-.1 - ` 

west virginia department of environmental protection 

Division of Watcr and Waste Management 

601 57`sStrcct SE 

Charleston, WV 25304 

I'honc: (304) 926-0495 

Fax: (304) 926-0463 

Joe Manchin III, Governor 

Randy C. I-luffman, Cabinet Secretary 

dep.wv.gov 

MI;NIORANDUVI 

To: Division of I-Iighway 

From: Division of Environmental Protection AW 

llate: 07/30/2010 

Subject: WVDOH/WVDEP Salt Brine from Gas Wells Agreement 

WVDOH/WVDEP Salt Brine from Gas Wells Agreement 

This agreement by and between the West Virginia Division of Highways and the West 

Virginia Department of Environmental Protection is limited to the benef cial use of natural 

gas well brines within the state of West Virginia for roadway prewetting (brine miaced with rock 

salt and rock salt/abrasive mixes prior to roadway application), anti-icing (brine applied directly 

to roadway surfaces prior to precipitation), and deicing (brine applied to roadway surfaces during 

and after tlie precipitation event). The approved use is limited to the wintertiine application of 

natural gas well brines in order to minimize the formation of bonded snow and ice to roadway 

surfaces by utilizing the melting capabilities of salt brine. 

Only natural gas well brines which meet the following criteria will be used for 

prewetting, anti-icing, and deicing purposes: 

Parameter Allowable Level 

TDS >200,000 ing/L 

Chloride <175,000 ing/L 

Sodium *<91,500 mg/L 

Calcium * 

pH 5.5 to 8.0 

Iron <10 mg/L 

Barium <2 mg/L 

Lead <10 mg/L 

Oil & Grease <10 mg/L 

Benzene <0.5 mg/L 

Ethylbenzene <0.7 mg/L 

Promoting a healthy environment. 
Toluene <1 mg/L 

Xylene <1 mg/L 

*The total of Chloride, Sodium, and Calcium shall be a minimum of 200,000 mg/L with Sodium 

making up no more than 91,500 mg/L. With Sodium concentrations above 91,500 mg/L, the 

freezing temperature of the brine actually increases. 

**All natural salt brine received shall have a freezing point of less than 0 degrees Fahrenheit. 

The application rates for natural gas well brines shall be limited to 10 gallons per ton for 

prewetting use, 50 gallons per lane mile for anti-icing use, and 100 gallons per lane mile for 

roadway deicing. 

Natural gas well brines managed under this agreement shall not be mixed with other 

types of solid wastes, including hazardous waste, municipal waste, other residual waste, special 

handling waste, or regulated radioactive waste. 

Nothing in this agreement shall be construed to supersede, amend, or authorize a 

violation of any of the provisions of any valid and applicable local law, ordinance, or regulation. 

The activities authorized by this agreement'shall not hanm or present a threat of hann to 

the health, safety, or welfare to people or the environment. The terms of this agreement will be 

modified or suspended to prevent hanm to the public health or environment or if brines cannot be 

regulated under the condition of this agreement. 

Facilities and equipment used for the storage of natural gas well brines shall be 

maintained in good operating condition. All storage tanks, secondary containment systems, and 

transfer lines shall be set up and operated in a manner that prevents spills, leaks, or other 

releases. 

Personnel shall be properly trained and educated on the implementation of prewetting, 

anti-icing, and deicing applications. The training must consist of a working knowledge of the 

application rates specified in this agreement and an understanding of the equipment used to mix 

or apply the brine to the roadway. Only personnel which have received adequate training shall 

be permitted to use natural salt brine under this agreement. 

Due to the potential for groundwater contamination resulting from the prewetting of 

storage piles, the brine shall only be applied to material just prior to roadway application. 

Each source of brine used for roadway prewetting, anti-icing, and deicing purposes shall 

be analyzed for all the criteria listed in this agreement prior to any application of gas well brine. 

The freezing point of the brine must be determined. Only gas well brine with a freezing point 

below 0 degrees F will be acceptable. 

For each new source of natural gas well brine, an analysis of the criteria listed in this 

agreement shall be submitted to the WVDEP for approval.