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EPA and the Marcellus Shale. Alliance for the Chesapeake Bay Citizens Advisory Committee March 5, 2011. Unconventional oil & gas development is conducted in a manner that is protective of human health and the environment. Goal.
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EPA and the Marcellus Shale Alliance for the Chesapeake Bay Citizens Advisory Committee March 5, 2011
Unconventional oil & gas development is conducted in a manner that is protective of human health and the environment Goal
Shale Gas Development in the Mid-Atlantic StatesRegional Conditions Rapid increase in development activity in one of world’s largest gas plays Densely populated areas Hydrologic conditions Formation containing uranium Produced water rich in total dissolved solids
Shale Gas Development Challenges Water availability Ensuring adequate treatment of flowback & produced waters Constructing infrastructure without adversely impacting streams and rivers Maintaining in-stream flows to provide assimilative capacity for permitted discharges, drinking water Maintaining groundwater resources Ensuring protective well casing to isolate underground sources of drinking water and prevent gas migration Abandoned oil & gas production wells
Shale Gas Development Challenges • Notification for every release of reportable quantity • Effective response to emergencies • Management of air emissions in an Ozone Transport Region • Protective handling of Technically Enhanced Naturally Occurring Radioactive Materials • Frac water storage ponds (construction, solids management, closure) • Erosion & sediment control (stormwater discharges) • Treatment & disposal of Total Dissolved Solids (salts)
EPA Efforts Underway Supporting States & Interstates Research Pre-Siting and Development Operation of Injection Wells Management of Air Emissions Flowback and Produced Water Treatment & Disposal Enforcement Compliance Assistance Other
EPA Efforts Underway • National Hydraulic Fracturing Research Study (EPA Office of Research and Development) • Initial results in 2012; final report in 2014 • More information at: http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/index.cfm • Wetlands construction permits review & compliance investigations (Region 3) • Working with National Park Service on Environmental Impact Statement (Region 3)
EPA Efforts UnderwayManagement of Air Emissions • Review major air preconstruction permits for subject facilities • Rulemaking & policy development • Clean Air Act (NSPS & MACT) • Collect methane, carbon dioxide, and nitrous oxide data through Greenhouse Gas Reporting Program http://www.epa.gov/climatechange/emissions/subpart/w.html • Encourage emissions reductions through Natural Gas Star Program http://www.epa.gov/gasstar/
EPA Efforts UnderwayFlowback and Produced Water Treatment & Disposal • Pretreatment programs for publicly owned treatment works (POTWs) • Pretreatment training for POTW operators on acceptance of oil & gas wastes (Region 3) • Qs&As for NPDES permit writers issued by EPA Headquarters 3/16/11 and available at http://cfpub.epa.gov/npdes/hydrofracturing.cfm
EPA Efforts UnderwayFlowback and Produced Water Treatment & Disposal(Region 3) • Considering Effluent Limit Guideline for Shale Gas Extraction • Program Oversight • EPA requests for characterization of discharges & impacts • PADEP requests to operators for monitoring at public drinking water systems and WWTP discharge points • Determine if discharge permit modifications are needed
State/Interstate Efforts Underway • Updated oil & gas regulations for well construction in Pennsylvania • DRBC gas drilling regulations for water use, site construction & operation, and wastewater management • SRBC remote monitoring network
DRBC Gas Drilling Regulations • Comment period closed 4/15/11 • EPA comments • Ensure backstops for protection of groundwater • Ensure awareness of independent federal requirements and those for which EPA maintains primacy • Full disclosure of chemical data prior to operation • Consistent requirements regardless of “high volume” classification
EPA Efforts Underway • Underground Injection Control permits for waste disposal • Issued by authorized states with EPA oversight & technical assistance • Issued by EPA in “direct implementation” states • Inspection of disposal of shale gas development waste via wells • National Energy Extraction Initiative • Emergency and Accident Prevention and Response
Managing RisksCompliance Assistance • Underground Injection Control • Unpermitted injection of wastes • Injection of wastes not in compliance with permit • Reporting of releases • National Response Center 1-800-424-8802 • Clean Air Act general duty clause
Managing RisksCompliance Assistance • Unpermitted discharges (spills) to U.S. waters • Discharge permits for treatment of oil & gas wastewater • Pass-through or interference at POTWs • Construction • Road crossings, pipeline crossings, well pads, compressor stations • Stream diversions
Hydraulic Fracturing Flowback and Produced Water Destinations • Underground Injection • Recycling • Evaporation/crystallization – centralized • Evaporation/crystallization – on-site
Managing RisksProtecting Human Health • Gas migration • Emergency response • Air releases & other routes of exposure
Leadership in the Industry • What will become standard practices for the industry? • Waste minimization • Water conservation • Baseline groundwater testing • Baseline surface water quality monitoring • Community relations (noise, road impacts, etc.) • Monitoring ponds and other potential sources of discharges during storm events • Responsible site reclamation
Looking Forward & Gearing Up Providing UIC permitting assistance Increased communication with industry & cross-program communication Increased staffing to address new level of oil & gas activity, especially in Pennsylvania & West Virginia Looking forward to results of Hydraulic Fracturing Research Study Environmental sustainability