Marcellus Shale Permit Application Training Wastewater Characterization and Transportation

1. Marcellus Shale Permit Application TrainingWastewater Characterization and Transportation Steve Socash ssocash@state.pa.us (717) 787-7381 John Wetherell jwetherell@state.pa.us (717) 787-8184 Pennsylvania Department of Environmental Protection Spring 2009

2. Wastewater Characterization and Transportation • Residual waste generator requirements • Chemical analysis, Form 26R • Transportation of wastewater requirements • Signs on transporting vehicle • Recordkeeping/reporting • Transporter log • Requirements for wastewater delivery to a POTW or CWT facility • Information required by the POTW or CWT facility

3. Residual Waste Generator Requirements (287.51-287.55) • Reporting and recordkeeping (addressed by 78.121) • Source reduction strategy (requirements addressed by Oil and Gas Operators Manual, Chapter 4) • Chemical Analysis of Residual Waste, Annual Report by the Generator (Form 26R) • http://164.156.71.80/WXOD.aspx?fs=7780d840f80b00008000091800000918&ft=1

4. Form 26R, Chemical Analysis of Residual Waste Annual Report by the Generator • 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

5. Form 26R, Chemical Analysis of Residual Waste Annual Report by the Generator, Instructions 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

6. Form 26R, Chemical Analysis of Residual Waste Annual Report by the Generator • Form 26R must be submitted to PADEP annually for each waste stream by March 1 • 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

7. Transportation of Wastewater(Chapter 299, Subchapter B) • Applicable when transporting residual waste • No transporter registration required • Note: For disposal or processing at a landfill 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 • Vehicle signs • Name and address of person who owns vehicle • Designated: Residual Waste • Lettering needs to be at least 6 inches in height

8. Transportation of Wastewater(Chapter 299, Subchapter B) cont. • 299.219 Recordkeeping and Reporting • Daily operational record (log) • 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)

9. Wastewater Delivery to a POTW or Centralized Wastewater Treatment (CWT) Facility 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

10. Wastewater Delivery to a POTW or CWT Facility (cont) • Within 30 days of the initial generation of wastewater from the fracing operation, the generator will need to characterize the actual impounded or stored fracing wastewater to be sent to the approved receiving facility • Submit a copy of 26R form with this chemical characterization to the receiving facility.

11. Wastewater Delivery to a POTW or CWT Facility (cont) • Receiving facilities that do not receive a copy of this 26R for the wastewater within 30 days of initial delivery, can not accept further loads of the wastewater 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.

12. Record Keeping Requirements at the POTW or CWT Facility • Type of wastewater received and well permit # • 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

13. Record Keeping Requirements at the POTW or CWT Facility (cont) • 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.

14. Example of Form Receiving Facility Needs to Submit to DEP