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Contaminate Migration Expected Under SB 4 “Well Stimulation Regulations” for California
by Tomas DiFiore
Thursday Feb 6th, 2014 4:05 PM
Well Casing Failures a.k.a. Sustained Casing Pressures - It's really quite simple to understand, cement shrinks, and cracks. Five per cent of all wells drilled show a cement failure immediately. Based on the history of conventional wells, and recent peer reviewed research: “Probablistically, the range of events expected for longer wells, with higher pressures, larger volumes of frac fluids, and more wells per pad, are that we should expect a higher accident rate. And that is what we're seeing.”

Dr. Anthony Ingraffea discusses gas well construction, hydrofracking, micro annular casing leaks.
Published on Jun 20, 2012, 23 minute video

“Because the annulus, between the casing and the rock, is now open from below to above, we now have a migration pathway so that anything that's down there in the way of salts, heavy metals, other deleteious things that were stored in the rock now have a pathway, a vector, and something to carry them upwards. And there will be methane migration.”

The California Well Stimulation Regulations in SB 4 have language that concurs and states: "the stratigraphic depths of protected waters, and the stratigraphic depths of low-permeability zones that will function to slow the migration of fluids towards protected waters or the surface."

Northern California and North Coast Shales, Tight-Sands, Tight-Gas, Natural Gas Extraction Onshore and Offshore
Part Two

This Is Your Brain On Meth(ane)

Perhaps California has only received half the legal description of 'New' Interim Well Stimulation Regulations required under the intent of SB 4. There is not enough actual information to undertake a Statewide EIR. It therefore seems appropriate to halt all hydro fracking in California and acid fracking well stimulation techniques.

Yes that's spelled M-O-R-A-T-O-R-I-U-M.

Right, and they used to use mercury to settle out the gold dust from rivers in the Sierra. And on that subject, hydraulic mining of our rivers was outlawed. The reasons to outlaw the use of water for the extraction of hydrocarbons are so numerous. From 'Wellbore Welfare' Enhanced Oil Recovery Federal subsidy dollars to exempted aquifers, and the release of GHG emissions from Steam Injection Wells and full field (oil field) steam flood scenarios lasting weeks, including Steam Assisted Gravity Drainage EOR combining vertical steam injection wells and dual horizontal wellbores.

Expect Contaminate Migration, under SB 4 “Well Stimulation Regulations” for California.
As defined and stated under groundwater monitoring requirements:

A well-specific (also referred to as “well-by-well”) or area-specific (also referred to as “oil or gas field-specific”)
groundwater monitoring plan shall include all of the following:
(1) A map and cross section of the well borehole(s) to undergo well stimulation treatment, showing the well name(s),
extent and orientation of the planned fracture network, "the stratigraphic depths of protected waters, and the
stratigraphic depths of low-permeability zones that will function to slow the migration of fluids towards protected
waters or the surface."

As a point of fact, a lot was left out of the regulations. Hydroflouric acid in frac fluids? Acid Fracking may be excluded by the 7% concentration threshold requirement. Reporting the use of Hydroflouric acid and Hydrochloric acid fracking fluids, is more important than anyone may realize. Fracture acidizing, involves pumping highly pressurized acid into the well, physically fracturing the reservoir rock and dissolving the permeability inhibitive sediments (like quartz).

The regulations only cover Hydroflouric acid. Industry uses both.

Minimal Impacts Linguistics Approach, Psy-Ops of Community Confusion

1780. Purpose, Scope, and Applicability.
(a) The purpose of this article is to set forth regulations governing well stimulation treatments, as defined in Section 1761, subdivision (a)(1), except that the requirements of this article do not apply to acid matrix stimulation treatments that use an acid concentration of 7% or less. Nor is an operator required to obtain a permit under Public Resources Code section 3160, subdivision (d), prior to performing an acid matrix stimulation treatment that uses an acid concentration of 7% or less.

(c) For purposes of this article, a well stimulation treatment commences when well stimulation fluid is pumped into the well, and ends when the well stimulation treatment equipment is disconnected from the well.

1783.4. Groundwater Sampling, Testing, and Monitoring.
A contingency plan for reporting information in the event of a well failure. A “well failure” means instances where the well casing has been compromised producing a subsurface leak into water bearing zones and is a potential threat to groundwater quality.

