DEP Circulates Concept Paper On Changes To Oil And Gas Drilling Regulations

DEP Circulates Concept Paper On Changes To Oil And Gas Drilling Regulations

On Wednesday the Department of Environmental Protection issued a concept paper to the agency’s Oil and Gas Technical Advisory Board on proposed changes to Pennsylvania’s Chapter 78 Oil and Gas Regulations required by the Marcellus Shale drilling law adopted in February as Act 13. The bulleted list of proposed changes cover application requirements, well location restrictions, proposed protection of water supplies, predrilling or prealteration survey requirements, erosion and sedimentation controls, wastewater control and disposal planning, standards for pit and tank containment and much more. DEP said proposed language to implement these changes should be available online on or about September 14. DEP has scheduled two additional Oil and Gas Board meetings to review these proposals on September 17 and October 15.  The proposals will also be shared with DEP’s Small Business Compliance Assistance Advisory Committee on October 24. DEP anticipates finalizing proposed language at the November 15 Oil and Gas Board meeting and then send it to the Environmental Quality Board on December 12 for their consideration. The Concept Paper Key Parts of Interest 1.Propose adding a requirement that a well operator identify on the well permit application the location of abandoned gas or oil wells within 1000 feet of the entire well bore length. 2. Propose adding regulations to this section to ensure compliance with the 2012 Oil and Gas Act 58 Pa.C.S.§ 3218(a). 3. Propose adding language to the requirement of notifying the Department within 24 hours of any water supply complaints a well operator receives, that it be by electronic means. 4.Propose to require the submission of chain-of-custody documentation with the results of the laboratory analysis.  5.Propose requiring the development of a site-specific PPC plan.  Also add the 2012 Oil and Gas Act requirement for unconventional wells to also have a site-specific containment plan noting which containment systems and equipment will be utilized to contain, control and prevent spills from leaving the well site. 6.Propose that the operator conduct continuous inspections of the drilling operations(including drilling pressures and fluid returns), all water bodies in close proximity, and the surrounding area for any signs an inadvertent return during horizontal drilling operations.  Documentation of such inspections shall be made available to the Department upon request. 7. § 78.70. Roadspreading of Brine for Dust Control and Road Stabilization Conventional Energy Related Systems The conventional energy related systems program targets individuals that are working in the field of oil, coal, natural gas, and petrochemical processing.  Courses timely topic that include natural gas development, carbon sequestering, and deep well injection. Advanced Oil and Gas Exploration Technologies Advanced Oil & Gas Drilling and Completion Technologies Building Envelope Air-tightness (New Course) Carbon Sequestration  (New - Featured Program) Electrostatic Treating of Emulsions  Fundamentals of Petroleum Refining Gas Pipeline Hydraulics Introduction to Underground Natural Gas Storage Land-Based Produced Water Re-injection Treatment  Natural Gas Plant Operations Program (New - Featured Program) Liquid Pipeline Hydraulics Process Vessel Design for FPS Motion  Underground Storage Tank Sump Maintenance  Natural Gas - Petroleum Engineer Training Program (New - Featured Program)

Occupational Safety and Health Administration Oil and Gas Industry

OSHA along with other Federal agencies schedule meeting to discuss performance-based approaches to protect oil and gas industry workers

WASHINGTON – The Occupational Safety and Health Administration (OSHA), along with the Bureau of Safety and Environmental Enforcement, United States Coast Guard, Environmental Protection Agency, and Pipeline and Hazardous Materials Safety Administration invite public participation in a September 20-21 meeting on the use and implementation of performance-based regulatory models for enhanced safety and environmental performance in the United States oil and gas industry.

Speakers at the September 20-21 meeting in Texas City, Texas will address the current regulatory landscape and discuss the challenges and benefits of non-prescriptive, outcome-based approaches to reduce the frequency and severity of harmful events.

Public attendees will have the opportunity to make comments at the meeting and all members of the public may submit comments in writing. Those interested in attending must register online by September 5. The meeting will also be Webcast live for online viewing. For more information, visit the registration website and read the Federal Register notice.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

We offer a series of health and safety training courses

Program 1: Occupational Safety and Health Act (OSHA)- OSHA Accepted Courses

New Program - OSHA Training Course for Well Drillers (0il and Gas Industry- 4 hour course)

Crystalline Silica - Silicosis- Safety Training Video
Mining Safety and Health Administration (MSHA) (Refresher)

A pdf file that contains a partial listing of the courses we offer - B.F. Environmental Training Program (Safety - OSHA).

Courses Powered by 360 Training

Low-cost, Low Maintenance Stormwater System Focus of NPS Demonstration Project

Upper Delaware News Release

Release Date:            Friday, August 31, 2012

Contact:                      Patrick Connolly, Chief of Maintenance

                                    E-mail:  Patrick_connolly@nps.gov             

Office Phone:  (570) 729-7137

Low-cost, Low Maintenance Stormwater System Focus of NPS Demonstration Project

Partners and Businesses Invited September 6, 2012, 1:00

Partners and local businesses are invited to observe installation of a stormwater filtration system at the NPS Headquarters Office, 274 River Road, Beach Lake PA, on Thursday, September 6^th at 1:00. The installer and park staff will talk with participants following completion of the project, anticipated to take approximately one and a half hours from start to finish. “Stormwater runoff can significantly threaten and impair the health and enjoyment of our nation’s water resources, natural habitats and scenic beauty, and we want to be a leader in finding affordable ways to reduce that impact”, said Superintendent Sean McGuinness.

Recognizing a need for inexpensive, relatively easily-installed and -maintained stormwater filtration systems in the Upper Delaware River Valley, National Park Service Superintendent Sean McGuinness seized the opportunity and personally investigated options for an engineered stormwater filtration media and delivery system for the NPS Headquarters office at 274 River Road, Beach Lake, Pennsylvania.

The system is designed to be installed into existing roadside drains (commonly called catch basins). Located just below the grate, they capture and filter the water as it leaves the surrounding surfaces, thereby reducing source pollution.

 “We were surprised at the elegant simplicity of the system”, said McGuinness.  This application can be included in projects with a minimum investment.  The cost of maintenance is also very low, involving occasional vacuuming and geotextile bag replacement. “Stormwater filtration systems also assist municipalities, agencies, storm water managers and contractors in meeting the Environmental Protection Agency’s National Pollutant Discharge Elimination System (NPDES) Phase II storm water regulations regarding runoff from new construction site activities”, according to the manufacturer.

For more information, contact Chief of Maintenance Pat Connolly at 570-729-7137.

Marcellus Shale Coalition Pre-Drilling Water Sampling

Pittsburgh, Pa. – Today, the Marcellus Shale Coalition (MSC) released a Recommended Practice (RP) for pre-drill water supply surveys. This is the third in a series of recommended practices, all aimed at reinforcing the MSC’s Guiding Principles to “continuously improve our practices and seek transparency in our operations” while furthering a fact-based dialogue that encourages responsible American natural gas development.

Pennsylvania regulations require natural gas producers to sample and test – with the owner’s consent – all water supplies within 2,500 feet of a proposed Marcellus Shale natural gas well. These pre-drill tests, which are conducted by certified laboratories, provide a baseline analysis of water chemistry prior to site preparation and development activities. Many natural gas producers test well beyond the 2,500 feet requirement, and were doing so prior to Pennsylvania enacting these new regulations.

According to the Center for Rural Pennsylvania, nearly 40 percent of Pennsylvania’s water wells do not meet at least one safe drinking water standard and another 20 percent of wells contain pre-existing methane.

“For years, well before shale gas production began in the Commonwealth, straightforward science has informed us that Pennsylvania’s groundwater chemistry drastically varies across regions,” said MSC president Kathryn Klaber. “This Recommended Practice builds upon what’s required by law and lays out in great detail steps operators can take to help ensure homeowners have a clear understanding of their water quality before natural gas-related activities begin. These tests, paid for by the natural gas producer, are shared with the well owners and state regulators, serving a critical public health function in many cases.”

Developed by technical experts from a host of MSC member companies, this RP recommends the following steps:

• A pre-drill survey should be conducted on all identified water supplies within a given area of the well pad surface location as required by the State Regulatory Agency (SRA).
   
• Water supply sources such as wells, springs and ponds should be evaluated prior to earth disturbance for site construction or prior to spud. Consideration should also be given to sampling water supply sources that are not currently in use.
   
• With the assistance of the water supply owner, locate the water supply(ies) and sampling location(s). Use GPS (preferably NAD83 datum) to determine and record the latitude and longitude of each water supply.
   
• The samples shall be collected, in accordance with all appropriate sample collection, preservation, handling, and defensible chain-of-custody procedures. Appropriate sample collection procedures can be found on the United States Environmental Protection Agency (USEPA) website (www.epa.gov).
   
