Comments on Permitting Guidance for Oil and Gas Hydraulic Fracturing Activities Using Diesel Fuels—Draft: Underground Injection Control Program Guidance #84
From the comments:
In 2005, despite exempting most HF activities from the Safe Drinking Water Act (“SDWA”), Congress explicitly still required HF injections with diesel fuel to obtain UIC permits under the SDWA.
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Nonetheless, since that time, at least 32.2 million gallons of diesel have been used without the required permits in states with and without primacy under the Act. Across 19 states, no oil and gas operators applied for the permits and consequently no permits were issued.
Whether by exposure to humans or the natural environment, the dangers of diesel pollution or spill incidents are substantial, and the consequences are potentially lethal. Even minor spill incidents can create demanding and expensive health and clean-up challenges.
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EPA should prohibit the use of diesel fuels in fracturing fluids in all hydraulic fracturing activities, whether in coalbed methane, shale or other geologic formations . As was plainly stated by the Secretary of Energy Advisory Board’s Subcommittee on shale gas (SEAB), because diesel’s environmental risks far outweigh any potential justi fication for its use, diesel should never be used as an additive to fracturing fluid.