This group brings together the best thinkers on energy and climate. Join us for smart, insightful posts and conversations about where the energy industry is and where it is going.


The BLM Makes the Case for Banning Waste Pits, but Doesn't Ban Them

Amy Mall's picture
Amy Mall 1257
  • Member since 2018
  • 51 items added with 21,688 views
  • Dec 26, 2012

Amy Mall, Senior Policy Analyst, Washington, D.C.

The BLM recently issued a new Instruction Memorandum to its field offices. This IM establishes policy for reducing preventable wildlife mortality, increasing protection of livestock, and increasing human health and safety around oil and gas facilities.

The IM points out the risks of open air waste pits–risks that have been well documented. NRDC and our partners called for the BLM to ban open air waste pits in our recent comments on the BLM’s proposed fracking rules (and we have also called for the EPA to ban them nationwide). The economical alternative to pits is something called a “closed-loop system” that uses enclosed steel tanks instead of pits to store potentially toxic waste.  

The BLM IM states that : “Closed or semi-closed loop systems minimize waste, livestock and wildlife entry, fugitive emissions that may affect air quality, and the risk of groundwater contamination. In addition, the use of tanks or dry cuttings pits, in place of open fluids pits, can result in reduced initial surface disturbance and expedited interim reclamation.” We agree that open air pits present a multitude of very serious risks to clean water, clean air, wildlife, wildlands, and human health.

The BLM goes on to say that field offices “should encourage operators to use closed tanks and closed loop or semi-closed loop systems,” and if an operator wants to use open pits or open tanks, then the BLM needs to analyze that approach through the review process that is conducted under the National Environmental Policy Act (NEPA), and the BLM must consider alternatives, or mitigation options for the open pits or tanks.

That all might sound good. While we are pleased that the BLM has acknowledged all the risks presented by shoddy waste management systems for what can be extremely toxic waste, we are disappointed that these methods are still left as an option for oil and gas companies. The BLM has characterized these risks as “preventable” — but isn’t taking the concrete action necessary to ensure they are prevented. The BLM is in the midst of a rulemaking where it can and should prohibit these dangerous methods.

The new IM also discusses the importance of secondary containment systems for tanks, methods to keep birds and bats away from from dangerous exhaust stacks, and marking fences that can endanger ground-nesting birds like sage grouse. These are all things that should also be required, not just encouraged. Requiring all of these practices–well known to protect natural resources–would not only protect wildlife, human health, and the environment, but would save the BLM from some additional NEPA review.

Amy Mall's picture
Thank Amy for the Post!
Energy Central contributors share their experience and insights for the benefit of other Members (like you). Please show them your appreciation by leaving a comment, 'liking' this post, or following this Member.
More posts from this member
Spell checking: Press the CTRL or COMMAND key then click on the underlined misspelled word.
Ronald Weedbaum's picture
Ronald Weedbaum on Dec 28, 2012


In the context of other environmental problems that we face, how would you rank fracking and the associated problem of waste pits? I mean compare it to coal mining, coal burning, tar sands mining and processing, fertilizer and pesticide use, the creation of dead zones from eutriphication, immense problems associated with livestock, deforestation, soil erosion, population growth, human sewage problems, global warming,  overfishing, landfills, fresh water depletion in arid areas, etc. Where do you rank fracking and the associated problem of waste pits in comparison to these problems? How many people and animals have actually died or been made sick by fracking and waste pits? 

I'd have to say that fracking would come in way after all of those other problems in terms of actual impact on people and animals.  And shale gas actually is a major improvement from an environmental perspective when compared to coal which is what we will use if we don't frack for shale gas. As an environmentalist, why are you spending so much time and effort on a problem that pales in comaprison to other more pressing problems?


Amy Mall's picture
Amy Mall on Dec 28, 2012

Dear Concerned Scientist: All of the polluting industries you mention present very serious threats to human and animal health and the planet and need to be addressed. Let me know if you would like information on our work on harmful activities other than fracking. We don't rank them. While burning natural gas at power plants can be an improvement when compared to burning coal, that doesn't mean that natural gas producers shouldn't be required to clean up their act. They have the technology and economic ability to capture toxic air emissions, store waste in tanks instead of pits that leak and spill, install safer casing, stay away from schools, and more. Why should they get a free pass?

Ronald Weedbaum's picture
Ronald Weedbaum on Dec 28, 2012

You should rank the activities though. Should we spend our time equally fighting cancer and fighting hangnails?

I'd like to see proportional effort to the seriousness of the problem. The way NRDC and other environmental groups are treating fracking, it makes it sound as bad or worse than many of the problems I just mentioned when in fact the rise of shale gas has in fact been a net improvement for the environment because it does displace coal. I'd guess that many people think fracking is a greater threat than global warming or any of the other issues I raised above. That is because they are being bombarded with polemics from the NRDC and others and are not being given the straight story including the positive aspects of shale gas.