How Much Acid Can California Geologic Strata Take?

Stimulation operations can be focused solely on the wellbore or on the reservoir; it can be conducted on old wells and new wells alike; and it can be designed for remedial purposes or for enhanced production. Its main two types of operations are matrix acidization and hydraulic fracturing. Most matrix stimulation operations target up to a ten foot radius in the reservoir surrounding the wellbore.

“Hydraulic fracturing, which includes acid fracturing, involves the injection of a variety of fluids and other materials into the well at rates that actually cause the cracking or fracturing of the reservoir formation. Major technology developments in (non)proppant-fracturing well stimulation, as evidenced by the numerous publications over the last few years, have been primarily in carbonate acidizing.”

“However, the industry uses a lot of acid in the noncarbonates. One of those areas is in spearheading fracturing treatments to reduce near-wellbore tortuosity, most of these in sands and shales.” [Tortuosity: the near wellbore pressure loss due to multiple fractures.] These multiple fractures nearest the wellbore cement casing exterior, are the result of the proximity of the propagation of the initial shockwave of fracture technique. Hope that is close enough for the professionals out there reading this.

This Is The Ground Beneath Your Feet On Acid

A type of stimulation treatment, acidizing is performed below the reservoir fracture pressure in an effort to restore the natural permeability of the reservoir rock. Well acidizing is achieved by pumping acid into the well to dissolve limestone, dolomite and calcite cement between the sediment grains of the reservoir rocks.

There are two types of acid treatment: matrix acidizing and fracture acidizing.

A matrix acid job is performed when acid is pumped into the well and into the pores of the reservoir rocks. In this form of acidization, the acids dissolve the sediments and mud solids that are inhibiting the permeability of the rock, enlarging the natural pores of the reservoir and stimulating flow of hydrocarbons.

While matrix acidizing is done at a low enough pressure to keep from fracturing the reservoir rock, fracture acidizing involves pumping highly pressurized acid into the well, physically fracturing the reservoir rock and dissolving the permeability inhibitive sediments. This type of acid job forms channels through which the hydrocarbons can flow.

Sands versus Carbonates
In pursuing heavy oil and bitumen resources, the energy industry historically focused on sand deposits. Beginning in the 1960s the oil sands were developed through a combination of surface mining and underground or in situ development. In situ development initially utilized vertical wells in a cyclic steam stimulation (CSS) process and, more recently, has used horizontal wells in the SAGD process Steam Assisted Gravity Drainage.

Diatoms are part of the marine plankton that make their shells from hydrated amorphous silica (opal). Under certain conditions, their remains can dominate the pelagic sediments. These conditions prevailed throughout most of California's sedimentary basins during most of the Tertiary Period.

In deep basins that are anoxic at depth, the diatoms accumulate in fine millimeter-scale or thinner layers, and the organic material is preserved. With burial and heat, the amorphous opal (opal-A) of the original diatoms is converted progressively to opal-Ct (opal-cristobalite) and eventually to quartz. There is a commensurate decrease in rock volume and porosity and an increase in brittleness.

Original opal-A has a real rock porosity of 60% or more, since there is porosity inside the diatom shells as well as around them. Opal-Ct has porosity ranging from 35%-45%, and quartz phase rocks can have porosity from 0% to about 25%. With these ranges of porosity, diatomaceous rocks can have tremendous storage potential, and by using modern methods of well completion and stimulation Monterey-type rocks all over California are good producers.

Geologically, It's A Whole Other World

Carbonates are sedimentary rock such as limestone formed from decayed organisms like coral and plankton. If exposed to high salinity water over millions of years and under the right conditions, limestone transforms into dolomite. Dolomite reservoirs typically offer better porosity and permeability systems than limestone reservoirs as they are more susceptible to karsting, a process whereby slightly acidic rainwater dissolves or leaches the rock. Many super-giant conventional reservoirs such as Ghawar, Saudi Arabia and Kirkuk, Iraq are carbonates

It is estimated that more than 60% of the world's oil and 40% of the world's gas reserves are held in carbonate reservoirs. The Middle East, for example, is dominated by carbonate fields, with around 70% of oil and 90% of gas reserves held within these reservoirs.

