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The recent incident of brine and drilling-waste dumping near the D&L Energy headquarters at 2761 Salt Springs Road exemplified the need for citizen vigilance.
State officials have been clear in stating the importance of tips to law enforcement when dumping is witnessed. More importantly, the incident displays the need for Ohio Department of Natural Resources to adopt a more sophisticated tracking process regarding Ohio’s brine system known as “cradle to grave.”
Ohio’s brine-tracking program requires brine haulers to keep travel and manifest logs. In the case of the recent dumping, chief Richard J. Simmers of the ODNR’s Division of Oil and Gas Resources Management said regulators are in the process of requisitioning and reviewing the logs of the trucks known to bring brine to the site, also home to Hardrock Excavating among other companies.
This is being done to track down all the trucks that hauled brine to the site. By nature, this is a reactive process. The problem already has occurred. It was stated that without the unidentified tipster, the dumping may never have been discovered.
Ohio may wish to treat this environmental tragedy as a learning experience. It may be time to apply modern logistics techniques, using smart devices, GPS and cloud-software technology to track brine much more stringently in the future.
The state also should consider a management reporting application that will alert ODNR officials if brine turns up missing.
The specifics of this new system will take more than the space allotted for this column, but here’s what a logistics system for tracking might look like:
The key component would be a centralized database and an accessible Web service interfaced by a smart-device app. Each of the players would be assigned a smart device. All well permits, both extraction and injection, would need to be entered into the database. Each employee in charge of receiving or disseminating brine would need to be associated with those wells. Individual brine-hauling firms and trucks would need to be entered along with each driver.
It would be important to record each transmission of brine in terms of gallons. Also, each transmission would record the user who is responsible for each record’s accuracy.
It is assumed that a brine-hauling truck has a metering capability. It is also assumed that each injection well has a meter that will determine gallons injected.
Therefore, when a driver picks up a set number of gallons from a well site, it is recorded. The driver also may use this system to determine if and where temporary storage capacity is available. This aspect of the system actually may save money for brine haulers and injectors due to increased efficiency.
Of course, it will never compare to the fallacy that the most-efficient way to get rid of the brine is to dump it into the river, but perhaps the federal charges against Ben W. Lupo, the owner of both D&L and Hardrock Excavating, will end that perspective once and for all.
Now, let’s look at the process from the point of view of the brine-injection site manager. A truck arrives with brine. The amount that is put into temporary storage to await injection will be recorded by the injection-site manager and the hauler.
At this point, the hauler is relieved of responsibility for the brine shipment. Then the amount injected into the well will be monitored by the meter on the injection well. This amount will, in turn, update the amount of temporary storage space available at that site. Thus, future brine hauls will have up-to-the-minute data on where capacity exists. More importantly, if the amount of brine injected does not coincide with the amount of temporary storage space, then the proper authorities can be alerted that brine is missing.
Believe it or not, this is a rather simple application and business process to implement for those of us who are computer geeks.
In fact, the software-development industry would welcome the new stream of revenue the oil and natural-gas businesses provide to other sectors of the economy.