### ROADSPREADING OF BRINE FOR DUSTCONTROL AND ROAD STABILIZATION

Introduction
Brine produced from oil and gas wells and other source s such as brine treatment plants and brine wells have been used for beneficial use as a dust suppressant and road st abilizer on unpav ed secondary road systems. This does not include brin e produced from shale formations. Brine is present in subsurface formations and is typically produced along with oil and gas. Because of t he potential for contaminants from the brine to leach into surface or ground waters, t he Department of Environm ental Protection (DEP) has developed guidelines that must be followed when spreadi ng brine on unpaved roads. The guidelines were developed under the authority of Clean Streams Law , the Solid Waste Management Act, and Chapters 78 and 101 of the Rules and Regulations.
In accordance with the Clean Streams Law, it is unlawful to put, place or allow a discharge of any substance that would result in pollution of t he waters of the commonwealth, incl uding both surface and ground water. The purpose of these guideli nes is to minimize the environmental impac t resulting from the use of brine for road maintenance. The brine generator, the transporter, the applicator and the roadw ay administrator (e.g., PennDOT, municipalities or private owners) share the responsibility to assure t hat all activities are conducted in accordance with the guidelines and in a manner which will not re sult in pollution of the waters of the commonwealth.
DEP considers roadspreading of brin e for dust control and ro ad stabilization to be a beneficial use of the brine. Brine should only be spread at rates and fr equencies necessary to control dust. For excess brine produced from oil and gas wells, operators may need to develop alternative disposal options such as deep well disposal or tr eatment and discharge.
Approval Procedure Any person who spreads brine from oil or gas wells (o ther than brines produced fr om shale formations) or other sources (such as brine treat ment plants and brine wells) on unpaved roads for dust suppression and road stabilization must submit a plan to DEP on a year ly basis for approval. T he approval can be obtained by the operator, municipality, owne r of the road, or the service com pany. The plan must show how the potential to pollute is minimized. Approval from DEP must be received before roadspreading can begin.
Plans must include the following information:
1. The name, address and telephone number of the per son and company seeking the approval and of the person(s) doing the spreading. The license plate number of the brine sp reader truck(s) is also to be submitted. 2. An original signed and dated stat ement from the municipality or otherperson authorizing the use of brine on their roads and that they will s upervise the frequency of spreading. 3. A legible map of the municipality or area identifying the roads that are to receive the brine and brine storage areas not at the well site. 4. A description of how the brine will be applied, including the equipment to be used and the method for controlling the rate of application. 5. The proposed rate and frequency of application. 6. The identification of t he geologic formation from wh ich the brine is produced. 7. A representative chemical analysis of the brine for the following param eters: calcium, sodium, chloride, magnesium, and total dissolved solids.
DEP will review the plan to determine if all the inform ation requested in items 1 through 7 is present. If the plan is complete and does not show a violation of any ope rating procedures, an appro val will be granted. The approval will expire December 31 of the calendar year roadspreading was requested.Commonwealth of Pennsylvania Depart ment of Environmental Protection www.depweb.state.pa.us 5500-FS-DEP1801 Rev. 7/2011 Operating Requirements
Any person who spreads brine must follow the conditi ons listed below under pl ans approved by the DEP:
1. The application of brine to unpaved roads must be performed in accordance with the approved plan. 2. The brine may only be applied at a rate and frequency necessary to s uppress dust and stabilize the road. The rate and frequency of application must be controlled to prevent the brine from flowing or running off into roadside ditches, streams, creeks, lakes and other bodies of water or infiltrating to groundwater. 3. Recommended spreading rates: The road should initia lly be spread at a rate of up to one-half gallon per square yard (typically after the road has been graded in the spring). The road should subsequently be spread at a rate of up to one-third gallon per sq uare yard no more than onc e per month unless–based on weather conditions, traffic volume or brine characteristics–a greater freq uency is needed to control dust and stabilize the road. The a pplication rate for race tra cks and mining haul roads should be determined for each site and should not exceed one gallon per square yard. 4. Only production or treated brines (other than brines produced from shale formations) may be used. The use of drilling, fracing, or plugging fluids or production brines mixed with well servicing or treatment fluids, except surfactants, is prohibited. Free oil must be s eparated from the brine before spreading. 5. Brine must not be applied within 150 feet of a stream, creek, lake or other body of water. 6. Brine must be spread by use of a spreader bar with shut-off controls in the cab of the truck. 7. Brine must not be placed on sections of road having a grade exceeding 10 percent. 8. Brine must not be spread on wet roads, during rain, or when rain is imminent. 9. Each vehicle used to spread brine shall have a clearly legible sign identifying the applicator on both sides of the vehicle. 10. The company spreading the bri ne shall notify the appropriate regional DEP Oil and Gas Office the business day before spreading brine. 11. The producing oil and gas wells must be in comp liance with the bonding requirements of the Oil and Gas Act. 12. The person who received approval for the r oadspreading plan must s ubmit a monthly report (5500-FM-OG0046) to DEP indicating the location and amou nt of brine spread duri ng the month. This monthly report must be submitted bythe 15th day following the month in which the brine was spread. This report must be submitted even if no sp reading took place during that month. 13. Any revisions to the plan must be submitted to DEP for approval. Approval must be obtained prior to implementation of the revisions. 14. Failure to comply with all these conditions may result in DEP rescinding the plan approval.
Reporting Requirements
Transporters of residual waste must follow the requ irements of 25 Pa. Code §299 Subchapter B (Standards for Collecting and Transporting of Residual Waste). Tr ansporters must keep a daily operations record and file an annual operational report with DEP by March. Oil and gas operators who generate brine must report the amount on their Annual Production Report. Instructions accompany the Annual Production Report describing how to report brine being roadspread.
Where are plans submitted? Southwest Regional Office Oil and Gas Program 400 Waterfront Drive Pittsburgh, PA 15222-4745 Telephone: 412-442-4024 FAX: 412-442-4328 Northwest Regional Office Oil and Gas Program 230 Chestnut Street Meadville, PA 16335-3481 Telephone: 814-332-6860 FAX: 814-332-6121 Eastern Regional Office Oil and Gas Program 208 West Third Street Williamsport, PA 17701-6448 Telephone: 570-321-6550 FAX: 570-327-3420

For more information, visit www.depweb.state.pa.us , keyword: Oil and Gas.