I do not think that companies should get a free pass when they cut corners or pollute where they shouldn't. To the contrary  I agree that companies should be required to do it right. Many companies are already doing it right.  All are being judged by the worst incidents or the worst actors amongst them. I suppose that is to be expected.

I'd like to see NRDC and other organiztions be straight on the positive impacts of shale gas for the environment as well. Not only is shale gas enabling us to reduce GHG emissions but it is also enabling major reductions in the emissions of particulate matter (a known killer), SO2 (which causes acid rain), mercury (which really does pollute water) and other air pollution. Coal mining pollutes streams and rivers way more than all fracking combined. I would just like to hear someone from the NRDC or the Sierra club acknowledge these facts and to say "Done right shale gas is a very positive development from an environmental perspective." It is not the ultimate goal but a major step in the right direction. 

If the US and the rest of the world were to switch from coal to shale gas it would be the best possible thing that could happen over the next 10 years from an environmental perspective. But with the way that NRDC, Sierra Club, Josh Fox, ProPublica and others are demonizing it it is much less  likely to happen. Countries will go on burning coal because the threats from shale gas and fracking have not been put in perspective or "ranked."




Amy Mall's picture
Amy Mall on Dec 28, 2012

Concerned Scientist:

Here is NRDC's latest statement on the role of natural gas in America's energy mix:

We work on a wide range of issues and our priority issue areas can be seen here:



Paul O's picture
Paul O on Dec 31, 2012

Lacking deeper knowledge on Fracking waste, I'm not sure how much my contribution is worth, but here it is:-

1) I'd like to know just what waste products constitute these waste pits

2) Are these waste products harmful to the environment, or to people and wildlife?

3) Will these waste products self resolve given some time, or will they remain harmful for indefinite or very long  periods of time?

I'd like basic fundamental information so as to be able to make up my own mind on fracking waste, as with other things.

Amy Mall's picture
Amy Mall on Dec 31, 2012

Dear Paul O: These are excellent questions. The contaminants in oil and gas wastes include carcinogens, radioactive materials, heavy metals, and more. There are substantial risks associated with pits to air, groundwater, surface waters, soil, wildlife, and human health. NRDC provided details about the contaminants and the risks in a petition to the U.S. Environmental Protection Agency. The petition can be found here:

These wastes can be very toxic and cause dangerous air and water pollution. Whether the problems will resolve over time will depend on the extent and type of contamination. Groundwater pollution in particular  can remain harmful for centuries. Soil contamination can also be very long lasting.

Ronald Weedbaum's picture
Ronald Weedbaum on Dec 31, 2012


This post is an excellent example of scare tactics 101. First use these words: carcinogen, radioactive and toxic as much as possible. Next, use presence/absence instead of concentrations. 

Note that what is not mentioned are the concentrations of carcinogens, the concentrations of radioactive materials and the concentrations of heavy metals. A common approach used by those who want to fan the flames of fear is to use this presence/absence approach rather than discussion actual concentrations.  Ask for concentrations and how these concentrations compare to what is thought to be a dangerous concentration.   Using this approach, something might have 1 part per trillion of a radioactive or carcinogenic substance where the danger level is 10 parts per million. But you can still say with a straight face that the substance has carcinogens in it. That is technically true but they are not present at concentrations that are problematic.

Go look at the safe drinking water standards and you will see that it is OK to drink water with cyanide, arsenic, asbestos, lead, mercury and many other scary sounding things as long as it is below a certain concentration. In fact we are probably all drinking water that has tiny trace amounts of many things that could be deadly in larger concentrations. Spring water from the most pristine, beautiful spring on earth could have any of these and more.

Almost everything on Earth is radioactive. Babies are radioactive. Flowers are radioactive. At tiny, tiny concentrations that are not harmful but they are radioactive. So again, people can say that about anything that they want to scare you about.

Always ask for concentrations. Chalk it up to scare tactics if they use presence/absence.

The main problem with this waste is the presence of salt (CaCl or NaCl). Formation fluids are extremely salty - commonly 6-8 times saltier than sea water so the fluid that flows back after a frack job is commonly very salty. That is why these fluids should never be allowed to seep into groundwater or surface streams. Salt does not scare people quite the way that carcinogens and radioactivity do though. The chemicals from the fracking, the radioactivity, the heavy metals are minor issues by comparison.

Get Published - Build a Following

The Energy Central Power Industry Network is based on one core idea - power industry professionals helping each other and advancing the industry by sharing and learning from each other.

If you have an experience or insight to share or have learned something from a conference or seminar, your peers and colleagues on Energy Central want to hear about it. It's also easy to share a link to an article you've liked or an industry resource that you think would be helpful.

                 Learn more about posting on Energy Central »