New York State Regulatory/Permitting Process and Practical Considerations for Publicly Owned Treatment Works (POTWs) to Treat Flowback Water

Transcription

1 New York State Regulatory/Permitting Process and Practical Considerations for Publicly Owned Treatment Works (POTWs) to Treat Flowback Water Presented by: Elizabeth M. Davis Rodney L. Aldrich, P.E. Sterling Environmental Engineering, P.C. Cornell University Cooperative Extension New York Marcellus Shale Natural Gas Summit: Challenges and Opportunities November 30, 2009 Engineering, P.C. 1

2 Flowback Water/ Produced Water Fluid that returns to surface through the well bore after hydraulic fracturing procedure is completed and pressure is released. Some water continues to flow out of producing gas wells and is referred to as produced water. Engineering, P.C. 2

3 Data from Pennsylvania wells drilled in the Marcellus shale indicate flowback recoveries range from 9-35% of the total fracturing fluid injected into each well. The Draft SGEIS estimates million gallons of hydrofracturing fluid may be used for one well with multi-staged hydrofracturing, with a potential flowback fluid return of 216,000 to 2.7 million gallons per well. Engineering, P.C. 3

4 Typical Chemical Makeup of Flowback Water from Marcellus Shale Gas Wells (based on data from wells drilled in PA and WV) From Section of the Draft SDEIS: Metals (calcium, barium, strontium) Dissolved Solids (chlorides, sulfates, calcium) Suspended Solids Mineral scales (calcium carbonate and barium sulfate) Bacteria-acid producing and sulfate reducing Friction Reducers Iron solids (iron oxide and iron sulfide) Dispersed clay fines, colloids and silts Acid gases (carbon dioxide, hydrogen sulfide) Naturally Occurring Radioactive Materials (NORM)-Radium Engineering, P.C. 4

5 Flowback Water Composition can change during the hydrofracturing process. Limited data from Marcellus Shale flowback water sampled at different times indicate increasing concentration trends for: Total Dissolved Solids (TDS) Radioactivity level Iron (unless iron-controlling additives are used) Metals The following concentrations tend to decrease for: Sulfate Alkalinity Engineering, P.C. 5

6 Deep Disposal Wells Site specific review and permitting process required. Injection zone strata must be evaluated for ability to accept and retain injected fluid. Injection fluid/strata water quality must be fully characterized. Regulated by NYSDEC Division of Mineral Resources and USEPA (Underground Injection Control Permit) On-site treatment systems can reduce sodium chloride and TDS levels. These will be operated by gas development company. Engineering, P.C. 6

7 Draft Regulatory / Permitting Process for POTWs to Treat Flowback Water As required by 6 NYCRR Part 554.1, prior to issuance of a well-drilling permit, the operator must submit and receive approval from the NYSDEC for a plan for the ultimate disposal of flowback fluid. The applicant may be required to submit an acceptable contingency plan. Engineering, P.C. 7

8 Only POTWs in New York State that have an approved Pretreatment Program are eligible to treat flowback water Pretreatment programs are a component of the National Pollutant Discharge Elimination System (NPDES) permit. Pretreatment reduces, eliminates or alters toxic pollutants (metals & organics) in wastewater prior to introducing the pollutants into a POTW. NYSDEC Division of Water shares pretreatment oversight with the USEPA Engineering, P.C. 8

9 New York State Pollutant Discharge Elimination System (SPDES) Permit issued to POTWs specifies effluent discharge concentration limits to control point source discharges to surface water. POTWs with industrial pretreatment or minipretreatment programs must notify the NYSDEC of new discharges or substantial changes in volume or character of pollutant discharges to the permitted POTW. NYSDEC reviews notification package to determine if SPDES permit requires modification. Engineering, P.C. 9

10 Naturally Occurring Radioactive Material (NORM) contained in flowback fluid or produced water may be subject to discharge limitations. Regulations are found in 6 NYCRR Title 6, Chapter 4, Part 380 Licensed radioactive material may be disposed of by release into public sanitary sewer systems if the conditions specified in Section are met. Engineering, P.C. 10

11 Regulatory Process: POTW Notification to NYSDEC Division of Water includes POTW letter of intent to treat new discharges and/or substantial change in volume Headworks Analysis- NYSDEC TOGS HFC Evaluation Form for Each Hydrofracturing Chemical Chemical and Whole Effluent Toxicity (WET) Test Reports Engineering, P.C. 11

12 Headworks Analysis- TOGS CFR Part 403 Requires Every 5 Years Given: Effluent Limits on Chemicals Both Presently in Permit and Desired Treatment Operations at POTW Each Unit Operation has a Removal Efficiency for each Particular Chemical Determine Allowable Influent Concentration for each Chemical Engineering, P.C. 12

13 Regulatory Process: POTW Notification to NYSDEC Division of Water includes HFC Evaluation Form for Each Hydrofracturing Chemical Chemical Manufacturer or Supplier Completes #3 through #10, and #18 for Each Chemical on Form Flowback Water Chemical Analysis Results and Whole Effluent Toxicity (WET) Testing of Most Sensitive Species Gas Development Company Reports Results Flowback Loading Rates Gas Development Company and POTW Complete Balance of Form Submit Chemical and WET Test Results with Headworks Analysis Engineering, P.C. 13

14 NYSDEC Issuance of Modified SPDES Permit will include Effluent Limitations for: Review of the Application could take 6 months or more. Total Dissolved Solids Always will be < or = 500 mg/l Other Parameters Identified in Flowback Water Analysis Likely will include Radium due to Naturally Occurring Radioactive Material (NORM) Concerns Engineering, P.C. 14

15 Susquehanna Basin Commission Discharge Regulations 18 CFR requires the Commission to promote and encourage State and local governments and industry to plan for regional wastewater treatment and management Gas development companies have to report flow back water volume in gallons and transfer/disposal location, and submit manifest documents Engineering, P.C. 15

16 Delaware River Basin Commission Discharge Regulations Requires Written Notification of Disposal Locations Minimum Discharge Standards: Suspended Solids Toxic Substances but no specific limits (see Stream Limits) Oil and Grease to 15 mg/l Industrial Discharges to USEPA Categorical Standards Total Dissolved Solids (TDS) to 1,000 mg/l Engineering, P.C. 16

17 Delaware River Basin Commission Discharge Regulations Stream Standards (affect POTW SPDES Permit Limits): Dissolved Oxygen, Temp., ph, Phenols, Odor, Synthetic Detergents, Fecal Coliform, Toxics, and: TDS 133% of Background 500 mg/l Radioactivity Alpha emitters max 3 picocuries per liter (pc/l) Beta emitters max 1,000 pc/l Engineering, P.C. 17

18 Practical Considerations Assuming radioactive contaminants allow, management at a POTW Modifications to POTW Primary Treatment Secondary Treatment Tertiary Treatment Engineering, P.C. 18

19 Practical Considerations - Modifications to POTW Primary Treatment Equalization Tank Tankers Can Offload at Fast Rate Constant or Near Constant Flow to POTW Smoothes Flow Variations Downstream Buffers Variability in Chemical Constituents Could take 6 months to a year to undergo contract procedures and construct Engineering, P.C. 19

20 Practical Considerations - Modifications to POTW Secondary Treatment Bio Reactors Pretreat Benzene, Toluene, Xylene (BTX) and Other Petroleum Chemicals Potentially Vulnerable to Upset Flowback Water May Require Improved Monitoring and Control of Bio Reactors Sludge Excessive radium or other NORM could interfere with disposal, especially by land application or incineration Engineering, P.C. 20

21 Practical Considerations - Modifications to POTW Tertiary Treatment Reverse Osmosis (Membranes) Distillation Brine Landfilled Incinerated Most POTWs do not have and will not want to add Acceptance Rate must ensure TDS Limit is met Engineering, P.C. 21

22 Potential Funding Sources to Modify Treatment Systems New York State-Clean Water Act State Revolving Fund USDA Rural Development Fund New York State- Office of Community Renewal NYSERDA Appalachian Regional Commission Engineering, P.C. 22

23 Nominal Cost Estimates to Treat Flowback Water Off-site treatment is estimated to cost between $0.03 and $0.05 per gallon An estimated 50-60% total savings can be realized by treating and reusing flowback and produced water onsite (Reference: Venture Engineering Blog, September 2008) Engineering, P.C. 23

24 Elizabeth Davis Rodney L. Aldrich, P.E. 24 Wade Road Latham, New York (518) Engineering, P.C. 24

25 References Mr. Brian Baker, P.E., Environmental Engineer III, Western Section, Bureau of Water Permits, New York State Department of Environmental Conservation (NYSDEC) Mr. Tim Rice, Section Chief, Division of Solid & Hazardous Waste, Bureau of Hazardous Sites and Radiation Mitigation, Radiological Sites Section, NYSDEC Application Guidelines for Radiation Control Permits for Discharges of Radioactive Material in Effluents to Ground or Surface Water, May 2002, NYSDEC, Division of Solid and Hazardous Materials, Radiation Section Delaware River Basin Commission Administrative Manual Part III Water Quality Regulations with Amendments Through July 16, 2008 Division of Water Technical and Operational Guidance Series, New Discharges to Publicly Owned Treatment Works (Originator: Mr. DiMura) (1.3.8) Memorandum, October 26, 1994 Draft Supplemental Generic Environmental Impact Statement of the Oil, Gas, and Solution Mining Regulatory Program, September 2009, NYSDEC Bureau of Oil & Gas Regulation, NYSDEC Division of Mineral Resources Marcellus Shale Play-Water Treatment Options Worth Considering- Venture Engineering Blog Susquehanna River Basin Commission, Regulation of Projects, 18 CFR Parts 801, 806, 807, and 808, Reflecting final rulemaking actions through December 4, 2008, effective January 15, Susquehanna River Basin Commission, Post-Hydrofracture Stimulation Report And Certification of Fluid Disposal, Engineering, P.C. 25