California Focus: Fracking, Acidizing with Hydroflouric Acid

“In California, at least, the obsession with fracking may be misplaced. In recent months, policymakers have begun to realize that the debate about fracking may be a distraction from the technology that’s the more likely candidate for tapping the Monterey Shale: A technique, already widely in use in the oil industry, known as acidizing.”

Dave Quast, of California Energy in Depth (TakePart interview) that acidizing uses generally between 750 and 2000 gallons, 85 percent of which is water. Acidizing with Hydroflouric Acid (HF) works much better than fracking in the Golden State because the oil-bearing shale is already naturally fractured and buckled from tectonic activity. “We know it’s dangerous, but we don’t know what it does downhole. There are known and unknown dangers.”

So much isn't known about hydrofluoric acid use by the Oil and Gas Industry. Three things are: the concentrations used by oil companies, what happens over the long term to the rock when a rock-dissolving chemical is injected into geologic sub-strata, and what happens to those 2000 gallons of hydrofluoric acid-laced water? September 02, 2013 By RL Miller
A climate blogger, RL is chair of the California Democratic Party’s Environmental Caucus.

There are two types of acid treatment: matrix acidizing and acid fracking.
From Distracted By Fracking, Robert Collier August 2013 Next Generation
Drilling the Monterey Shale Parts 1 & 2: The Most Dangerous Chemical You’ve Never Heard Of

A matrix acid job is performed when acid is pumped at low pressure into the oil well and into the texture of the reservoir rocks. The acids dissolve the sediments and mud solids that are inhibiting the permeability of the rock, enlarging the natural pores of the reservoir and stimulating the flow of oil. The acids physically fracture the reservoir rock and dissolve the sediments that are blocking the flow of oil.

Because Hydroflouric acid is so successful at dissolving anything it touches, drilling companies add other substances to the mix to prevent the acid from dissolving the oil well’s steel casings (intended) to keep the oil and chemicals from leaching into the surrounding rocks and water table.

A low-volume form of acidizing has long been used nationwide, including in California. This process typically occurs in aging oil wells during the final stages of production, as a means of coaxing out the last dregs of oil before the well is abandoned. In contrast, the tactic now being pioneered in California appears to involve much higher volumes of injected acid as a primary technique for new wells. (To alleviate tortuosity)

Both Hydroflouric (HF) and hydrochloric acid (HCl) are used, and are sometimes combined, depending on the geology. However, the sandstones and silicates that are prevalent in the Monterey Shale lend themselves especially to HF use. In many cases, HF acid is created at the oilfield by mixing hydrochloric acid with ammonium fluoride and immediately injecting the mix down the well. Creating the HF acid on site is accepted as safer than offsite production, as it reduces the risk of transport accidents.

In The Arid Productive Farmlands Of California Drought Solution Numero Uno

60 Million Gallons Turned To Steam Per Day in one oilfield.
60 million gallons a day taken from the California Aqueduct.

Compared to the water usage of a single family of four, in a 3 bedroom household, that's roughly equivalent to the yearly water usage of 700-1000 families in California, each day.

The 2013 California Green Building Code Water Use Modifications states:
“A new 3 bedroom single family home with 4 occupants is modeled to use, 174,000 gallons of water per year. The majority of this is for landscaping.”

In one week, in one oil field, the yearly water usage of between 5,000 – 7,000 California families is pumped down into the ground, as steam. It comes back out with the oil, as toxic produced water.

In the video Mixing Oil & Water, it is shown how just one oil company injects steam into the ground for 7 days in a row, then there is a soaking period followed by a production cycle. As production falls off, steam injection is again, applied – hence the term “Cyclic Steam Injection”.

Mixing Oil & Water: 4 min video
Kern County Farmer Fred Starrh stars in this interesting short video. When his almond trees died after he irrigated them with local ground water Fred Starrh sued nearby Aera Energy (Shell/ExxonMobil venture) for polluting the water.

The math below is pretty close, though slightly rounded.

