Marcellus Shale Coalition Releases the Facts on Flowback Water Treatment

CANONSBURG, Pa., Feb. 4 /PRNewswire/ — The Marcellus Shale Coalition today issued the following statement to provide the facts regarding water use and flowback water management in the development of natural gas from the Marcellus formation: “Pennsylvanians deserve to get the facts about water management for Marcellus Shale development.  We need to put an end to the suppositions that could threaten our state’s ability to create jobs and investment here at home. “Regulations governing the use and management of water needed to drill a Marcellus Shale well in Pennsylvania are among the most stringent in the nation, and ensure the protection of the Commonwealth’s water resources.  Water withdrawals from streams and rivers must be approved, including the withdrawal location and amount of water required for each well, as well as detailed storage and treatment plans. …

Some might ask how stringent are the regulations, and are they stringent enough. One of the regulatory agency representatives at a recent Marcellus Shale public meeting, said federal regulations are stronger than those in PA, but the feds only regulate a small portion of gas industry activities.

“The industry currently treats or recycles all of its flowback water. Recycling accounts for approximately 60 percent of the water used to complete Marcellus Shale wells, with greater percentages predicted for the future.  There are more than a dozen approved water treatment facilities available to treat flowback water, with plans for additional capacity in the future …

Some might ask what the nature of the treated or recycled end product actually is. How much of the original toxic materials and total dissolved solids (TDS) are removed by the treatment, and are ALL the permitted treatment facilities producing the same end product before discharge? Are some discharging only partly treated – or even untreated – fluid?  Is discharging any of the treated fluid into a waterway, injecting it deep into an abandoned well or burying it in a landfill environmentally benign and of no risk to public health? Also, given the number of wells currently producing flowback fluid, is a dozen treatment facilities adequate to protect the environment and public health?

“Claims about elevated levels of Total Dissolved Solids (TDS) in the Monongahela River from natural gas development have been refuted by studies that attribute a minimal amount of the total TDS levels to Marcellus Shale drilling activity. In fact, historical monitoring shows the variability of TDS levels in the Monongahela and other rivers to be a cyclical phenomenon over the past 30 years. …
Some might say that TDS is a scientifically-established environmental pollutant, known to damage freshwater aquatic organisms, endanger public health, interfere with potable water supplier’s services and with industries using water. They might ask whether adding more TDS to the Monongahela – or to any waterway – makes sense, regardless of whether the TDS comes from gas drilling activities or from some other source.
To read the entire press release, click here:

http://www.prnewswire.com/news-releases/marcellus-shale-coalition-releases-the-facts-on-flowback-water-treatment-83561557.html

For those unfamiliar with what the Marcellus Shale Coalition is, click here: http://www.pamarcellus.com/

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.

Public Supports Rules for Drillers

By DAVID THOMPSON – dthompson@sungazette.com

POSTED: December 17, 2009

More than 100 people turned out Wednesday for a public hearing regarding a Department of Environmental Protection proposal to set more stringent treatment standards on wastewater primarily associated with the natural gas industry.

The hearing was hosted by the state Environmental Quality Board and moderated by Patrick Henderson, executive director of the state Senate Environmental Resources and Energy Committee.

Of the approximately 20 people who testified at the hearing, held at the DEP’s Northcentral Regional Office in Williamsport, most were either in favor of the proposed standards or advocated even stricter or wider-reaching standards.

Two who testified said they believed current discharge standards are adequate.

The proposal would impose restrictions on the amount of total dissolved solids – or TDS – sulfate and chloride that can be discharged by a treatment plant into a waterway.

It also regulates levels of barium and strontium that can be discharged from wastewater specifically from the natural gas industry.

Deb Nardone of the Pennsylvania Council of Trout Unlimited spoke in favor of the proposed standards, calling it “a necessary tool” for the DEP to use to protect the state’s fresh water resources.

Nardone suggested that more stringent regulations may be needed in the future, but in the meantime, the ones proposed should be “in place as soon as possible.”

Anne Harris Katz of Fairfield Township said she and her husband were drawn to the area almost 20 years ago but now questions whether the move was a good choice.

Katz said she fears the gas industry will change the region’s “pristine environment, small-town atmosphere and the confidence that residents’ health and safety are adequately protected from the short- and long-term hazards of gas drilling and extraction.”

“The proposed new standards will decrease the amount of pollution, and in this instance, less is better,” Katz said.

Her husband, Harvey M. Katz, said the gas industry should bear the cost of treating its wastewater, not the public.

He added that water polluted by gas industry wastewater will impact the area’s aquatic life.

Nathan Sooy of Clean Water Action, which represents a consortium of environmental and watershed groups, spoke passionately about the impact gas industry wastewater could have on local waterways.