• Water samples shall be analyzed by an SRA certified laboratory using USEPA SW-846 methods or drinking water methods (where drinking water methods exist). For parameters that have a Maximum Contaminant Level (MCL), the laboratory should be instructed to provide a laboratory reporting limit no greater than the published MCL.
   
• Operators should inform the water supply owners and/or residents that any and all information/data collected will be provided to the owner/occupant and to the SRA (if required by state regulations) and, as such, the information could be disclosed as public information upon inquiry to the SRA.

Continued Klaber: “Additionally, the MSC is developing a robust pre-drill water quality database. When complete, this first of a kind library will serve as an important environmental and public health tool to help address water quality challenges that have persisted in rural communities for decades.”

The parameters they recommended

Alkalinity 

Total Chromium

Oil & Grease 

Total Arsenic

pH 

Total Barium

Specific Conductance 

Total Lead

Total Dissolved Solids 

Total Selenium

Total Suspended Solids 

Total Strontium

Chloride 

Total Calcium

Sulfate 

Total Iron

Total Hardness 

Total Magnesium

Surfactants (MBAS/foaming agents) 

Total Manganese

Benzene, Toluene, Ethylbenzene, Xylenes (BTEX)

Total Potassium

Dissolved Methane* 

Total Sodium

Dissolved Ethane 

E. Coli

Dissolved Propane 

Total Coliform

Nitrate as N 

Turbidity**

Comments

1. I am glad that a more uniform list is being recommended.

2. I would like to see the full range of VOCs and MTBE.

3. I would like to see glycols added to the list or at least added when the conditions seem correct.

4. I think the Guidance should include more on purging and documenting the water quality during the purging process to make sure the purge was adequate, but it is a good start.

5. During purging, the pH, mv or ORP, Conductivity, and Temperature should be documented.  If possible, this is also a great time to measure turbidity.

6. I strongly recommend adding Total Aluminum to this testing.

7. I strongly recommend adding Bromide to this testing.

8. It would be nice if the guidance provided more information on detection limits, but I do like the fact that want the results reported in a uniform manner. 

9. Would like to see testing for nuisance bacteria or heterotrophic bacteria when the conditions seem appropriate - probably 50% of the time.

B.F. Environmental Consultants Inc. provides training in proper baseline sampling practices, review and use of baseline testing data, and educating professionals to work with private well owners, plus we provide training and educational programs for private well owners.

B.F. Environmental Consultants Inc also does post drilling assessments and reviews.

The actual guidance document can be found here.

Frustrated with Natural Gas Development Vandalism is NOT the Answer

"Possible vandalism investigated after chemical spill at gas well site

By Laura Legere (Staff Writer)

Published: August 21, 2012

Police probing chemical spill

State environmental regulators asked state police to help investigate a 100-gallon chemical spill at a natural gas well site in Susquehanna County on Monday after bullet casings and a bullet were found near a broken glass tube that caused the leak. 

The spill of glycol was discovered by a worker Monday about 11:30 a.m. at Cabot Oil and Gas Corp.'s Grosvenor well site in Dimock Twp., Department of Environmental Protection spokeswoman Colleen Connolly said.

The chemical was largely contained to the well pad but a heavy rain raised the risk of runoff, she said. Absorbent material and a vacuum truck were sent to the site to clean up the fluid.

The broken tube was connected to a 500-gallon tank of glycol, which is used as part of the dehydration process at the well site, she said.

The two Grosvenor wells were drilled in September 2010, according to state data. Ms. Connolly did not immediately know if there are active operations at the site." 

Source of the article - http://thetimes-tribune.com/news/possible-vandalism-investigated-after-chemical-spill-at-gas-well-site-1.1361238

Baseline Testing Results Wayne County Pennsylvania

 Memo

August 18, 2012

To: Wayne County, Manchester Township, PA 18436

From: Brian Oram, PG

B.F. Environmental Consultants Inc.