1.4 million barrels a day. 42 (gallons) x 1.4 million is 58,800,000 almost 60 million gallons. That's 184 acre feet each day. A seven day cycle equals 1288 acre feet of water usage, and with 12 cycles per year, that's 15,456 acre feet of water per year turned to steam, and injected underground.

Compared to the water usage of a single family of four, in a 3 bedroom household, that's roughly equivalent to the yearly water usage of 700-1000 families in California, each day.

In one week, a quantity of water which could serve the yearly needs of 5,000 – 7,000 California families is pumped down into the ground, as steam. It comes back out with the oil, as produced water. As production falls off, steam injection is again applied, hence the term “Cyclic Steam Injection”. That means that in one year, in one oil field in California, the quantity of water used to steam the earth would serve 60,000 to 70,000 households (single family of four, 3 bedroom) including landscape needs.

Under full-scale cyclic steam injection operations, it is probable that about 100 to 120 million barrels of oil could be recovered; if continuous steam displacement is applied successfully, recovery could approach 200 to 240million barrels.

From Kern County, California to the Alaskan Tundra Big Oil Is Steaming The Planet's Surface, and releasing GHG emissions. How many mercury toxic CFL light bulbs does it take to save one billion kW per hour?

Extreme Oil Drilling (National Geographic)

“It takes 81 trillion btu’s everyday just to warm the ground at Kern. 25 square miles to 1600 feet deep. It takes so much energy, enough to power one large air conditioner for every human being on the planet.” 81 Trillion btu's per day to heat Kern County to 200 degrees.

Kilowatt Hours (Kwh) to btu (british thermal unit) conversion table shows the most common values for the quick reference.
1 Kwh = 3,412.14163 Btu/hr

81 Trillion btu's per day
81 trillion divided by 24 (hours) =

3,375,000,000,000 btu per hr
3,375,000,000,000 btu divided by 3,412 btu/hr =

989,155,920.281 kwh - almost a billion KW per hour

For the sake of our water, our air, our rivers, our food, and our communities, we need to
Ban Fracking in California. A Fracking Moratorium would create a time frame for expanded development of existing sustainable portfolios of energy, and not trade maximum exploitation rate loan guarantees against environmental impacts for international market edge.

On the subject of California Water usage statistics, watch the 2012 the KQED film "State of Thirst" video on California Water Management. It contains a clear animation of the flow of water throughout the State!

No, neither oil nor gas are mentioned. Oil and water don't mix, but toxins leech, and contaminates migrate. Oil And water aren't usually mentioned together in funded research or special edition news segments, and not even in recent educational videos on California Water Management. When it comes to water resources in the State, one never hears any mention of oil and or gas production. Like twin tunnel vision, there's a duality of mental states of denial.

The Frackinator Denominator In Water Conservation

1) The agricultural sector uses around 80 percent of all of the water withdrawn in California.
2) The agricultural sector uses around 80 percent of all of the water withdrawn for human use in California (34.2 million acre-feet per year agricultural use divided by a total human use of 43.1 maf).

This California number is the same as the global estimate of agricultural water use: 80% of the water humans use goes to agriculture. Using this number, agriculture only uses around 41% of the state's water. From: San Francisco Chronicle The denominator problem: Misleading use of water numbers...Dr. Peter Gleick, President, Pacific Institute

In California, where nearly half of the nation's fruits and vegetables are grown with water from as far away as the Colorado River, the perennially cash-strapped Golden State's governor is proposing to spend $25 billion to divert more of the Sacramento River from the north to the south. Near Bakersfield, a private project is underway to build a water bank, essentially an artificial aquifer.

Still, more than 100 exemptions for natural aquifers have been granted in California, some to dispose of drilling and fracking waste in the state's driest parts. Though most date back to the 1980s, the most recent exemption was approved in 2009 in Kern County, an agricultural heartland that is the epicenter of some of the state's most volatile rivalries over water.

In 1981, shortly after the first aquifer exemption rules were set, the EPA had to lower the bar for exemptions as part of settling a lawsuit filed by the American Petroleum Institute. Since then, the agency has issued permits for water not "reasonably expected" to be used for drinking. The original language allowed exemptions only for water that could never be used.