Sooy said the DEP proposal “will go a long way towards ensuring our drinking water supplies will not have unsafe levels of (TDS)” and urged the agency not to weaken the proposed discharge standards.

Sooy added that the rules should be put in place as soon as possible, that no drilling permits be issued until that happens and that discharge standards should be applied to other materials found in gas drilling wastewater.

City resident John Bogle said the gas industry will prove harmful to the state’s tourism industry, the Pennsylvania Wilds initiative, agriculture and property values.

Bogle suggested the industry could adversely impact the area in ways similar to the coal industry.

“A trip through the coal regions will show what pollution from an unregulated extractive industry can do to the economic future of a region.”

“The DEP’s proposed TDS strategy is a solid move in the right direction,” he said. “The DEP needs to stick to its guns.”

Jerry S. Walls, former director of the county planning department, said it is “vitally important for Pennsylvania to have effective policy standards for the discharge of total dissolved solids.”

According to Walls, clean water is as essential to a healthy environment and positive quality of life.

“Our groundwater, rivers and streams should not be viewed as easy, unlimited waste disposal systems,” he said.

Walls said he was involved in the planning, design and development of the Lycoming County landfill. The DEP has specific standards regarding the control of leachate from the landfill. However, frac water flowback impoundment lagoons at drilling sites “have no such standards” which ‘equals preferential regulatory treatment of the natural gas industry,” he said.

Walls lauded the industry’s efforts to recycle gas drilling wastewater, adding the proposed TDS standards would provide incentives to continue that practice.

John Tewksbury, a kindergarten teacher from Muncy, said he attended the meeting on behalf of his students who wanted him to speak in support of the regulations.

Tewksbury said the students were concerned with the impact pollution could have on rivers and streams.

F. Alan Sever, an engineer from Montoursville who worked for the DEP, said the Environmental Quality Board determined in 2001 that there “was no reason to assign statewide effluent limitations for total dissolved solids, chloride or sulfate.”

Sever said that except for isolated incidents on specific streams, the DEP has not shown that there is any reason to change that policy.

If the agency finds specific problem areas, it could assign “site specific” discharge limits at those sites, he said.

Sever also took issue with the cut-off date – April 1, 2009 – for when dischargers would fall under the new guidelines and those that would be gandfathered under the previous guidelines.

By grandfathering treatment facilities already causing problems and assigning stringent limits to those that did nothing to create a problem is unfair, he said.

He also cited an example of a discharge permit issued to a company several days prior to the cut-off day and suggested the permit was issued “in order to protect this company from having to meet these new limits.”

Ned Wheeler, president of Keystone Clear Water Solution Inc., said the oil and gas industry has been in Pennsylvania for 100 years and has a history of cooperation with regulatory agencies.

Wheeler said the proposed regulations are “unrealistic and unreasonable” and do not take into account regulations already in place.

According to the DEP, the expected results of the new rules would be to prevent the water quality issues that came to light in 2008 on the Monongahela River and ensure that the cost of treating gas industry-generated wastewater will not be borne by customers of drinking water systems.

In the fall of 2008, the river flow fell and concentrations of TDS, which mostly is salt, and sulfate in the river rose to historic highs.

According to the agency, the West Branch of the Susquehanna River and Moshannon Creek have a limited capacity for handling new loads of TDS and sulfate.

RDA info and meeting places/times

Stop the Department of Environmental Protection (DEP) from caving in to mining and gas industry pressure. These industries would like to transfer the water quality of the Susquehanna River to their bottom line by using it as an inexpensive dump for their salt and chemically laden waste water.

Attend the hearing on Wednesday 16th at 5:00, DEP’s office in the Old Grit Building at 3rd and William Street, Williamsport. Your attendance will support DEP’s own research which has lead to a good proposed strategy for new TDS discharges. Without public support, DEP may be forced to retreat from its own recommendations.
BACKGROUND
Last April DEP published a strategy to protect Pennsylvania Rivers from becoming too saline by greatly limiting the amount of Total Dissolved Solids (TDS) in NEW discharges into the rivers.
This strategy came after critical conditions appeared in the Monongahela River Basin due to mining and gas industry discharges. Gas drilling waste water, which is extraordinarily high in TDS, put the already stressed river over the limit for potable water withdraw.  Bromines from gas industry waste water react with disinfectants used in water plants to produce carcinogenic secondary chemicals.  The result was a drinking water health advisory issued to thousands of water users.
This September, forty three miles of Dunkard Creek, which stitches back and forth across the boarders of Pennsylvania and West Virginia, experienced a massive fish kill. The culprit, which wiped out almost all animal life in the stream, was toxins produced by an invasive algae which can only thrive in brackish water.
Below are some excerpts from DEP’s preamble to the hearing. Link to complete document here.     http://pabulletin.com/secure/data/vol39/39-45/2065.html

“Total dissolved solids (TDS) is comprised of inorganic salts, organic matter and other dissolved materials in water.”

