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Luke McClendon
Mr. Peterson
ENGL 015-007
26 July 2015
Closed Loop Containment Systems: A Proposal to Isolate Hydraulic Fracturing Wastewater from
the Environment
Submitted To: Pennsylvania Department of Environmental Protection Office of Oil and Gas
Management
Submitted By: Luke McClendon
Submitted On: July 26, 2015
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Executive Summary
Closed Loop Containment Systems: A Proposal to Isolate Hydraulic Fracturing Wastewater from
the Environment
By: Luke McClendon
In Southwestern Pennsylvania the hydraulic fracturing (fracking) industry has found a
home extracting oil and natural gas from the Marcellus Shale Formation. Along with the
economic boom that came with the wells, a potentially tragic scenario has developed in
Southwestern PA. Eighteen impoundment ponds, some holding up to 15 million gallons of
fracking wastewater, are spread throughout the landscape. These man-made ponds are
environmental disasters waiting to happen. While there have been some recent expansions to
regulations to improve the water-tight integrity and leak detection capabilities of these ponds, I
think there is a better solution. I propose that the Pennsylvania Department of Environmental
Protection, as the regulatory authority responsible for the protection of the environment, consider
requiring all fracking wastewater be held in closed loop containment systems instead of only
ordering improvements to the existing containment measures. These tanks, along with the
associated platforms and spill containment equipment set up underneath them, will ensure that
these potentially harmful fluids are isolated from the environment.
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Leaking Impoundment Ponds Contaminate the Environment
In hydraulic fracturing (fracking), large amounts of water containing additives, called
proppant, are pumped into wells in order to create microfractures in the Marcellus Shale
Formation in Pennsylvania. The resulting high pressure fractures microfissures in the rock
formation, and the proppant keeps these fissures open so that gases can escape. The escaping
gases creates flowback which pushes a large portion of the water back out of the well. The
resulting chemical sludge, referred to as fracking wastewater, may contain materials such as
brines, metals, radionuclides, and hydrocarbons. Many of these chemicals can contribute to an
increase in greenhouse gasses or be harmful if inhaled. This contaminated water must then be
stored somewhere until it can be recycled for use in another well, treated to be placed back into
groundwater systems, or disposed of via deep injection wells (The Process). Due to the unique
geological formations in the area, the usual method of disposal for the industry, deep injection
wells, is typically not used. Because of this, the majority of the wastewater must be held for a
period of time before it is either reused or trucked out of state for disposal. The current method
of holding the fracking wastewater is huge open ponds called wastewater impoundments. Over
the years, many of these man-made ponds have sprung leaks polluting local waterways and
increasing potentially toxic chemical deposits in the ground. In Washington and Greene
Counties alone, there are eighteen impoundment ponds, six of which caused Range Resources to
receive fines of $4.15 million in 2014 because of environmental damage caused by leaks (Conti).
Isolating Wastewater via Closed Loop Systems
I propose that you, the Pennsylvania Department of Environmental Protection (PA DEP),
should mandate closed loop systems for all future impoundments. As defined by the Oil & Gas
Journal, “a closed loop system is defined simply as a mechanical and chemical system which will
allow an operator to drill a well without using a reserve pit (Astella).” In the Draft rules currently
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pending from the PA DEP, we find defined a “Modular Aboveground Storage Structure – an
aboveground structure used to store wastewater that requires final assembly at a well site to
function and which can be broken down and moved to another well site after use (Pennsylvania,
5).” The closed loop system I am recommending is essentially the same series of tanks as you
have defined here that will hold all wastewater until it can be reused, recycled, or properly
disposed. Utilizing these systems has the potential to decrease the current environmental risk
profile to which Pennsylvanians and Pennsylvania’s resources are being exposed by continuing
the use of open pit impoundments.
Why a Closed Loop System
As with any proposed increase in regulation, a delineation of reasons must be given to
justify the change. Additionally, we must also consider the effect of an increase in regulation of
the industry. The benefits of a closed loop system are certainly substantial to the environment
and people of Pennsylvania, but there are also benefits to the gas and oil industry. We must also
consider that you have already spent a substantial amount of time and effort on the current
proposed rules, and these changes would require restarting the process of publishing new rules.