Oil companies have been the biggest users of aquifer exemptions by far. Once an exemption is issued, it's all but permanent; none have ever been reversed. Permits dictate how much material companies can inject and where, but impose little or no obligations to protect the surrounding water if it has been exempted.

The EPA and state environmental agencies require applicants to assess the quality of reservoirs and to do some basic modeling to show where contaminants should end up. But in most cases there is no obligation, for example, to track what has been put into the earth or, except in the case of the uranium mines to monitor where it ends up.

Underground Safe Drinking Water vs Underground Injection of Hazardous Wastes

An Eloquent Argument For The End To Aquifer Exemptions

In August of 2012, On behalf of Eastern Navajo Diné Against Uranium Mining (“ENDAUM”) a letter of intent to challenge the Aquifer Exemption Issued to Hydro Resources, Inc. for Church Rock was sent to Senators and the EPA. The Navajo Nation challenged an Aquifer Exemption permit application which is well below the EPA threshold, at 3,000 TDS. The language of their legal arguments shine a light on the process as only native voices could.

Based On The Statutory Language

“The Act’s requirements for protecting USDWs are found in 42 USC § 300h. Specifically, the Act provides that drinking water programs have requirements that, at a minimum, assure that no underground sources of drinking water will be endangered by any underground injection. Id. at 300h(b)(1), 3(C).

The Act further provides that underground injection endangers drinking water sources if:
1) such injection may result in the presence in underground water which supplies or can reasonably be expected to supply any public water system of any contaminant, and
2) if the presence of such contaminant my result in such system’s not complying with any national primary drinking water regulation or may otherwise affect the health of persons.

H.R. Rep. 95-338, 123 Cong. Record 3658-3659 (1977) (emphasis added); see also, Phillips
Petroleum Co. v. U.S. Environmental Protection Agency, 803 F.2d at 560 (concluding that if a
requirement on injecting activities is necessary to assure that underground sources of drinking
water are not endangered, whether that requirement impedes mineral recovery is irrelevant
because the “clear and overriding concern” of Congress in passing the Act was to assure the
safety of “present and potential sources of drinking water”).

California Fracking May Produce Radioactive Wastes And Release Radioactive Gas

Fracking not only uses chemicals that can contaminate drinking and groundwater, it also releases large amounts of natural radioactivity from the ground into the air, including Radium-226, which has a half-life of 1,600 years.

Horizontal hydraulic fracturing for dry natural gas in California has the potential to result in the production of large amounts of waste materials containing Radium-226 and Radium-228 in both solid and liquid mediums. This type of radioactive material is particularly long-lived, and could easily bio-accumulate over time and deliver a dangerous radiation dose to potentially millions of people long after the drilling is over.

In NY it has been found that the brine that returns to the surface can contain up to 16,000 picoCuries per liter of Radium-226, research shows. The discharge limit in effluent for Radium 226 is 60 pCi/L, and the EPA’s drinking water standard is 5 pCi/L.

The New York Times has reported that 116 of 179 Marcellus wells in Pennsylvania had high levels of radiation in wastewater samples. Water used to hydraulically fracture the deep, 380 million-year-old shale layer and release the natural gas it holds, comes back as radioactive wastewater.

Public Drinking Water Intakes Do Not Often Test For Radiation Levels

Radiation Sources in Natural Gas Well Activities

The risk is from exposure to increased concentrations of ionizing radiation, which is naturally present in the ground in the forms of radium, thorium, uranium, lead, and/or radon (Horn, 2009; EPA, 2011). The secretary of Energy's 2009 final report mentioned the potential for radioactive isotopes only once in the 23-page report. However, the study by Horn (2009) and subsequent investigations by The New York Times (Urbina, 2011) have resulted in more attention to the matter by the Department of Energy (DOE) (McMahon, 2011).

Sources of Radiation:
 The Earth itself is radioactive, and the ground contains a variety of radioactive isotopes. Coincidentally, deposits of natural gas tend to have higher concentrations of radioisotopes, and this fact has been used by geologists to locate natural gas deposits (EPA, 2011). This naturally occurring radioactive material (NORM) is typically composed of one or more of the following elements:

Uranium and its decay products (including Radon)

Thorium and its decay products

Radium and its decay products


The metals usually do not exist in their free metallic form but are found in the geology as salts. Uranium salts are generally not soluble in water, but radium salts are. Thus, the water existing within the rock formations, called formation water, has high concentrations of both salts, hence the term "brine water" and radioactivity.

