American Oil and Gas Reporter - May 2016 - 95

Brine Disposal Next Regulatory Target
PITTSBURGH-Disposing of produced
water in Pennsylvania soon could become
significantly more complicated, Pennsylvania Independent Oil & Gas Association
members were warned at their April 7
spring meeting in Pittsburgh.
Burt Waite, senior geologist and program director for Moody & Associates
Inc. in Meadville, Pa., referred to managing
produced water as "the single greatest
environmental challenge to our industry."
"There have been some attacks on the
preferred method of disposal in Pennsylvania," he continued. "Another is coming
down the pike."
Regulations abound at the federal level
as well. Samantha McDonald, director
of government relations for the Independent Petroleum Association of America,
ran through a laundry list that ranged
from wildlife to emissions and discharges,
hazardous material transportation, and
worker safety.
Sometimes the only response is the
courthouse, and PIOGA General Counsel
and Vice President of Government Affairs
Kevin Moody reviewed a number of cases
the association was either involved in or
monitoring.
In other PIOGA spring meeting presentations:
* Martin J. Saunders, attorney at law

Expect the Pennsylvania Department of
Environmental Protection to begin requiring operators to remove chloride before
discharging produced water to receiving
streams, Burt Waite, a senior geologist
and program director for Moody & Associates, warns the Pennsylvania Independent Oil & Gas Association.

with Steptoe & Johnson PLLC in Canonsburg, Pa., advised companies on complying
with federal wage and hour laws.
* PIOGA's director of natural gas
market development, Joyce Turkaly, led
a panel discussion that ranged from using
natural gas to fuel fleet vehicles to promoting manufacturing and petrochemical
industries. Panelists were Robert H. Beatty
Jr., chief executive officer of "O" Ring
CNG Fuel Systems LP in Coolspring,
Pa.; Sandy Spencer, a business development specialist for Appellation Pre Fab
LLC in Montoursville, Pa.; and Tim Wetzel, principal in networking and consulting
firm BridgeWorks LLC in Beaver, Pa.
Brine Disposal
Historically, the preferred method of
handling produced water in Pennsylvania
has been treating it to remove sediment,
hydrocarbons and heavy metals, then discharging it into a receiving stream under
a National Pollutant Discharge Elimination
System permit, Waite observed.
In 2013, he recalled, as part of the triennial review the U.S. Environmental
Protection Agency requires of all state
water quality programs, the Pennsylvania
Department of Environmental Protection
proposed to establish a chloride limit for
all NPDES discharges in the state. "That
didn't quite gain traction, and DEP pulled
it," Waite remembered.
But DEP is scheduled for another triennial review this year, and he said chloride
was again under discussion. "In fact, I
think we can safely expect there is going
to be a chloride limit proposed," he stated.
Although no details have been published, Waite said in 2013, DEP proposed
a limit of 250 milligrams per liter. Another
possibility is the U.S. Fish & Wildlife
Services' suggested "aquatic protection"
limit of 78 mg/l. He compared those with
the average concentration of 40,00060,000 mg/l in typical Pennsylvania brine
and concluded, "We have a massive effort
to remove that salt."
At present, Waite said, it costs $6.30
a barrel to transport, treat and dispose of
water in the state. Adding salt removal
will raise that to about $10.50 a barrel,
he estimated. Calculating an average water-to-oil ratio of 3-to-1, "That equates
to $31.50 per barrel of oil produced," he
reasoned. "Those economics don't work."
Fortunately, there may be some alternatives, Waite went on. He said producers
were disposing of brine through underground injection in neighboring West Virginia as well as in Ohio, where more than
150 Class II wells were injecting through

PIOGA is engaged in litigation challenging the Pennsylvania Department of Environmental Protection's Chapter 78/78a
regulations, municipal ordinances, and
DEP's continued enforcement of Act 13
sections that were overturned by the
state Supreme Court, among others, association General Counsel and Vice
President of Government Affairs Kevin
Moody lists.

the entire Paleozoic section. A practicing
geologist for 45 years, Waite averred, "I
can tell you without fear of contradiction
that the geology between Ohio and Pennsylvania, or Pennsylvania and West Virginia, doesn't change at the state line."
Another established treatment option
is evaporation and crystallization at a
central treatment facility, suggested PIOGA Environmental co-Chairman Paul
Hart, director of Fluid Recovery Services
(FRS) in Creekside, Pa. FRS operated a
crystallizer at its Creekside centralized
treatment facility in the 1980s, and is upgrading the NPDES permits at three of
its central facilities to incorporate the
latest evaporation/crystallization treatment
technology, he said.
"Evaporation and crystallization are
well established treatment processes, and
hence, technology is not an issue; the
important thing is to make the economics
work for the majority of producers," Hart
attested. "Producers can help operators
such as FRS make the economics work
by committing to bring higher volumes
of water to the treatment facilities."
In The Courts
PIOGA's most recent legal involvement,
MAY 2016 95

American Oil and Gas Reporter - May 2016

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