Forget about rationality, subjectivity, objectivity, apologist studies, and the rest of the words used to describe various points of view, opinions and rhetoric. How about one simple word – Reality! Chemicals are everywhere. In our homes, in industry, in agriculture, in our cars, virtually everywhere; look around you. This offers numerous pollution opportunities.
According to the USEPA the average U.S household generates more than 20 pounds of household hazardous waste annually. While all industrial facilities are regulated on how and where they should dispose of waste, households are not. EPA developed a household waste EXEMPTION. The exemption allows us to perform our routine maintenance tasks around the house without applying for a disposal permit. It allows us to have solvents, paints, pesticides, fertilizer, rodent poisons, grease, oven cleaners, drain openers, used oil, antifreeze, batteries, lighter fluids, cosmetics, nail polish, insecticides, household cleaners…. all defined as hazardous in our homes. Based on 20 pounds of hazardous waste per household and there are 7,482 households in Schuyler County (Census 2006-2010) then approximately 150,000 lbs. of hazardous waste produced is produced annually. This doesn’t even include the sanitary waste which may contains metabolized and un-metabolized highly stable and hazardous pharmaceuticals that end up in septic systems and wastewater treatment plants. This is a definite, this is reality; not a potential, not a probable, this is happening. Our homes may as well be mini-industrial facilities.
Cuyahoga River Burning (image NOAA)
Somehow, we have taken care of all this exempted household waste and our waterways are not degrading.
Environmental history shows us that the Clean Water Act (CWA) arose out of need to end the degradation of our national waterways back in the early 1970s (remember the Cuyahoga River burning?).
Our waterways are cleaner than they have been in over 30 years and they are not going back, even with 20,630 significant industrial users discharging to public wastewater treatment plants. Regulations written under the CWA make sure waste treatment plants do not introduce toxic or non-conventional pollutants in waterways.
In fact to effectively manage concern over shale waste the EPA recently initiated a rulemaking process that will set pre-treatment water quality standards for wastewater from shale gas activities. This rule that will not be proposed until 2014 would add a pretreatment standard to the Oil and Gas industry making sure wastewater treatment have an easier task.
Peter Mantius says that when it comes to treating shale waste, the state is hoping for the best. He can’t be further from the truth. Just ask Michael J. Sligar, he wrote an article titled “One POTW’s Acceptance of Hydrofractured Water” that appeared in the NYWEA Magazine in winter 2010 (volume 40). In the article, Sligar outlines his ordeal navigating through the regulations and requirements when he attempted to obtain a permit for his facility (Watertown WWTP) to accept a small amount of shale flowback. The sGEIS in draft form (which will still undergo significant updating) unveils a straight forward plan to address shale wastewater management. Section 6.1.8 gives an assessment of the wastewater concern and discusses how the NYSDEC plans to mitigate potential impact. Operators are required to file fluid disposal plans pursuant to 6 NYCRR §554.1(c)(1). These plans have to be in place prior to the issuance of the drilling permit. Also referenced in the section is Appendix C of TOGS 1.3.8, Guidance for Acceptance of New Discharges which provides guidance to any pre-treatment POTWs that plan on accepting shale wastewater.
Can shale waste be treated? NORM in the form Ra 226 has been shown to precipitate out during treatment. High salinity waste? Wastewater from vegetable pickling plants, seafood processing plants and also some cheese processing plants are high in salinity; they get treated and discharged. Marcellus waste is really not a whole lot different from any other existing wastewater streams.
Note: NYS Regulations have been re-released and updated since the penning of this piece.