It does not include a ban on road spreading, like unconventional shale gas operators must comply with [25 PaCode Section 78a.70], nor does it set any environmental standards, guidelines, setbacks, public participation or notice requirements or pre-approvals before road spreading of the wastewater takes place despite the growing public outcry against this disposal method.
The draft regulation and Perry’s comments were shared at the December 16 meeting of the PA Grade Crude [Oil] Development Advisory Council which advises DCED and DEP on conventional oil and gas industry issues.
“We do intend for this document to be the regulation that we ultimately submit to the Environmental Quality Board for their consideration," said Perry. "This advisory committee does have a somewhat unique right to present a report to the Environmental Quality Board and it's our intention to allow for that opportunity, but recognizing that this document that we circulated is what's going to be submitted to begin the process of the public comment period, and any changes would be made through that public comment period.”
Perry said they do not have a specific date in mind for putting the proposed regulation in front of the Environmental Quality Board for action. It could be as early as April.
DEP is also in the process of drafting a companion package of regulation changes setting additional environmental performance standards for conventional oil and gas drilling surface and subsurface activities.
Objecting To Annual Waste Disposal Reporting
At the December 16 meeting, Arthur Stewart, Chair of the Council’s Regulatory Committee, specifically objected to new language in Section 78.121 of the draft regulation that required conventional operators to report annually on where waste and wastewater goes for disposal, treatment or recycling identifying "the specific facility or well site where the waste was managed."
“Do you mean to change the current practice, or are you simply trying to codify the existing practice?” said Stewart. “Because this would seem to suggest that we would have to tie waste reports to the specific facility, which as we said in our comments, wow, that would be an extreme change to our production, reuse and disposal reporting in a way that your forms wouldn't even accommodate.”
“Remember, we're taking water, in many instances, and using it, reusing it, recycling it, on hydrofracture or plugging jobs,” said Stewart. “You can't possibly mean that we should be saying, ‘This amount from this tank went there, and then this amount from that tank went there,’ because it's coming from many, many sources to be consolidated in the plugging or fracking job.”
DEP does not require “cradle to grave” documentation to track where waste is being generated to where it is disposed for conventional or unconventional (shale gas) drilling. This requirement is not being proposed in the draft regulation for conventional operators, although it has been suggested many times.
The existing conventional oil and gas waste reporting requirements calls only for an annual report of how much solid and liquid waste they produce by oil and gas well and generally where that waste goes for disposal, treatment or for road spreading.
Unconventional oil and gas operators have to report information monthly in more detail.
Both conventional and unconventional oil and gas drilling generate very similar solid and liquid wastes, but reporting is handled much differently with the conventional industry getting a huge break.
According to DEP data, conventional oil and gas well operators generated over 93.4 million gallons of wastewater in 2017-- which is no small amount.
As noted in a recent report by the Better Path Coalition, DEP’s Oil & Gas Waste reporting database contains a variety of significant reporting mistakes with the existing, simple requirements and they recommended the independent state Auditor General do an audit of the reports to help identify those issues, but he declined. [Read more here]
Report Illegal Road Spreading
DEP recently determined conventional oil and gas companies and liquid waste haulers are not complying with Residual Waste regulations in road spreading their production wastewater and advised them to stop spreading. [Read more here]
If road spreading of conventional oil and gas wastewater is happening on dirt and gravel roads there’s a very good chance it is being done illegally and should be reported to DEP immediately by calling 1-800-541-2050 or Click Here to submit a complaint. [Read more here.]
Health, Environmental Hazards of Road Spreading
Since August of last year, Penn State and others have added to a growing body of research results documenting the potential harms to public health and the environment from road spreading oil and gas drilling wastewater. [Read more science here. Read more science here.]
In addition, as PA Environment Digest reported last week, DEP officially lists 84 townships as “Waste Facilities” where conventional oil and gas wastewater has been disposed of by road spreading. [Read more here.]
Townships have been advised to do their due diligence on any company offering to spread drilling wastewater on their dirt and gravel roads to make sure they comply with DEP’s Residual Waste regulations. [Read more here]
Spreading Wastewater Tears Apart Dirt Roads
The Penn State Center for Dirt and Gravel Road Studies has advised townships for years that road spreading oil and gas wastewater is not only an “environmentally unsound practice,” it can cause water pollution and damage roads. [Read more here]
“Yea, it does suppress dust, but so would plain water for a while without all the potential side effects,” said Steve Bloser, Executive Director of the Center. [Read more here]
Eric Chase from the Center added, “Any liquid you put on the roads is going to suppress dust for a little while, right? But, the fact of the matter is the high sodium brines are just not very effective.” [Read more here]
The harm caused by the disposal of oil and gas wastewater on dirt and gravel roads has been documented by a number of experts and by first-hand observations in Pennsylvania. [Read more here]
Next Meeting Of Committee/Council
There will be a meeting of the PA Grade Crude [Oil] Development Advisory Council Regulatory Committee to be announced for February to work on comments to DEP’s draft regulation, and if needed another in March.
The Regulatory Committee meeting will be sunshined by DCED which provides staff support to the Council
The next formal meeting of the Council will be on April 21 in State College starting at 10:00 a.m.
For more information, visit the DCED PA Grade Crude [Oil] Development Advisory Council webpage. Questions should be directed to Adam Walters, adwalters@pa.gov or call 717-214-6548.
NewsClip:
-- The Allegheny Front - Reid Frazier: Despite Moratorium, 2 Million Gallons Of Conventional Oil & Gas Waste Spread On PA Roads Since 2018
Related Articles This Week:
-- Sign Better Path Coalition Petition: DEP - Keep ALL Oil & Gas Wastewater Off Our Roads!
-- Environmental Health Project: Feb. 22 Shale Gas & Public Health: Translating Science Into Policy Public Health Summit
Road Spreading Archive:
-- PA Environment Digest: All Road Spreading Conventional Oil & Gas Wastewater Articles
Related Articles:
-- DEP Lists 84 Townships As ‘Waste Facilities’ Where Conventional Oil & Gas Wastewater Has Been Disposed Of By Road Spreading; Municipalities Need To Do Their Due Diligence
[Posted: January 3, 2022] PA Environment Digest
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