DEP needs to hear from you!

A Message from the RDA…

DEP needs to hear from you and your organization.

Pennsylvania’s Department of Environmental Protection (DEP) has proposed new regulations for industrial wastewater that is high in total dissolved solids (TDS).

Natural gas drilling operations in the Marcellus Shale uses substances high in TDS for hydrofracturing (fracking) wells. The wastewater  that comes back out of wells (flowback fluid) after fracking is also high in TDS. The high levels of TDS in Marcellus wastewater is mostly in the form of salts and can be two to four times saltier than seawater.

Frac and flowback fluids can enter streams and rivers intentionally (legally by permit) or accidentally. The result can be a danger to health for all organisms – including humans. It can also make the water unfit for industrial use.

DEP needs the new regs to ensure that wastewater generated at Marcellus Shale gas drilling sites does not damage streams and rivers.

To read details about the proposed new regs, go to this link in the PA Bulletin: http://pabulletin.com/secure/data/vol39/39-45/2065.html

DEP’s  Environmental Quality Board (EQB) held several public hearings on the proposed new regs held across the state, and some of the testimonies given by members of the public can be viewed at this site:  http://www.northcentralpa.com/category/category/gas-drilling

DEP needs to hear from all who care about our environment, our heath and the businesses which depend on clean water.

Please consider having your organization send a letter or email to the EQB commenting on the proposed new regs. Feel free to craft comments based on the testimonies of others and/or from the talking points noted at the end of this message.

If individual members of your organization are willing to write letters or send emails to the EQB, that would be very helpful.

Natural gas industry representatives are lobbying very hard, backed by substantial funding, to prevent any strengthening of the existing regs. In fact, lobbyists are asking for the regs to be even weaker than they are now.

Send written comments by postal- or e- mail on the proposed rule NO LATER THAN FEBRUARY 10, 2010:

Environmental Quality Board
P.O. Box 8477
Harrisburg, PA 17105-8477
regcomments@state.pa.us

Here are some talking points to make about DEP’s proposed changes to Chapter 95, Wastewater Treatment Requirements. These come courtesy of Clean Water Action.

1.  We need safe drinking water!  DEP’s proposal will go a long way towards ensuring that our drinking water supplies will not have unsafe levels of total dissolved solids (TDS).  DEP should not weaken their proposed discharge standard for TDS.

2.  We need these regulations to be in place as soon as possible to protect our rivers and drinking water.  DEP should stop giving out more drilling permits until wastewater rules are in place.  DEP should also stop allowing existing or proposed wastewater plants to pollute our rivers unless they follow these new rules.

3.  DEP should add discharge standards for those contaminants that are frequently found in Marcellus Shale gas drilling wastewater.  These would include bromides, arsenic, benzene, radium, magnesium, and possibly others.  Many of these contaminants are very difficult for drinking water systems to remove.

4.  DEP needs to ensure that all aspects of the generation of Marcellus wastewater are regulated.  Currently there are no requirements to track wastewater from drilling sites to treatment plants, and there is no oversight over the reuse of Marcellus wastewater.

Radioactive waste water? uh oh!

http://apps.grouptivity.com/socialmail/main.do?uId=208252&tId=351621&pk=82379009649&acn=zj!d9&pId=HeOHCWXaPRs=&acn=zj!d9

Recycling of waste water to be norm for Marcellus Shale gas wells

Recycling the wastewater or flowback from gas wells is a step in the right direction. However, you’ll notice that the article mentions that this wastewater is only 15% to 30% of the total amount of water used to fracture a well. What happens to the other 70% or so? Does it stay under the ground, deep in the shale and we hope it is never to be seen again? Does is slowly creep back into our ground water? Do any of the toxins used in the fracking fluid migrate back up through the ground with gases like methane and become problems for landowners later on?

Another concern. What are they doing with the wastewater right now? The regulations that DEP is putting in place won’t go into effect until 2011, but there is a lot of wastewater sitting around Tioga County, as well as other places, and there doesn’t seem to be a good plan for disposing of it. Hence issues like the one with Dunn’s Tank Service in Towanda, PA. And as the fellow in the article mentions Dunkard Creek, you just have to wonder what the streams will be like around here in another 30 years. We are still dealing with coal mining run off and contaminates from deep injection wells from the last 40 years.

By Rick Stouffer, TRIBUNE-REVIEW
Tuesday, October 20, 2009

Major companies drilling for natural gas in Western Pennsylvania’s Marcellus Shale rock formation are or soon will be recycling all the waste water recovered from their operations, executives said Monday.

Jeff Ventura, president of Range Resources Corp., emphasized the importance of recycling and reusing water recovered from its natural gas drilling operations in Washington County.

“We are recycling 100 percent of the flowback water, which is between 15 percent and 30 percent of the water used during Marcellus Shale well drilling,” said Ventura. A typical well drilled in the Marcellus Shale formation uses new horizontal drilling technology that uses millions of gallons of water to fracture gas-containing shale thousands of feet underground and may return 600,000 gallons of water to be recycled.

Ventura, a native of Penn Hills, spoke yesterday at Hart Energy Publishing’s “Developing Unconventional Gas East Convention” in the David L. Lawrence Convention Center, Downtown.

