Marcellus Shale Permit Application Training
Wastewater 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
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
2
Residual Waste Generator
Requirements (287.51-287.55)
3
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=7780d84
0f80b00008000091800000918&ft=1
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
4
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
Form 26R, Chemical Analysis of
Residual Waste Annual Report by
the Generator
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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/landrecwast
e/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
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)
8
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
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.
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Wastewater Delivery to a POTW or CWT
Facility (cont)
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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.
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
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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.
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Example of Form Receiving Facility
Needs to Submit to DEP
Volume
DAY
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
gallon
License Plate
#
Well Permit
#
Location of Well(s) generating wastewater
Generator
Address
Wastewater
Type
State
14
Chemical
Analysis
Yes/No