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SGEIS Fracking Flowback

SGEIS Fracking Flowback

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No place to get rid of fracking flowback in New York.
No place to get rid of fracking flowback in New York.

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Published by: James "Chip" Northrup on Sep 18, 2011
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01/01/2013

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1
NORTHRUP
The dSGEIS fails to adequately address frack waste disposal.
There is nowhere to safely dispose of frack waste in New York state. No drillingpermit should be issued without a final disposition plan for frack waste.
The lack of facilities to dispose of fracking wastes is emblematic of the State’s lack of  preparedness for horizontal hydrofracking shale. The dSGEIS attempts to mask this lack of preparedness by speculating on how frack waste
might be
disposed of in Section5.13.3, but does not require any those solutions to be in place prior the issuance of  permits, nor does it require the permit applicant to show how the frack waste will befinally disposed of, it merely suggests that it will attempt to
track 
such waste. To
where,
 exactly ? Frack waste from Pennsylvania was trucked into the state to the municipaltreatment plant at Auburn. The closest EPA permitted disposal wells are located acrosstwo state lines – in Ohio. Or, once in Pennsylvania, a New York frack waste truck maysimply dump it into the nearest trout stream.
1
The “bootlegging” of frack waste acrossstate lines has drawn the scrutiny of the EPA.
2
 Proceeding without adequate preparation simply repeats the mistakes on frack wastemade in Pennsylvania. That state issued permits without any clear disposal plan in placefor the frack waste generated. The results were shameful.
3
The SGEIS lists various ideasof how to address frack waste disposal – but offers no conclusive solutions. There areonly 6 permitted disposal wells in New York, only 3 of which take brine, none of whichtake fracking flowback.
4
Texas has almost 12,000 EPA permitted disposal wells or a totalof 50,000 including injection wells that can take produced water.
5
 
5.12.2. 1 Recycling of Fracking Flowback 
The proposed regulations mention re-use, but re-use is not disposal; it simply increasesthe net toxicity and radioactivity with each re-use - to the point of becoming to “hot tohandle” and too toxic to move safely on rural roads.
5.13.3 Flowback Water
Cumulatively, the DEC’s proposed dSGEIS would facilitate the production of billions of 
1
 http://www.huffingtonpost.com/2011/04/24/pennsylvania-fracking-wastewater-krancer_n_853055.html 
2
 http://www.nytimes.com/2011/10/21/us/epa-to-tighten-rules-on-wastewater-disposal.html?_r=2&emc=eta1 
3
 http://www.nytimes.com/interactive/us/DRILLING_DOWN_SERIES.html 
4
 http://www.dec.ny.gov/energy/29856.html 
5
 http://www.rrc.state.tx.us/about/faqs/saltwaterwells.php 
 
2gallons of fracking flowback. The DEC has no definitive plan or regulations on how todispose of this toxic radioactive material. Wholly irresponsible solutions have been proposed by the DEC and already deployed in New York 
6
– including spreadingflowback as de-salting material on roads without proper SEQRA approval or dumping itinto municipal treatment plants that are incapable of removing either the toxic chemicalsor radioactive materials.
5.13.3.2 Municipal Sewage Treatment Facilities
It is illegal to treat fracking flowback in sewer plants in most states, includingPennsylvania, so it is trucked to the closest disposal wells in Ohio,
7
or trucked tomunicipal sewage treatment plants in New York 
8
that are not equipped to treat it. SeeFigure 1 for a map of vulnerable treatment plants. The DEC suggests that the frackingwaste water could be “pre-treated” before it is run through the sewer plant, but can site nosuch systems in use.
Figure 2 Municipal Treatment Plants That Could Take Frack Waste
6
 http://www.marcellus-shale.us/drilling_wastewater.htm 
7
 http://www.pittsburghlive.com/x/pittsburghtrib/s_745228.html 
8
 http://shaleshockmedia.org/2011/07/08/auburn-city-council-votes-to-ban-drilling-waster-water/ 
 
3
5.13.3.4 Road Spreading
The DEC supposedly requires an SEQRA to allow fracking flowback to be spread onrural roads as “de-icer”. Alas, the DEC have already ignored their own requirement,allowing millions of gallons to be spread on thousands of miles of rural roads, includingnext to protected trout streams, for year after year, which simply increases the build-up of toxins and radioactive materials.
9
Spreading frack waste on roads is illegal in most states.
Figure 2 Frack Waste Spread on Roads Near Trout Streams5.13.4 Solid Residuals from Flowback Water Treatment
Fracking flowback is toxic and radioactive. The SGEIS equivocates on radioactivity, butcarbon rich “black shale” is, by industry definition,
radioactive
. Black shale is, accordingto the American Petroleum Institute’s definition, more radioactive than any other sedimentary layer. If it were not, it would not show up as “shale” on the gamma rayreading of a well log
.
Horizontally hydrofracking shale is a textbook way to bringradioactive material to the surface. Processing frack flowback leaves a residual sludgethat is hundreds to thousands of times above normal levels.
10
The toxicity of the residual
9
 http://www.pressconnects.com/article/20110720/NEWS01/107200413/1112/ 
10
 http://www.scribd.com/doc/64407403/Radioactive-Waste-Management 

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