Recycling efforts are expected by proponents to play a huge role in achieving the state Department of Environmental Protection’s proposed 2011 water quality discharge standards.

Earlier this year, DEP Secretary John Hanger announced a proposal that all industrial water discharges contain less than 500 parts per million of total dissolved solids. The proposal would impact several industries, including natural gas development.

Water recycling is important because demand for treating wastewater from oil and gas production in the state is expected to reach about 9 million gallons a day this year, according to a DEP report. It is projected to increase to 16 million gallons next year and 19 million gallons a day in 2011, when new standards limiting such pollution would take effect.

Another major drilling company, Rex Energy Corp. of State College, is recycling all Marcellus Shale drilling water the company recovers.

“We believe that water-related issues in the Marcellus have been somewhat overblown, but we are recycling 100 percent of our recoverable water,” said Rex CEO Benjamin W. Huburt.

Not everyone is convinced that recycling recoverable water is the answer to potential water pollution problems within the Marcellus Shale formation, which covers an area including most of Pennsylvania and portions of New York, Ohio and West Virginia, more than 54,000 square miles.

“Two words, Dunkard Creek,” said Tom Hoffman, Western Pennsylvania director for Clean Water Pittsburgh, referring to a huge kill of fish, mussels and other aquatic life along a 30-mile stretch of Dunkard Creek in Greene County on the Pennsylvania-West Virginia border. Wastewater from drilling operations have been blamed for the incident.

A yellow algae usually found in very hot climates such as in the Southwest is believed to be the reason for the kill, although the direct source for the algae formation has yet to be determined, officials have said.

CNX Gas Corp. has agreed to suspend injections of wastewater from its coalbed methane gas operations at Consol Energy Corp.’s Blacksville No. 1 mine in Greene County.

DEP issues $3,000 fine to Dunn’s Tank Service for illegal transfer station in Wysox; Company was storing gas well drilling wastewater without permit

I just want to point out two things here.

1. There is something very wrong with the fact that we have a lot of wastewater sitting around in various places, permitted or not permitted, and no place or way to dispose of it. If this industry was new to the planet then I might cut it and the state agencies a little bit of slack, but it’s not new! They have been drilling out west at this rushed rate long enough to know that they are going to have waste water and it’s going to have to go somewhere. Heck, most local residents I have spoken with can figure this out and most of them are not that familiar with the gas industry. I want to know why this problem was not solved prior to the drilling. My suspicions are as follows. The DEP and the state of PA are new to this. On some level they might claim that they didn’t know what to expect. That really doesn’t get them off the hook though. It’s their job to protect and keep themselves informed and up to date on what transpires on the state lands and waterways, so they should have made sure that somebody in the DEP knew what was to come and then made sure the regulations were in place to take care of preconceived problems, such as waste water disposal. My other suspicions are purely political and I will not get into that here, especially since they are suspicions.

2. I find it to be either extremely short sighted and poor management for Dunn’s Tank Service to not know the laws that relate to their industry or to have made no effort to find out what they are. To me that basically says, ” We don’t really care and were not really that competent.” And they’re the ones responsible for transporting toxic wastewater around the state? Wonderful.

BY JAMES LOEWENSTEIN

The Department of Environmental Protection announced Tuesday that it has fined Dunn’s Tank Service Inc. of Towanda $3,000 for operating a waste transfer station without a permit last July in Wysox Township.

“Dunn’s was storing gas well drilling wastewater in tanker trailers and you must have a waste transfer station permit from the DEP to do that,” said DEP Northcentral Regional Director Robert Yowell. “DEP will take similar enforcement action against any other such illegal facility in this region.”

DEP inspectors investigated a citizen complaint in late July and discovered two tanker trailers at the Dunn site holding about 10,000 to 12,000 gallons of gas well drilling wastewater, the DEP said in a press release that it issued on Tuesday.

A Dunn’s employee told DEP inspectors that his company was transporting the wastewater to the tanker trailers for temporary storage when disposal facilities were unable to accept it, the press release said.

The DEP sent Dunn’s a notice of violation letter containing requirements that all wastewater be removed from the site and that no additional wastewater be transported there, the release said.

A DEP inspection in August confirmed that the company had complied with those orders, the release said.

The fine was paid to the Solid Waste Abatement Fund that pays for cleanups across the state, the environmental agency said.

Todd Dunn, owner of Dunn’s Tank Service, said his company did not know the storage of the wastewater required a permit.

“We’re from Oklahoma,” he said. “It was ignorance on our part on not knowing the law.”

He said the wastewater was actually stored at the site in two steel “frac” tanks.

In Oklahoma and Texas, storage of wastewater in the frac tanks would not have required a permit, he said.

He also said the wastewater that was stored was not hazardous. “It was basically fresh water,” Dunn said.

“There was no danger,” he said. “There was no contamination or anything like that.”

“I was shocked that they didn’t give us a warning,” rather than issue a fine, he said.

Dunn said that since the fine was imposed, Dunn’s Tank Service has held a workshop for its supervisors to make sure they know the DEP rules and regulations that would pertain to the company, he said.

Dunn’s Tank Service, which is headquartered in Oklahoma, has an office in Towanda.

James Loewenstein can be reached at (570) 265-1633; or e-mail: jloewenstein@thedailyreview.com.