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BENEFICIAL USE PERMITTING | Oil & Gas Wastewater | Multiple Sites, Pennsylvania
Hull was secured to provide permitting and technical assistance to clients in the waste and shale gas industry to beneficially reuse oil and gas wastewater from wells producing from the Marcellus Shale.  The technology chosen to treat the oil and gas wastewater prior to beneficial reuse consisted of a zero-liquid discharge concentrator (LM-HT® Produced Water Concentrator) designed and developed by Heartland Technology Partners, LLC  (LM-HT® is a registered trademark owned by Heartland Technology Partners, LLC.)
The locations chosen to site the concentrators ranged from well pads to compressor stations to landfills.  Some facilities were designated to treat only the wastewater from the well pads, while other facilities were designated as commercial treatment facilities.  Therefore, the permitting of these facilities was handled under either:
  1. the Pennsylvania Department of Environmental Protection (PADEP) Office of Oil and Gas Management using the Approval of Alternative Waste Management Practices application; or
  2. the PADEP Bureau of Waste Management using the WMGR123 general permit application.
  • Participated in pre-application meetings with multiple regions of the PADEP and several departments within the PADEP to resolve technical issues and to develop a near-uniform approach to permitting across the state.
  • Worked with clients, regulatory personnel, and subcontractors to educate all stakeholders on the treatment technology and permitting process.
  • Developed numerous plans for spills, nuisances, sample collection and system operations at the facilities.
  • Developed an approach to address Naturally Occurring Radioactive Material (NORM) and Technically Enhanced NORM (TENORM) to ensured worker protection and detail the procedures that will be used by the facility operator detect, characterize and manage radioactive material in wastes entering the permitted facility.
  • Outlined the process, equipment and materials generated.
  • Obtained PADEP-approval of permits and requests that allowed our clients to treat wastewaters and discharge the resulting water vapor to the atmosphere in lieu of off-site transportation and disposal.  If requested, portions of the water vapor stream were recovered for beneficial reuse in hydraulic fracturing.
This treatment technology and permitting approach are relatively new to both industry and regulatory agencies.  Therefore, all aspects of the treatment and permitting process had to be developed, tested, refined and revised before a an acceptable solution was settled on.  In addition, regional differences in geology, wastewater constituents, and regulatory requirements necessitated an adaptable and versatile treatment and permitting strategy.
Treatment process energy requirements were met by reusing waste heat from a compressor station and using an enclosed flare from a natural gas well. In addition, all plans required for the permitting (radiation plans, spill prevention plans, etc.) were tailored to the LM-HT® Produced Water Concentrator treatment process to maximize implementability and minimize impacts to operational efficiency.