This is a presentation given by Steve Garvin at a Doddridge County Commissioners meeting. In it, he expressed concerns about the oil and gas industry in West Virginia and pushed for better identification systems of chemicals used by the gas and oil industry for the safety of the public and public officials.
Mr. William Goodwin, Superintendent
Clarksburg Sanitary Board
222 West Main Street
Clarksburg, WV 26301
Re: WV/NPDES Permit No. WV0023302 Accepting Oil and Gas Wastewater
Dear Mr. Goodwin:
This correspondence shall serve as the agency's formal response to your e-mail dated May 10, 2009 in which the Clarksburg Sanitary Board (CSB) requested information as to the requirements that would be imposed upon the CSB as a result of accepting oil and gas related wastewaters.
The USEPA and WVDEP discourages POTWs from accepting wastewater from oil and gas operations such as coal bed methane gas and marcellus shale wastewaters because these wastewaters essentially pass through sewage treatment plants and can cause inhibition and interference with treatment plant operations. The wastewaters from these types of operations contain high levels of chloride, dissolved solid, sulfate, and other pollutants. POTWs provide little to no treatment of these pollutants and could potentially lead to water quality issues in the receiving stream. The CSB discharges to the Monongahela River basin which nows into the State of Pennsylvania. Pennsylvania has recently experienced exceedances of water quality standards with respect to total dissolved solids and sulfate in the Monongahela River. Therefore, prior to accepting these types of vvastewaters, the CSB must evaluate and establish local limits accordingly. The agency strongly encourages the CSB to ensure that appropriate local limits be established to prevent inhibition, pass-through. and interference with all POTW operations. Prior to CSB issuing a permit for the acceptance of these wastewaters, the CSB must establish the appropriate local limits through a permit modification and adopt them into its sewer use ordinance. The following bullets list the agency's expectations and requirements that would be imposed, at a minimum, if the permittee decides to continue to pursue accepting oil and gas related wastewaters.
•The agency has determined that the following pollutants are pollutants of concern associated with oil and gas related wastewaters and may have a potential for inhibition, interference, and pass-through: total dissolved solids (TDS), sulfate, chloride, arsenic, titanium, cobalt, nickel, silver, zinc, vanadium, tin, cadmium, lead, chromium, hexavalent, chromium, copper, fluoranthene, cyanide, mercury, selenium, antimony, beryllium, barium, ammonia nitrogen, fluoride, nitrite nitrogen, nitrate nitrogen, oil and grease, total suspended solids, iron, aluminum, chloroform, benzene, phthalate esters, strontium, strontium-90, boron, lithium, gross alpha radiation, gross beta radiation, radium 226 + radium 228.
•The CSB must conduct a head-works analysis and establish a Maximum Allowable Headworks Loading (MAHL) for the pollutants listed above. If the actual loading of any of the pollutants is more than 20% of MAHL, a local limit must be developed for the pollutant and adopted.
•Wastewater shall not be introduced or connected into the combined sewer at a point where there are CSOs between the introduction/connection point and the head-works.
•No pollutants can be introduced into a POTW (including the collection system) that can create a fire or explosion hazard. Wastewaters with a closed cup flashpoint of less than 140 degrees Fahrenheit using test methods specified in 40 CFR 261.21 of the code of federal regulations are prohibited from being introduced into POTWs. Due to the nature of the organic pollutants present in this nondomestic wastewater, the permittee must conduct thorough testing on this nondomestic wastewater to determine if it is permissible. Additionally, this should also be imposed as a limit in any permit issued by the City for this type of wastewater.
•No pollutants can be introduced into a POTW (including the collection system) which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that may cause acute worker health and safety problems. Due to the nature of the organic pollutants present in this nondomestic wastewater, the permittee must evaluate the necessity of limitations to be protective of POTW workers. Information on this type of evaluation is available in an EPA guidance document entitled Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors (EPA Document No. 812-B-92-001 issued June 1992).
•The acceptance of this wastewater during wet weather events shall not lead to increased wet weather discharges from CSOs.
•The agency will impose monitoring at Outfall 001 for the pollutants listed above.
•Due to issues with TDS and sulfate in the Monongahela River in Pennsylvania, the agency will impose limits for TDS and sulfate without the benefit of a mixing zone on Outfall 001 in order to be protective of Pennsylvania's water quality criteria.
•The agency will also impose effluent limitations for chronic toxicity, chloride, and possibly other pollutants.
•Technologically Enhanced, Naturally Occurring Radioactive Materials (TENORM) are regulated by the Nuclear Regulatory Commission (NRC) and/or the West Virginia Department of Health and Human Resources (WVDHHR) per 60 CSR 23 of the West Virginia Legislative Rules. This regulation requires facilities accepting TENORM to be certified by either the WVDHHR or the NRC prior to acceptance. Further, TENORM includes requirements with respect to radioactive exposure levels that may need imposed as local limits and/or effluent limits to be protective of POTW workers and water quality standards. The permittee must coordinate with the NRC and/or WVDHHR to obtain any necessary approvals and provide its findings to the WVDEP.
If you have any comments or questions, feel free to contact Netar (Nate) Wadhwa of our
office at 304-926-0499 extension 1013.
Scott G. Mandirola
Next, Garvin presented a Wikipedia article on the 2014 Elk River chemical spill.
Following are letters of support: