Transcript Wastewater Transportation2.ppt

Pennsylvania
Department of Environmental
Protection Bureau of Oil and Gas
January 2010 Training Session
 Residual waste generator requirements - development &
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completion of Form 26R
Submission requirements
Record-keeping requirements
Transporter Responsibilities
Waste Treatment facility requirements
Other stuff – Form U & Marcellus Shale Committee Study
 Reporting (addressed by 78.121)
 Source reduction strategy (requirements addressed
by Oil & Gas Operators Manual, Chapter 4)
 Chemical Analysis of Residual Waste, Annual
Report by the Generator (Form 26R)
 On the CD or available through O & G website
 Record-keeping
 Client Information
 Name, mailing address identified in the oil and gas
permit application, contact information
 Waste description
 Type, amount, unit of measure, chemical analyses
attachments
 Chemical analysis parameters for wastewater produced
from Marcellus Shale operations listed in Form 26R
instructions
 Laboratory information (accredited lab)
 Generating process description
 Identify well permit number or if centralized
impoundment the well permit number associated
with that impoundment
 Management of residual waste
 Information on receiving processing or disposal facility
Name, address, contact information, volume delivered
Section B. Waste Description
 Subsection 2. Chemical Analysis Attachments
 (B)(2)(d) applicable to wastewater produced from the
drilling, completion and production of a Marcellus
shale or other shale gas well, requires testing for 51
parameters
 Chemical analysis for specific parameters can be waived if
the generator certifies, in writing, that the parameter is
absent based upon generator knowledge
 Other analysis required by form including gross analysis,
trace analysis and hazardous determination not required
for wastewater produced from the drilling, completion
and production of a Marcellus shale or other shale gas well
provided Section (B)(2)(d) is completed
 Form 26R must be submitted to PADEP annually
by March 1st for each waste stream
 Can recertify without analysis for up to five years if no
changes to waste stream or process generating waste
stream
 Must reanalyze waste streams at least every five years
 Applicable when transporting residual waste
 No transporter registration required
 Note: For disposal or processing at a landfill or
other individual permit waste facility additional
transporter requirements may apply. Reference:
Waste Transportation and Safety Program
http://www.depweb.state.pa.us/landrecwaste/cwp/
view.asp?a=1238&q=463529
 Applicable when transporting treated water for
reuse unless “de-wasted” by DEP
Vehicle Signs
 Name and address of person who owns vehicle
 Designated Use: Residual Waste
 Lettering needs to be at least 6 inches in height
 Recordkeeping and Reporting (299.219)
 Daily operational record (log)
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Kept in cab
Type and weight or volume
Name, address and telephone number of generator
Name and location of destination facility
Name and address of person transporting
The license plate number of trailer
 Records of daily operational logs kept
by transporter for 5 years (kept in office)
 Prior to delivery of wastewater from a well site,
tank farm or impoundment to a POTW or CWT,
the wastewater generator will need to contact the
receiving facility to ensure that they have approval
from DEP to accept and treat the wastewater
 Within 30 days of the initial generation of wastewater
from the fracturing operation, the generator will need to
characterize the actual impounded or stored fracing
wastewater to be sent to the approved receiving facility
 Provide the Form 26R information, including chemical
characterization, to the receiving facility
 Receiving facilities that do not receive the Form
26R information for the wastewater within 30 days
of initial delivery, can not accept additional loads
from the generator from that well site for
processing, transfer, treatment or disposal
 For the first 30 days of wastewater generation after
fracturing, the operator of the well site will provide
and the receiving facilities will rely upon an oil and
gas industry generic characterization of the
wastewater.
 Type of wastewater received and well permit number
 The volume of wastewater received
 The name, mailing address, telephone number, county and
state of each generator of wastewater received
 The name and location of any transfer facility that received
and transferred the waste
 The name and address of the person or municipality
collecting or transporting the wastewater
 The license plate number of the trailer transporting the
wastewater
 This information should be available from the
residual waste transporter log. A copy of that can
be handed to the receiving facility or a copy made
at the receiving facility
 The receiving facility will be responsible for
summarizing information from all Marcellus Shale
wastewaters received to include the information
from the previous slide on a report to be submitted
to DEP with their monthly Discharge Monitoring
Report.
Volume
DAY
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18
gallon
License
Plate #
Well Permit
#
Location of Well(s) generating wastewater
Generator
Address
Wastewater
Type
State
Chemical
Analysis
Yes/No
 Treatment activities at well site regulated under Chapter 78
(relating to oil & gas wells)
 Storage and transportation of the treated wastewater off the
well site is managed under the Residual Waste regulations
unless a determination is made by the DEP Waste Program,
in writing, that the treated wastewater is no longer a waste
 When treated wastewater is reused at another well site the
activities at that well site are again regulated under Chapter
78
 DEP Waste Program general permits for treatment off of the
well site prior to waste reuse are under development
Steve Socash
[email protected]
(717) 787-7381
Ron Furlan
[email protected]
(717) 787-8184
Pennsylvania
Department of Environmental Protection
January 2010