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Will DEPís new Permitting Strategy protect PA waters and health?


The Delaware River is one of the waterways that could eventually receive discharges of treated industrial wastewater produced during natural gas extraction in the Upper Delaware River region. It is currently called upon to assimilate various discharges from multiple permitted sources such as sewage treatment plants, as well as non-point source contaminants like fertilizers, pesticides and sedimentation
By SANDY LONG
UPPER DELAWARE REGION — In response to the increased threat to Pennsylvania’s waterways from polluted wastewater generated during natural gas drilling, the Pennsylvania Department of Environmental Protection (DEP) has developed new discharge standards that will take effect by January 2011. Meanwhile, an interim “Permitting Strategy” is being implemented in a “rethinking of historic practices,” according to the DEP.
The news was announced by acting secretary John Hanger at a public meeting of the Marcellus Shale Wastewater Technology Partnership, comprised of DEP and gas industry professionals.
In its new “Permitting Strategy for High Total Dissolved Solids (TDS) Wastewater Discharges,” the DEP notes, “There are many pollutants of concern in the wastewater associated with hydraulic fracturing.” The industrial wastewater is high in total dissolved solids, as well as sulfates and chlorides.
TDS cause toxicity through increased salinity, which affects the health of aquatic organisms. The document notes that water quality analyses of Pennsylvania’s major watersheds show that many of the state’s rivers and streams have a very limited ability to assimilate additional TDS, sulfates and chlorides due to elevated levels from historic practices.

 
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An example from fall 2008 in the Monongahela River basin is cited, where water quality standards for TDS were exceeded at 17 potable water intakes from West Virginia to Pittsburgh, when the river reached seasonal lows and concentrations of TDS and sulfates increased to historic highs.
“High total dissolved solids in industrial wastewater have been a problem in the Monongahela River and are an impending problem on a statewide level,” noted Hangar. “We are establishing base standards for this water so dischargers move toward actually treating TDS in industrial wastewater rather than simply depending on dilution to protect water quality.”
Can treated wastewaters still be discharged into a drought-stricken stream?

 

According to DEP spokesman Tom Rathbun, during a drought emergency, the governor is granted emergency powers to regulate water use as necessary. When issuing National Pollutant Discharge Elimination System (NPDES) permits, the wastewater discharge is modeled using a statistically derived stream flow that simulates the lowest average seven-day flow over a 10-year period, or what could be thought of as a drought-like condition. All water quality parameters must then be met in-stream at this drought-like condition.
The new standards are intended to protect Pennsylvania’s waters, including drinking water, and thereby, human health. But will they be stringent enough?
What’s in it?
A closer look at the Permitting Strategy indicates the following:
• Although the DEP acknowledges that water with TDS and chloride levels greater than the standards may have the potential to cause health effects, it notes, “no reliable data exist currently that support this and no health-based standard will be proposed at this time.”
• The new strategy is aimed at prohibiting new sources of high-TDS wastewaters from the state’s waters and is expected to include “an allocation strategy to address situations in which multiple discharges cause or contribute to downstream water quality standards violations.”
• The interim strategy in place between April 1, 2009 and January 1, 2011 will be to “maximize the use of available assimilative capacity of receiving streams where that is feasible.”
• DEP proposes to develop revisions to current regulations to add effluent standards for TDS, sulfates, chlorides, Total Barium and Total Strontium—all pollutants in Marcellus wastewaters.
• Publicly owned treatment works that accept such wastewater would be required to have an EPA-approved pretreatment program.
• Other disposal pathways involving partial removal of TDS to enable reuse of the wastewater will be considered.

Traditional methods of treatment have involved processing at centralized waste treatment facilities and publicly-owned treatment works (POTW). However, the DEP notes that “nearly all of the existing and proposed facilities do not treat the main pollutants of concern—these are passed through the treatment system with little or no reduction in pollutant loading—as TDS and chlorides are not removed using current treatment methods.” The Environmental Protection Agency (EPA) recommends that POTWs not accept this type of wastewater due to the potential for “pass through.”
Another possibility mentioned in the document is the production of a “viable end product,” such as road salt, from the recovered solids. Rathbun explained that the process for treating wastewater would take several steps. “In the preliminary steps, metals and other contaminants from the frac water could be removed. This would involve treatment steps like pH adjustment, allowing the water to stand for a period of time to allow settling, adding polymers or other additives to enhance settling, aeration to remove volatile organics and ammonia, and other procedures.
“This sludge would then be disposed of at the appropriate residual waste facility depending on its chemical make-up. The cleaner water could then be evaporated, with a salt cake remaining that could be used for other purposes, both for ice removal on roads and other industrial processes. Before the salt remaining after water treatment could be used for anything, the operator would need to obtain a beneficial use permit from the Bureau of Waste Management. That permit will have conditions in it to ensure that the salt is safe to use for the proposed activity.”
DEP will develop a proposed rulemaking to amend the water quality regulations this summer with an opportunity for public comment. To view the new Permitting Srategy, visit www.depweb.state.pa.us, choose keyword: Wastewater, then select the ‘Marcellus Shale Wastewater Partnership’ link.

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