laden with toxins typically associated with the Marcellus layer:  ie.  the same heavy metals and the radioactivity  (http://www.dec.ny.gov/docs/materials_minerals_pdf/ogdsgeischap5.pdf  )?

2.      Ground water concerns in Harford Mills.

According to a report written by John Helgren, formerly  of the Cortland County Health Department, back in the 1970’s  a large surface spill of brine in the Harford/Harford Mills area flowed into the local surface water and then into the ground water and irrevocably polluted a number of private drinking water wells in the area ⁽http://www.tcgasmap.org/default.asp?metatags_Action=Find%28%27PID%27,%279%27%29#Comments%20on%20SGEIS ).  Current members of Cortland County Health Department say this toxic brine plume has not dissipated  and is still slowly traveling underground some 40 years later.

In order to remedy the loss of drinking water to the local residents,  the Harford Water District was formed.  A public well was drilled and it currently supplies some 50 homes with water.  Unfortunately, according to a report published by the New York Times ,  water  from the Harford Water District has been found to exceed the health limits for arsenic, radium 226,  radium 228,  and radon  (  http://projects.nytimes.com/toxic-waters/contaminants/ny/cortland/ny1101762-harford-water-district-1 ) .

If these pollutants exceed health limits in aquifers near the surface in Harford,  what are their levels in the deeper formations –like the Marcellus, or the Salina?

3.       Relevance, accuracy and frequency of testing.

Relevance.   Although laboratories like LSL of East Syracuse have tested the brine at the Harford Mills Facility, are they testing for all of the substances of concern?   Recent analytical results from that lab make no mention of radium, radon or of radioactivity.

The test results do mention elevated levels of bromide,  but fail to mention the danger of toxic brominated trihalomethanes that can form after bromides are exposed to water purification procedures  (http://www.post-gazette.com/stories/news/environment/bromide-a-concern-in-drilling-wastewater-212188/ ). Can the road spreading of brine containing elevated levels of bromides endanger municipal drinking water supplies where water purification procedures are in place?

Accuracy.   One of the problems associated with testing brine stored open holding ponds is the presence of a layer of fresh water floating on the surface of the brine.  After heavy precipitation,  the holding pond can pick up significant volumes of fresh water that  can temporarily dilute the brine.   Can this dilution skew the accuracy of the testing?    Recent test results from Harford Mills say, “Due to sample matrix interference, the sample was diluted and the reporting limits were raised accordingly.”   Does this mean that the concentrations of potential toxins were not measured accurately?

Frequency.   How often does the DEC require testing at the Harford Mills Facility?   Is annual testing adequate?   Does all brine in the holding pool originate exclusively from the Harford facility?  If not, should the brine be re tested each time brine from other sources is added?

4.       Cumulative effects.

Do the DEC tolerances for toxic substances in one truck load of brine take into account the cumulative impact of many truckloads applied to our roads over a season, or thousands of truckloads over decades?  Of particular concern are cumulative  impacts near the municipal drinking water well-heads.

5.       Provenance of the Brine.

What guarantees do municipalities have that the  brine coming from Enterprise Partnerships originates  exclusively from the Harford Mills salt domes?  Is there anything in their contracts with municipalities  that commits to this?   During the winter season, for example, when consumer demand for propane is high,  will the facility need more brine than it has  to stabilize the salt domes?  Will the company then turn to drilling operators  to provide them with drilling waste to serve that purpose?

One surprising revelation in LSL’s lab report is the elevated level of surfactants.   It might be worth inquiring as to why surfactants would be present in a gas storage dome.   Surfactants are routinely used in drilling and in hydrofracking.  AirFoam HD is a brand used at some well sites in Pennsylvania, and it is composed largely of 2 Butoxy Ethanol,  a known human endocrine disrupter  and carcinogen.   Were the surfactants discovered at elevated levels in the Harford Mills brine composed of 2 butoxy Ethanol?   The reports do not say.

Bob Applegate

ninibob@frontiernet.net

835-6205