30-Apr-14
Hydraulic Fracturing Review c/o
Verschuren Centre for Sustainability in Energy and the Environment
Cape Breton University
Re: Shale Gas
Dear Hydraulic Fracturing Review Committee,
As a parent and wastewater engineer, I have made a concerted effort to become better informed
on hydraulic fracturing. I recently attended the open house in Halifax hosted by Dr. Wheeler and
appreciated the exchange of information on the review process.
From a wastewater perspective, “Flowback and produced water can contain a number of
constituents at levels not typically found in WRRF [sewage treatment plant] influent”1.
Municipal wastewater treatment facilities are designed to treat typical municipal sewage and
there are wastewater discharge bylaws2 in place to ensure the wastewater characteristics are
within acceptable limits. “Fracking water can have a wide range of constituent concentrations
throughout the production cycle. The largest concern for WRRFs is typically high salinity,
measured as total dissolved solids (TDS) or specific conductance. Because salts are in the
dissolved phase, they are not significantly removed by biological and other traditional
wastewater treatment unit operations. Salts can have a negative effect on the biological treatment
process due, in part, to higher osmotic pressure. In addition to high levels of TDS, fracking water
can contain high levels of fluid additives, metals, and naturally occurring radioactive material.”3
Flowback and produced water loads into municipal wastewater treatment systems will have the
potential to upset the biomass and lead to non compliant effluent discharges by municipally
owned facilities with a secondary level (CCME National Standard) of treatment.
1
WEF Fact Sheet: Considerations for Accepting Fracking Wastewater at Water Resource Recovery Facilities
http://www.ccme.ca/ourwork/water.html?category_id=81#336
3
WEF Fact Sheet: Considerations for Accepting Fracking Wastewater at Water Resource Recovery Facilities
2
Further, how can effluent discharge objectives be determined if the “wide range of constituent
concentrations”4 are not known because of proprietary non-disclosure of the hydraulic fracturing
fluid?
I would like add my voice to the opposition to hydraulic fracturing. The majority of the
information I have reviewed leads me to conclude that a prudent direction would be to extend the
moratorium on shale gas development for a minimum of ten years because there are too many
risks and unknowns.
Thank you for your consideration
Ian Guppy, P.Eng, PMP
2081 Kline Street
Halifax, Nova Scotia
4
WEF Fact Sheet: Considerations for Accepting Fracking Wastewater at Water Resource Recovery Facilities