In brief, it appears that the hydrofracking mixture spilled recently in PA falls under the Underground Injection Control Program of the Safe Drinking Water Act (while most compounds are now exempt). The ramifications may be significant, but depend in part on how Pennsylvania is, or is supposed to be, handling this matter.

Originally, I was examining the  MSDS, or Material Safety Data Sheet, for LGC-35.  This is the hydrofracking product, made by Halliburton, that was involved in a  chemical spill in Pennsylvania, as reported by Reuters.  I did a post about the incident a while back, here.  There were fines and a temporary ban was imposed on the company doing the fracking.

The MSDS for LGC-35  is posted here, by the Finger Lakes Sierra Club group.  The two constituents of this mixture are listed in the MSDS as paraffinic solvent (30 – 60%) and polysaccharide (30 – 60%).  I’ve been going through other MSDSs and chemical databases, and, in the final analysis, I think it is supportable (stay tuned for more supporting detail) to say that, for purposes of the Safe Drinking Water Act (as changed by the Energy Policy Act of 2005), this paraffinic solvent (or paraffin) is a basically a type of diesel fuel.

Now, the relevant section of the amended Safe Drinking Water Act reads

(d) “Underground injection” defined; underground injection endangerment of drinking water sources
For purposes of this part:
(1) Underground injection.— The term “underground injection”—
(A) means the subsurface emplacement of fluids by well injection; and
(B) excludes—
(i) the underground injection of natural gas for purposes of storage; and
(ii) the underground injection of fluids or propping agents (other than diesel fuels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities.

(My emphasis.)

If this analysis is correct, then LGC-35 is not excluded from the definition of “underground injection,”  and PA’s Underground Injection Control program ought to apply to the wells using LGC-35. It should prove interesting to examine what sorts of monitoring and other requirements come into play here.


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