The news that DEP politely called for ending disposal of drilling wastewater from the remaining 15 plants that were in operation prior to August 2010 when the new Total Dissolved Solids Rule went into effect is welcome. The reason for DEP's action--rising levels of bromide on the Mon and Allegheny Rivers documented by good work by Carnegie Mellon University--is unwelcome. Carnegie Mellon University reports that generally bromide on the two rivers is above background and between low and moderate levels but has reached high levels for short periods.
Bromide itself is harmless. It is part of the total dissolved solids such as salts and sulfates that is regulated by the Safe Drinking Water Act through a secondary standard, because high TDS concentrations change the color, taste and odor of water.
Drinking water plants that take in water and process it to deliver to homes and businesses have no equipment to remove TDS. What comes in the plant flows through to the tap.
Moreover, bromide at certain concentrations reacts with chlorine in the drinking water treatment process to create a third substance that is a known carcinogen so keeping bromide levels low in water is particularly important.
The Mon River and Allegheny River have for many years had TDS levels that have exceeded 400 mg/liter, nearing the 500 mg/liter Safe Drinking Water standard limits, and TDS levels exceeded that limit on the Mon River in October 2008.
At that time, the Mon River when it reached Pennsylvania from West Virginia already was at the Safe Drinking Water Standard of 500 but the TDS levels increased further as the river flowed to Pittsburgh. The sources of TDS are numerous, including industrial discharges, coal mining, and gas drilling wastewater. The historic discharges have been enough to stress both the Mon and Allegeheny rivers and new ones can push it over the limit.
In response to the 2008 TDS levels exceeding the 500 standard, DEP issued a drinking water advisory to the public and ordered municipal sewer treatment systems that were taking drilling wastewater and discharging it to the Mon River to cut by 90% the drilling water discharges. That order is still in effect to my knowledge.
Given the Carnegie Mellon University data and the unexpected bromide issue, now stopping drilling wastewater discharges to both the Mon river and Allegheny is a sensible precaution. It also seems to be a precaution with limited impact on the gas drilling industry as a result of the already widespread and still growing use of recycling technology that the industry developed in response to the prospect of the August 2010 new TDS rule.
If companies could recyle but have not been as a result of the operation of the old plants, such companies can join many others in the industry and recyle or treat to the safe drinking water standard drilling waste water. Eureka is one company that has plant running that can do exactly that.
With the bromide issue being addressed, the bigger issue of TDS levels on the Mon River remains lurking. The TDS pollution sources to the Mon are multiple, including new ones like waste from scrubbers installed at Hatfield Ferry coal plant that are providing vital air pollution control, and the TDS levels have been uncomfortably close to the 500 level since 2008.
Indeed the sulfate levels, a major part of TDS, have been above the environmental limits. DEP, therefore, recommended in December 2010 to EPA that the Mon river be listed as impaired for sulfates and steps be taken to reduce sulfate loading of the Mon River.
Everyone who uses the Mon River--from drinking water suppliers to industrial dischargers--would be well-served by a cooperative plan to lower TDS levels. The bromide piece of the TDS issue reminds strongly that managing and reducing the TDS levels on the Mon River is a necessity.
Thanks for the overview, John; very helpful. I agree with your assessment that the impact on drilling is limited, with most producers seeing the writing on the wall over the last couple of years and moving toward more recycling / reuse, and less discharge. The other issue here seems to be an incremental cost increase for those who don't/can't recycle to shift their treatment to commercial facilities that are equipped to treat the water instead of municipal facilities that were not built to accept those types of wastes. Thanks for addressing the issue.
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