“TDS causes toxicity to water bodies through increases in salinity, changes in the ionic composition of the water, and toxicity of individual ions.”

“Several studies on the potential impacts to aquatic life from these large TDS discharges were also conducted on major tributaries flowing into the Monongahela River in Greene County, PA. Each of these studies documents the adverse effects of discharges of TDS, sulfates and chlorides on the aquatic communities in these receiving streams. The former concludes that there is a high abundance of halophilic (salt-loving) organisms downstream from the discharges of TDS and chlorides and a clear transition of fresh water organisms to brackish water organisms in the receiving stream from points above the discharge to points below. It is evident from this study that increases in salinity have caused a shift in biotic communities.

The Monongahela River Watershed is being adversely impacted by TDS discharges and many points in the watershed are already impaired, with TDS, sulfates and chlorides as the cause.

In addition, watershed analyses conducted by the Department (DEP) of the West Branch of the Susquehanna River and the Moshannon River Watersheds have documented that they are also severely limited in the capacity to assimilate new loads of TDS and sulfates.”

You are needed. Attend the hearing to support DEP’s proposed strategy, based on good science, for protecting Pennsylvania’s waterway.
To speak at the hearing call 717-787-4526 to register.

J. Public Hearings

The Board will hold four public hearings for the purpose of accepting comments on this proposal. The hearings will be held at 5 p.m. on the following dates:

December 14, 2009
5 p.m.
Cranberry Township Municipal  Building
2525 Rochester Road
Cranberry Township, PA 16066-6499
December 15, 2009
5 p.m.
Department of Environmental  Protection
Cambria District Office
286 Industrial Park Road
Ebensburg, PA 15931
December 16, 2009
5 p.m.
Department of Environmental Protection
Northcentral Regional Office
Goddard Conference Room
208 West Third Street,
Suite 101
Williamsport, PA 17701-6448
December 17, 2009
5 p.m.
Lehigh County Government Center
17 S. 7th Street
Allentown, PA 18101
responsible drilling alliance

Use your feet…

Here is an email from the Responsible Drilling Alliance out of Williamsport, PA. please follow the link at the end of the message for more info.

Use your feet to protect our rivers.

Have your feet take you to the hearing in Williamsport on December 16th to support, with your presence, the proposed new rule for Total Dissolved Solids for gas industry wastewater.  Gas drilling waste water is extremely high in TDS.  Under current rules they are allowed to discharge this TDS content directly into the river.  The new proposed rules would greatly limit new TDS discharges.

Not surprisingly these new proposed rules have come under quite a bit of pressure from a number of industries not just the gas drillers.  It is important to note that these new rules will not apply to existing water discharges so they will not put anyone out of business. Only new discharges or large modifications to existing plants will come under them.

This September, more than forty miles Dunkard Creek in western PA was cleared of almost all its fish and other aquatic animal life by the toxins of an invasive algae.  Golden Algae, the culprit,  needed high levels of TDS’s to thrive. Last summer, even before the fish kill,  the Monongahela  River exceeded the TDS standard for potable water intake and its bromide content level required a health advisory to be issued.

Strong public support is needed to counteract industry’s efforts to lower the proposed standards.    We all need to show up to the hearing and speak or send in written comments.  Instructions on how at bottom of this email.

December 16, 2009
5 p.m.
Department of Environmental  Protection
Northcentral Regional Office
Goddard Conference Room
208 West Third Street,
Suite 101
Williamsport, PA 17701-6448

http://pabulletin.com/secure/data/vol39/39-45/2065.html

DEP should be ashamed of itself

Somebody please tell me WHY they gas industry is still drilling when we have all these problems popping up!?!?! Helen Humphrys comment about “a real challenge” is a terribly understated comment about polluted water!  I have been reading about the DEP’s findings and they are slowly realizing that they are going to have to create some new regulations and maybe change a couple of the old ones…and that will take effect in 2011, 2012. So what happens until then? What about the waste water from the drilling sites now?
At this point the DEP needs to step in and say NO DRILLING until this is resolved. I don’t understand why all of these public offices are treating the gas companies like we own them something. We don’t owe them anything! They owe the land owners and the state of PA and since the budget was signed with no severance tax we’re not even going to get that much out of them. If these companies want to continue to drill here then they should have to pay for all the waste water treatment facilities, all the water monitoring stations, heck they can pay for the state to hire more workers to keep tabs on all of this! If they want to drill here and take a resource that is going to make money for them then they should have to take the time and energy to make sure all the requirements are being met and the problem there lies in the the state of PA. PA has terrible regulations for their water and state land and as these problems arise they have done practically nothing to amend those regulations to make sure our water and forests are preserved and healthy. They’ll do but it will be too late. There is an awful lot of contamination that is going on and can go on between the start of the major drilling, about year ago, and 2012 when the new regulations actually take effect.
Okay, that’s my rant for the day. I used it up before noon…crap.
Levels of total dissolved solids spike in Monongahela
Thursday, October 15, 2009
By Don Hopey, Pittsburgh Post-Gazette

For the third time in the past 12 months, dissolved contaminants in the Monongahela River have spiked well above federal and state water quality standards for taste and odor, and the situation is expected to get worse.

