Krancer will take part in the June 26, panel in Hershey with a senior NRDC attorney.
"NRDC's math is way off in terms of how much wastewater is being recycled by the shale gas industry, and the report does not accurately characterize the extent to which the regulations we have in place in this state are ensuring drilling proceeds safely and responsibly," Krancer wrote in the letter. "As we move forward, it is crucial that debate on proper policy and regulation rest on a solid foundation of facts."
The panel discussion about the regulation of hydraulic fracturing in the mid-Atlantic region is part of the Mid-Atlantic Conference of Regulatory Utilities Commissioners' June meeting. Krancer's 10:15 a.m. appearance will be alongside Kate Sinding, a senior NRDC attorney.
In the letter, Krancer noted that, contrary to the report, brine from shale formations is not being used in road spreading in Pennsylvania. Brine is salty water that flows back to the surface after gas wells are brought into production.
"The report also fails to consider several important measures that DEP has put into place, the upshot of which is that recycling of wastewater has greatly increased across the state," Krancer said, first mentioning the "dramatic sea change" in shale gas wastewater disposal practices that happened as a direct result of the April 2011 call on industry by DEP and Governor Corbett to cease delivering wastewater to treatment facilities not equipped to fully treat the wastewater that were "grandfathered" from the 2010 total dissolved solids regulations.
For the first six months of 2011, 1.977 million gallons of shale gas wastewater were reported to have been sent to "grandfathered" facilities while, for the second half of 2011, according to data reported by operators, that total was only 17,136 gallons, a 99-percent reduction.
Krancer went on to explain in the letter that DEP has implemented a revised general permit to provide regulatory clarity and encourage the use of treatments at zero-liquid-discharge facilities, which remove contaminants from the wastewater so it can be re-used again in drilling operations.
Krancer also described the numerous measures in place to ensure the safe handling, transportation, storage and disposal of fluids associated with natural gas development.
"I am aware of the NRDC's longstanding opposition to natural gas extraction by hydraulic fracturing," Krancer wrote. "I do hope that NRDC's constitutional adversity to natural gas as a fuel will not prevent open-minded discussion and fair fact finding."
A copy of the letter is available online.
