Conventional Oil & Gas Drillers Dispose Of Drill Cuttings By ‘Dusting’ – Blowing Them On The Ground, And In The Air Around Drill Sites

“Dusting” is one of several alternative on-site waste disposal methods DEP allows in its regulations for drill cuttings under 25 Pa. Code Section 78.61(d) for conventional drilling and 25 Pa. Code Section 78a.61(d) under the unconventional regulations.

All the alternative methods of disposal are supposed to be for on-site disposal of “uncontaminated drill cuttings” and can include methods like using “solidifiers, dusting, unlined pits, attenuation or other alternative practices” approved individually for each well by DEP.

According to DEP’s regulations and the forms used to approve dusting, only “uncontaminated” drill cuttings from drilling above the casing seat in an oil and gas well can be disposed of through “dusting.”

“Uncontaminated” drill cuttings are defined as “…drill cuttings [that] are not contaminated with pollutional material, including brines, drilling muds, stimulation fluids, well servicing fluids, oil, production fluids or drilling fluids other than tophole water, fresh water or gases.”

The casing seat– the bottom-most depth in a conventional oil and gas well where casing extends to prevent groundwater and other infiltration into the well– can be from hundreds, to 1,500, or more feet deep.

Total conventional well depths can be up to 12,000 feet.

In spite of the fact both conventional and unconventional oil and gas drilling goes through the same rock formations in the vertical part of the wells, how DEP regulates them differently.

The DEP form used by conventional operators to request approval of alternative disposal methods like “dusting” is two pages long.  It basically just says tell DEP where the driller is going to do it and describe in narrative form how they plan to protect the environment.

Specifically, the key part of the form asks drillers requesting alternative disposal methods to– “Complete this section if requesting approval of an alternative practice to dispose of drill cuttings or residual wastes at the well site. Describe the type of waste, including any additives, and the proposed alternative practice. Include information that will demonstrate the proposed practice will provide protection equivalent or superior to the practices identified in 25 Pa. Code sections 78.61 [Disposal of drill cuttings], 78.62 [Disposal of residual waste – pits], or 78.63 [Disposal of residual waste – land application].”

This form also allows DEP to approve on-site disposal of drill cuttings by using pits and land application– spreading them around the drill site, something they’ve done for decades.

The DEP form used by unconventional operators for alternative disposal methods is 13 pages long and requires operators to submit extensive information about the chemical and physical characteristics of the drill cuttings, and chemicals and fluids that could get into those cuttings or used in the drilling process and much more.

This form also allows DEP to approve on-site storage and processing of waste in addition to the on-site disposal of drill cuttings and “dusting.”

There is also a three-day notification requirement to DEP prior to the start of “dusting” at unconventional drilling operations, according to DEP.

There is also no way to confirm that conventional and unconventional oil and gas operators are only disposing of “uncontaminated” drill cuttings above the casing seat by “dusting,” unless a DEP inspector actually goes onsite to verify what’s going on.