The state Department of Environmental Protection announced yesterday that high levels of total dissolved solids, or TDS, in the river began showing up two weeks ago near the town of Crucible in Greene County. Since then, additional violations of the 500 parts per million TDS standard have been recorded in 46 miles of the river to Elizabeth in Allegheny County, where levels peaked on Saturday at about 600 parts per million.

“This is the second time we’ve noted high TDS levels this fall and that’s telling us that this is a problem,” said DEP spokeswoman Helen Humphreys. “We’ll be continuing to monitor the situation, but there’s no reason to think that levels will not go higher again. There’s no question we have a challenge before us.”

Last fall TDS levels exceeded water quality standards in more than 90 miles of the river and peaked at more than 900 parts per million.

The Monongahela River is the water supply for 350,000 people and the 11 public water treatment facilities that draw water from the river are not equipped to remove TDS, which is a measure of all elements dissolved in water, including carbonates, chlorides, sulfates, nitrates, sodium, potassium, calcium and magnesium.

For most, high TDS levels will make the water smell and taste bad and spot dishes and glasses but do not make an affected water source unsafe to drink. But individuals allergic to sulfates can be sickened, and the DEP has once again advised concerned residents to use bottled water for drinking and cooking until river flows increase and TDS levels return to normal.

Sources of TDS include sewage treatment plants, drainage from abandoned and active mines, power plant scrubber and coolant water discharges and wastewater from oil and gas well drilling operations.


Still trying to solve the Dunkard Creek fish kill

Pa. points to mine discharge for Dunkard Creek fish kill

By Don Hopey, Pittsburgh Post-Gazette

A heretofore undisclosed underground flow of mine pool water between Consol Energy’s Blacksville No. 1 and No. 2 mines may have contributed to the highly salty, polluted discharges that caused the massive, month-long fish kill on Dunkard Creek.

The Pennsylvania Department of Environmental Protection said stream sampling shows discharges high in dissolved solids and chlorides from Consol Energy’s Blacksville No. 2 Mine are the “primary immediate source” of the fish kill that last month wiped out aquatic life on 35 miles of the 38-mile stream that meanders along the Pennsylvania-West Virginia border.

But the DEP, in a letter dated Wednesday, has also asked Consol to provide information of the underground connections between its active Blacksville No. 2 Mine in West Virginia and its inactive Blacksville No. 1 Mine in Pennsylvania, and requested that the U.S. Environmental Protection Agency revoke a deep well injection permit for coalbed methane waste water at the inactive mine.

The DEP also said it has obtained information that the mine pool in the inactive mine is flowing into the mine pool in Blacksville No. 2.

Consol has previously said that the wastewater from the inactive Blacksville No. 1 mine is not flowing into the active Blacksville No. 2 mine.

Fish, freshwater mussels, salamanders and aquatic insects started dying on Sept. 1 and continued dying throughout the month.

The Pennsylvania DEP has also asked the West Virginia DEP, in a letter dated Oct. 2, to “take necessary enforcement measures” to control pollution discharges of total dissolved solids, chlorides and sulfides from the Blacksville No. 2 mine treatment facility.

That treatment facility stopped treating and pumping mine water into the creek as the fish kill progressed last month, but Pennsylvania DEP wants assurances that the earlier pollution loads will not resume when it becomes necessary for Consol to resume pumping water out of its active mine.

“We have also observed that the levels of chlorides being discharged from . . . the Blacksville No. 2 Mine are unusually high for a discharge solely from a deep mine,” the Pennsylvania DEP said in that Oct. 2 letter. “Although Consol is primarily liable for its discharge from (Blacksville No. 2) and any consequences that result from that discharge, DEP is suspicious of other sources of chlorides that might be discharged into the Blacksville No. 2 Mine or into one of the mine pools connected to the Blacksville No. 2 Mine.”

In its six-page Oct. 7 letter to Consol, the Pennsylvania DEP requested extensive discharge and flow records dating back five years for the Blacksville No. 1 and No. 2 mines, the Morris Run Borehole where the coalbed methane drilling wastewater was injected into the Blacksville No. 1 Mine, and information about Consol’s management of interconnected mine pools in the area of southwestern Pennsylvania and northern West Virginia.

More details in tomorrow’s Pittsburgh Post-Gazette.
Don Hopey can be reached at dhopey@post-gazette.com or 412-263-1983.