Hull was secured to provide permitting and technical assistance to clients in the shale oil and 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. The permitting of these facilities was handled under either the Pennsylvania Department of Environmental Protection (PADEP) Office of Oil and Gas Management using the Approval of Alternative Waste Management Practices application or the PADEP Bureau of Waste Management using the WMGR123 general permit application.
In support of this project, Hull 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. We also worked with clients, regulatory personnel, and subcontractors to educate all stakeholders on the treatment technology and permitting process. Hull developed numerous plans for spills, nuisances, sample collection and system operations at the facilities. We 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. Hull then 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.
All aspects of the treatment and permitting process had to be developed, tested, refined and revised by Hull before 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.
Dave Mustafaga, PG, CPG