When A Well Is Installed, Radioactivity Can Come To The Surface In Several Ways:

Drilling fluid- During the drilling process, the rock cuttings must be removed so drilling can continue. To this end, drilling fluid is used to bring the rock cuttings to the surface. The drilling fluid can be a liquid, a gas, or a combination of the two. Drill fluid itself is usually a mud-like substance that contains the rock cuttings, which may have radioactive solids, and formation water, which likely has radioactive salts (Resnikoff, et al., 2010).

Fracking- Anywhere from 10 to 40 percent of the water used in fracking comes back up the well (Urbina, 2011) carrying formation water and concentrations of salts that dissolve in the frack water, which includes NORM.

Production- Formation water, which contains high concentrations of salts and radioactivity, is brought to the surface along with the extracted gas and oil. Radon gas is also extracted along with the natural gas.

Underground and Background Radiation: NORM; TERM; TENORM

The natural radiation of the Earth, generally not a cause for concern, is called background radiation, or normally occurring radioactive material. However, any process that concentrates natural radiation produces technologically enhanced NORM, or TENORM, technologically enhanced naturally occurring radioactive material. TENORM poses a higher risk to people due to higher concentrations of radioactive materials.

The work involved in drilling and maintaining wells produces TENORM, such as:

Scale- Salts have a specific solubility in water. Once that solubility level is reached, no more of that salt will dissolve in the water. Excess salt, including radioactive salts, will precipitate out on nearby solid surfaces, including the well head and casing. Other areas that can have radioactive scale deposits include the water lines associated with separators, heater treaters, and gas dehydrators.

Recycling water- Radioactive salts are not easily filtered out of water. Each time the water is sent down the well, the concentration of radioactivity in the water increases. In addition, if chemical scale inhibitors are used, the concentration of radioactivity remains in the water.

Companies typically use recycled water in many different ways in an effort to be environmentally conscious and efficient. Companies will routinely spray recycled water on unpaved roads several times a day as a dust suppressant, which could expose workers and the environment to increased radiation levels. In the winter, recycled water can also be sprayed on roadways to de-ice the roads, having a similar result.

When injected as waste into underground 'exempted aquifers' they can settle to the bottom where they will reside for a long time. A Beneficial Use Designation under law allows this brine water to be used for de-icing paved road surfaces, dust control on dirt roads etc.*

Separation pits- Separation pits are used to divide the solids, including drill cuttings, from the liquids (formation water and drilling fluids). As the solids settle out, they may contain increased concentrations of radioactive material. The liquids may also have increased radioactive concentrations. A similar concept to the separation pits, shale shakers are used to separate solid and liquid wastes. Both the liquid and solids may contain elevated radioactivity.

Filters- Often cloth or bag filters are employed in the process of cleaning the water before reuse. The fine sediment that collects in the screen or filter may contain elevated radioactivity.

Sludge- Sludge is composed of dissolved (potentially radioactive) salts that precipitate from produced water as its temperature and pressure change.

Equipment- As a result of work processes that spread radioactivity over the work site, the equipment can become contaminated with radiation. Gas processing equipment with the highest radiation levels includes reflux pumps, propane pumps and tanks, and more (EPA, 2011).

Radioactive Levels, Regulations, Recyling and Re-Use

Many studies have been done across the United States to determine the concentration of NORM within specific natural gas formations, in Pennsylvania (Pennsylvania Geology, 2008), Arkansas (Arthur et al., 2008), and Louisiana (STRONGER, 2011). Some of these same studies have reported radioactivity levels for NORM at natural gas wells. However, other studies report widely different values for radioactivity at wells in the United States based on geographic location (EPA, 2011), radioisotopes studied (Rahon, 2010), and processes studied (Smith et al., 1996).

The New York Times reported that hydraulic fracturing wastewater at 116 of 179 deep gas wells in the state contained high levels of radiation and its effect on public drinking water supplies is unknown because water suppliers are required to conduct tests of radiation only sporadically.

