While disclaiming accurate figures for potential dusting, FracTracker estimate seems like a good first estimate for a maximum tophole volume (1500 ft depth) of about 12.5 inch diameter borehole for surface casing (water protection string). But then claim 70,000 ton from 721 wells when only about 600 were drilled. Hardly a good estimate, and just for surface casing not the well (you don’t make anything clear)
2. a) DEP added, to help control fugitive dust emissions, “a common measure used by operators is spraying water on the wellbore while drilling is occurring,” a practice also used by water well drillers.”
b)”Practice Is Pervasive In Conventional Drilling
The practice of “dusting” is pervasive in the conventional industry.”
So, dusting is common in drilling into the ground, and control methods are common to both petroleum and water well drilling. How serious is “dusting” in the water well drilling through similar geologic formations? Aren’t you concerned?
3. Dusting is a condition encountered while drilling, characterized as you have described, not a waste management technique after drilling. PA forms specify for surface casing point only, dusting into unlined pit. Drilling below surface casing seat, nada.
Poorly written Mr Hess, poorly documented FracTracker.
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