Reduced Pollution, Happy Neighbors, and Money Saved
The greatest impact mandating closed loop systems will have is on the waterways and
groundwater surrounding the impoundment sites. These closed loop systems, if properly installed
on platforms above shallow emergency containment tanks, will have a much lower risk of
contaminating the environment than lined pits in the event that a leak occurs. Utilizing closed
loop systems for impoundments will also remove the possibility of evaporation of water and the
associated diffusion of substances in the water that are potentially harmful. This will also mean
that more water will be available for reuse at a later time since water will not be lost through
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evaporation. Closely related, odors commonly associated with impoundment ponds will not be
noticed by the local community. The final and potentially most important benefit to the industry
players is that there are several instances where a closed loop or tank system is actually more
cost effective than the current or proposed pit impoundments. The most substantial cost savings
to the industry is seen in the remediation of drilling sites. In many cases, it is cheaper to put
money into purchasing tanks at the onset of working in an area than it is to dig, line, maintain,
and remediate a traditional lined earth pit. One study conducted in New Mexico compared the
costs associated with a closed loop system and an open air impoundment pond and found that a
high cost forecast showed an open pit to cost $447,000 while a closed loop system would come
in at $180,000 lower for a total lifetime cost per well site of $267,000 (Carroll).
Departing Industry and an Invested DEP
There are two major obstacles to accomplishing the goal of implementing a closed loop
system: politics and investment in current proposals.
The political refrain is so common that it almost silences any opposition before it starts.
Whenever any regulation not seen as 100% favorable to the gas and oil industry is suggested, the
opposition immediately jumps in with the 'What if they leave?' question. There are actually two
readily apparent answers. First, since the beginning of the oil and gas exploration, the industry
has quickly adjusted to any regulatory changes. Second, there is too much value here and too
much invested for the companies to pull out as long as the potential for profit exists. From the
website of one of the largest producers in the area, rangeresources.com: “net production from
Quarter 1 2015 was 1.14 billion cubic feet equivalent per day.” At the current cost of natural gas,
$2.77/cubic foot, Range Resources stands to gain $3.15 billion per day just from the sales of
Marcellus Shale natural gas. While this figure does not take into consideration any costs incurred
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by the company and actual profits are going to be much lower, the potential earnings indicated
by this number suggest that the state has a long way to go before the gas and oil industries are so
taxed and restricted by rules that they will leave.
Currently, you appear highly invested in your recommended rules. The proposed rules
will require unconventional drillers (the defined term for wells that utilize hydraulic fracturing
and produce the wastewater at hand) to eliminate all temporary storage pits and transition to
centralized wastewater impoundment ponds that have tougher regulations than the currently
utilized impoundment ponds. These new ponds are supposed to be built like the landfills within
the state. The DEP Deputy Secretary for Oil and Gas, Scott Perry, has been quoted “It’s [the new
centralized impoundment] a substantially engineered structure, compared to the temporary pits
(Cussik).” Later in the interview Mr. Perry also said, “This is not an end point but a beginning
for discussion (Cussik).” Even though Mr. Perry’s circuit of interviews and press spots
demonstrates your investment in the current regulations, his comments give us hope for future
regulatory changes.
Making Progress Together
I know that we have just completed one stage of regulation review with several to go
before current regulations can be updated without even discussing new ideas. I know that to a
certain extent the gas and oil industry are customers of the state and we are trying to keep them
happy. I know that additional restrictions will require more training of your staff. These are not
small concerns and should be seriously considered as we move forward. I think that changing our
regulations to include a requirement for closed loop containment systems rather than centralized
impoundment ponds will not only be better for the environment, but we can also show that it will
be cheaper to purchase and utilize a closed loop system than it will be to continue upkeep,
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maintenance, and eventual remediation on the current style of impoundment ponds. Additional
regulations, while difficult and time-consuming, should hold the best interest of the environment
foremost. I firmly believe that it is in the best interest of the environment to keep this
contaminated water in a closed loop system to prevent potential environmental disasters.
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Works Cited
Astrella, Lance. “Technology – Closed Loop Drilling Systems can eliminate Reserve Pit Costs.”
Oil & Gas Journal. 27 May. 1996. n. pag. Web. 25 Jul. 2015.
Carroll, Daniel. “On-Site Wastewater Containment for Hydraulically Fractured Wells”
flimarcellusconference.files.wordpress.com 7 May. 2011. Web. 25 Jul. 2015.
Conti, David. “Range Resources to pay $4.15M fine, close old gas drilling impoundments.” Trib
Live. 18 Sept. 2014 n. pag. Web. 25 Jul. 2015.
Cussick, Marie. “With new draft rules, DEP steps up oversight of drilling waste.” State Impact
Pennsylvania. 9 Mar. 2015. n. pag. Web. 25 Jul. 2015.
Pennsylvania. Department of Environmental Protection. Draft Final Chapter 78a. 13 Feb. 2015.
Web. 25 Jul. 2015.
“The Process of Hydraulic Fracturing.” EPA.gov. EPA. n. d. Web. 25 Jul. 2015.