There is no safe level of toxins, "The current scientific consensus postulates that there is no known safe level of exposure to radioactive materials."

TENORM is defined by the National Research Council of the National Academy of Sciences as: Technologically Enhanced Naturally Occurring Radioactive Materials are any naturally occurring radioactive materials not subject to regulation under the Atomic Energy Act whose radio nuclide concentrations or potential for human exposure have been increased above levels encountered in the natural state by human activities.

While federal and state agencies have tried to develop ways to protect humans and the environment from harmful exposure to the radiation in such materials, TERM remains a challenging problem in the United States. Because many industries and types of products potentially contribute to excess radiation production, including mineral extractions and refining, oil and gas production, drinking water treatment processes and wastewater treatment plants, scientists, researchers and legislators are struggling to find viable solutions.

Highly corrosive salts, carcinogens like benzene and radioactive elements like radium, can occur naturally thousands of feet underground. Other carcinogenic materials can be added to the wastewater by the chemicals used in the hydrofracking itself. While the existence of the toxic wastes has been reported, thousands of internal documents obtained by The New York Times from the Environmental Protection Agency, state regulators and drillers show that the dangers to the environment and health are greater than previously understood.

Recycling and Re-use Concentrates Radiation, Then Disperses It To Road Surfaces

What Beneficial Use Designations are allowed under California law that serve to mitigate costs of disposal of otherwise hazardous materials? Is there really a cost savings? Beneficial Use Designations (BUD) of Fracking Flowback and Wastewater starts in California's Water law. Using brine to water roadways to control dust or as a de-icing agent

People can be exposed to radioactive materials from drilling and fracking operations when trucks hauling waste materials travel past their homes, when crops are grown on contaminated soil, and when farm animals ingest radioactive deposits on plants.

Today's Investment In Oilfield Water Management (Recycling)

Much Is Made Of Investment In Oilfield Water Management but; recycling of wastewater and decontamination of produced water is still just a hopeful myth at the end of 2013.

“After two years searching for a blockbuster investment in oilfield water management, fund manager Judson Hill is still holding on to his money. Hill’s NGP Energy Capital Management saw potential in what looked like a hot growth area in energy: treating and recycling the 21 billion barrels of wastewater flowing annually from U.S. oil and natural gas wells, particularly from shale.

Instead, it found the market “too fragmented and too frothy,” said Hill, a managing director at the private equity firm in Texas whose latest fund has invested $3.6 billion. It’s not as though we look back and say, WOW, half the ones we passed on were just home runs. They weren’t.”

Fracking Bonanza Eludes Wastewater Recycling Investors

Picking a winner in water treatment eludes even Schlumberger Ltd. (SLB), the world’s largest oilfield services provider. Schlumberger jumped into water recycling years ago envisioning a fast-growing, vibrant new specialty. “We’ve spent millions and millions of dollars evaluating virtually every available and reasonable-looking technology out there, always hoping we’d find the silver bullet, said Mark Kidder, who runs Schlumberger’s oilfield water management unit. We've found nothing.”

As of October, November, and December of 2013 there were only “recurring losses to other investors that sunk hundreds of millions of dollars into companies that promised to solve water concerns by treating water. Publicly traded targets including Nuverra Environmental Solutions Inc. (NES), GreenHunter Resources Inc. (GRH) and Aqua-Pure Ventures Inc. (AQE) which have all reported a succession of losses since 2011. Shares of the three companies have fallen an average 46 percent during the past 21 months.”

Of the $31 billion spent each year on managing water resources in U.S. and Canadian oilfields, $2.8 billion, less than 10 percent, is spent on recycling. PacWest Consulting Partners LLC.

BUD- Beneficial Use Designation

Besides recycling, another method of turning liability to profit is the 'beneficial use designation' under both California DTSC and California Water Law. No matter the name of the State in which unconventional gas reservoirs are fracked, there are a variety of methods employed to manage Shale Gas Extraction Wastewater (SGEW). These range from disposing of it (untreated) deep underground in injection wells, treatment as necessary to allow it to be re-used in other hydrofracturing procedures, and treating it to a degree necessary that it can be discharged to surface waters or surface evaporation ponds (pits).

