GMA offers comments on ‘fracking’

Calls for geosynthetic lining and stabilization applications.

Editor’s note

The Geosynthetic Materials Association (GMA) has commented on a revised proposed rule from the U.S. Department of Interior-Bureau of Land Management (See document below dated August 20, 2013.) The revised proposed rule is entitled, Oil and Gas: Hydraulic Fracturing on Federal and Indian Lands. The purpose of the comments is for GMA to make a public statement that promotes geosynthetic materials as a best practice for fracking applications as it relates to the Department of Interior’s regulations. GMA’s comments were also discussed during congressional office visits during today’s (Sept. 19, 2013) GMA Lobby Day in Washington, D.C.

-Ron Bygness

August 20, 2013

U.S. Department of the Interior
Bureau of Land Management
Washington, D.C. 20003
43 Code of Federal Regulations Part 3160
Oil & Gas: Hydraulic Fracturing on Federal and Indian Lands
Regulation Identifier No. 1004–AE26
ACTION: Supplemental notice of proposed rulemaking and request for comment.

Introduction

In response to the revised proposed Department of the Interior rule entitled, Oil and Gas: Hydraulic Fracturing on Federal and Indian Lands, related to the care, separation, and storage of liquids and solids associated with the natural gas extraction process known as “fracking,” the Geosynthetic Materials Association (GMA) offers the comments and information below.

GMA recommends that the regulations propagated require the use of a composite liner system (geomembrane and geosynthetic clay liner) for containment and groundwater applications as this system has been demonstrated by the U.S. Environmental Protection Agency (EPA) to be the most effective barrier methodology, regardless of the classification of the materials (hazardous, non-hazardous, or designated for beneficial re-use). Further, GMA recommends that language and requirements be added to the regulations promoting the use of geosynthetic materials in supporting activities such as road construction, soil reinforcement and stabilization, and other infrastructure and construction related activities.

Statement of request(s)

In Oil and Gas: Hydraulic Fracturing on Federal and Indian Land, the Bureau of Land Management (BLM) solicits comments: The revised proposed rule would also provide opportunities for the BLM to coordinate standards and processes with individual states and tribes to reduce administrative costs and to improve efficiency. More specifically, Section 3162.3–3(d)(5) would require the operator to provide for BLM’s approval information about the handling of recovered fluids.

Further, Section 3162.3–3(i)(5) would require submission of the following information concerning the handling of recovered fluids: (1) The volume of fluid recovered during flowback, swabbing, or recovery from production facility vessels; (2) The methods of handling the recovered fluids, including, but not limited to, transfer pipes and tankers, holding pond use, re-use for other stimulation activities, or injection; and (3) The disposal method of the recovered fluids (end of section).

Respondent comments

Lining & Stabilization Applications—The materials and systems that have been used with great success during the past three decades and are the current standard-of-practice for lining and groundwater protection systems are manufactured by members of the GMA. GMA members, in cooperation with EPA and other industry participants have investigated, documented, and improved the protocol(s) for these materials over time. Much of this information has been created or gathered via EPA initiatives and publications. GMA provides a list of a few of the pertinent EPA publications that speak to this topic below. The most critical issue to GMA’s opinion is a requirement for a composite liner for the storage of liquid materials consisting of a geomembrane liner used with a geosynthetic clay liner as a composite system. EPA published studies have demonstrated the excellent performance of these systems over multiple locations and environments. The most obvious evidence of this fact is included as Appendix A of this correspondence and is extracted from the 2002 EPA publication titled: Assessment and Recommendations for Optimal Performance of Waste Containment Systems.

The inclusion of geosynthetics for reinforcement and stabilization of oil and gas well pads and access road construction is environmentally friendly, and long- and short-term cost beneficial. Depending on the specific site, designing and installing well pads and access roads with geosynthetics provides initial aggregate reduction. Reducing aggregate requirements to stabilize soft soils reduces both the number of trucks hauling aggregate and the amount of time spent operating heavy construction equipment, significantly reducing CO2 emissions and the carbon footprint. Additionally, the inclusion of geosynthetics in well pad and access road construction reduces the need for future aggregate maintenance. Finally, geosynthetics can protect native grasses and ease the removal of the aggregate layer to return the site to the original condition upon the completion of the fracking well. Aggregate installed directly on native grasses is difficult to remove following completion of heavy truck traffic. Geosynthetics provide defined separation of the aggregate and native grasses.

Conclusion

Based on the technical information referenced herein and additional EPA and other publications, GMA recommends that the U.S. EPA Subtitle D Regulation, federal regulations in 40 CFR Part 258 (Subtitle D of RCRA), be utilized and thus define and require a “composite liner” for liquid storage consisting of two components: an upper component consisting of a flexible membrane liner (FML), as specified by Subtitle D, and a lower component consisting of a geosynthetic clay liner containing at least 0.75 lb/ft² of sodium bentonite. If “composite liner” is not redefined to include a lower component GCL, then at a minimum an alternative liner design should be provided.

GMA thanks BLM for the consideration provided. GMA, its respective member companies, and their staffs are more than willing to respond to any additional BLM inquiry on this or other related topics.

Sincerely,

Andrew M. Aho
Director, Technical Markets
Industrial Fabrics Association International
1801 County Road B. West
Roseville, MN 55113-4061

Boyd J. Ramsey
Chairman, Executive Council
Geosynthetic Materials Association
GSE Lining Technologies Inc.
19103 Gundle Road
Houston, TX 77073