Considerations have included that:
1) “It is desirable to identify a beneficial use for the concentrated salt solution, or brine, as well as the dried salt cake that may be produced by the various treatment processes. One apparent possible use is the application to roads as a winter de-icing agent.”

“Brine from traditional oil and gas drilling has been used for years as a de-icing agent. There are also brine wells specifically for brine production. Traditional, in this sense, generally means drilling that does not use the hydraulic fracturing process (no chemical additives). However, concern has been raised that the brine, or salt cake obtained from treated SGEW may contain trace amounts of chemicals from the hydrofracturing process as well as constituents dissolved in the produced water and brought to the surface by the gas extraction.”

“Research from the Bureau of Oil and Gas Management (PA) indicates that Shale Gas Extraction Wastewater (SGEW) includes a high content of hazardous heavy metals, such as barium and strontium. There is also concern about radioactivity. The Marcellus Shale play is known to generally be more radioactive relative to other geologic formations.”

2) “Of course, the radioactivity of deeply buried shale is of no concern. However, what is natural or normal at that depth is not natural on the surface of the ground and concern is being expressed about the radioactivity of products resulting from Marcellus Shale extraction. These previously buried materials are referred to as naturally occurring radioactive materials (NORMs). When materials containing NORMs are processed or refined, the radioactive material may become more concentrated to create technologically enhanced naturally occurring radioactive materials (TENORMs). The primary radionuclides of concern are Radium 226 (Uranium-238 decay series) and Radium 228 (Thorium-232 decay series)“.

Excerpts From: Chemical Analysis Of Major Constituents And Trace Contaminants Of Rock Salt and SGEW salt (BUD) Bureau of Water Standards, Pennsylvania

High Concentrations Of Both Barium And Strontium

“Rock salt is a sedimentary rock, which is classified as an evaporate. Naturally occurring rock salt is formed from the evaporation of inland seas. The rock salt contains the minerals found in that particular body of water; mostly sodium, chloride, calcium, magnesium, potassium, and sulfate. These are the major elements found in rock salt. All of these substances are highly soluble in water.”

“Shale is also a sedimentary rock: however, it is classified as a clastic rock layer. Clastic sedimentary rocks are composed predominantly of broken pieces of older weathered and eroded rocks and are classified based on grain size, clastic and cementing material (matrix) composition, and texture. Shale is a fine-grained, clastic sedimentary rock composed of mud that is a mix of flakes of clay minerals and tiny fragments (silt-sized particles) of other minerals, especially quartz and calcite. Many of the minerals that make up shale are insoluble in water.

“Marcellus Shale is black shale, a dark, thinly laminated carbonaceous shale, exceptionally rich in organic matter and sulfide and often containing unusual concentrations of certain trace elements such as uranium, vanadium, copper, and nickel. Conversely, data from the SGEW analysis indicates that high concentrations of both barium and strontium are usually present.”

Naturally occurring rock salt was formed from the evaporation of inland seas. Its primary constituents are sodium, chloride, calcium, magnesium, potassium, and sulfate. Rock salt generally contains between 90 to 98% sodium chloride. The salt content in SGEW may exceed 7 times that of sea water. Approximately 77% of the rock salt used in the US is used for highway de-icing.

California Also Uses Rock Salt On Mountain Passes In Winter Snow Or Ice Conditions.

This BUD Is Definitely Not For You

For the sake of our rivers and streams, groundwater recharge basins, and watershed drainages, there should be No Beneficial Use Designation for Frac Wastewater Applications To Road Surfaces – whether dirt, rocked, or paved allowed anywhere in California.

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Tomas DiFiore
North Coast resident
§Mud-acid & pre-frac acid updated
by Tomas DiFiore Sunday Feb 9th, 2014 2:38 PM
UPDATE 02092014
As a point of fact, a lot was left out of the regulations. Acid used in 'pre-frac preparation' may be excluded along with mud-acid. The 7% concentration threshold requirement would not apply. Concentrations of pre-frac acids can be 28% per cent to base fluid.

The regulations seem to cover acidization. Except that acids are used in drilling muds (MUD-ACID), and as pre-frac fluids in preparation for 'well stimulation' in concentrations to 28%.

That's the only substantial change.