15 Hillcrest Drive

Dallas, PA 18612

Sample Information- Sample # 1 (Well)
Wayne County, Manchester Township

Site: 

Drilled Well- no data

Purge Time –12/16/2010 at 12:15 am

Estimated – 

Lab Number – XX-XXXX-20101216-PST - Test America / Tetra Tech

Parameter	Result	Standard	Comment
Ethylene Glycol	0.76 mg/L	< 0.3 to 14 mg/L R	Detection Limit Issue
Ethane	< 0.00049 mg/L	no standard	OK
Ethene	< 0.00052 mg/L	no standard	OK
Methane	< 0.00022 mg/L	< 7 mg/L	OK
Propane	< 0.010 mg/L	no standard	OK
Surfactants (MBAS)	< 0.013 mg/L	< 0.5 mg/L	OK
T. Kjeldahl Nitrogen	< 0.15 mg/L	no standard	OK
Radium 226	0.15 pCi/L	< 5 pCi/L	OK
Radium 228	0.06 pCi/L	< 5 pCi/L	OK
Gross Alpha	1.46 pCi/L	< 15 pCi/L	OK
Gross Beta	0.72 pCi/L	< 4 pCi/L	OK

Parameter	Result	Standard	Comment
Thorium	< 0.002 mg/L	see gross alpha	OK
Uranium	0.0011mg/L	< 0.030 mg/L	OK
Thallium	< 0.010 mg/L	< 0.002 mg/L	Detection Limit Issue
Silver	< 0.005 mg/L	< 0.05 to 0.10 mg/L	OK
Aluminum	< 0.200 mg/L	< 0.05 to < 0.2 mg/L	OK
Arsenic	< 0.010 mg/L	< 0.010 mg/L	OK
Barium	< 0.200 mg/L	< 2 mg/L	OK
Beryllium	< 0.004 mg/L	< 0.004 mg/L	OK
Boron	< 0.200 mg/L	< 0.6 mg/L R	OK
Calcium	28.4 mg/L	no standard	OK
Cadmium	< 0.005 mg/L	< 0.005 mg/L	OK
Cobalt	< 0.050 mg/L	< 0.011 mg/L R	OK
Chromium	< 0.005 mg/L	< 0.1 mg/L	OK
Copper	0.0713 mg/L	< 1 mg/L	OK
Potassium	0.660 mg/L	no standard	OK
Lithium	< 0.050 mg/L	< 0.7 mg/L R	OK
Magnesium	3.99 mg/L	no standard	OK
Manganese	0.0012 mg/L	< 0.05 mg/L	OK
Mercury	< 0.0002 mg/L	< 0.002 mg/L	OK
Molybdenum	< 0.040 mg/L	< 0.040 mg/L R	OK
Sodium	4.56 mg/L	no standard	OK
Nickel	< 0.040 mg/L	< 0.1 mg/L	OK
Lead	< 0.003 mg/L	< 0.005 mg/L	OK
Selenium	< 0.005 mg/L	< 0.05 mg/L	OK
Strontium	0.319 mg/L	< 4 mg/L R	OK
Zinc	0.0047 mg/L	< 5 mg/L	OK
Iron, T	< 0.100 mg/L	< 0.3 mg/L	OK
Iron, D	< 0.100 mg/L	< 0.3 mg/L	OK

Parameter	Result	Standard	Comment
pH	7.4	6.5 - 8.5	OK
Acidity	< 5 mg/L	no standard	OK
Ammonia Nitrogen	0.17 mg/L	no standard	OK
Bromide	< 0.20 mg/L	no standard	OK
Chloride	6 mg/L	< 250 mg/L	OK
Hardness, T	84 mg CaCO3/L	no standard	OK
Nitrate-Nitrite	0.17 mg/L	< 10 mg/L	OK
Oil and Grease	< 4.8 mg/L	no standard	OK
Conductance	230 uS/cm	no standard	OK
Sulfate	6.7 mg/L	< 250 mg/L	OK
T. Alkalinity	80.3 mg/L	no standard	OK
T. Dissolved Solids	111	< 500 mg/L	OK
Ratio TDS/ Conductivity	0.48	*****	OK
Total Rec. Phenolics	< 0.010 mg/L	no standard	OK
T. Suspended Solids	< 4 mg/L	no standard	OK

Parameter	Result	Standard	Comment
Benzene	< 0.005 mg/L	< 0.005 mg/L	OK
Ethylbenzene	< 0.005 mg/L	< 0.700 mg/L	OK
Toluene	< 0.005 mg/L	< 1.0 mg/L	OK
T. Xylenes	< 0.015 mg/L	< 10 mg/L	OK
alpha-BHC	< 0.000048 mg/L	no standard	OK
beta-BHC	< 0.000048 mg/L	no standard	OK
delta-BHC	< 0.000048 mg/L	no standard	OK
Lindane	< 0.000048 mg/L	< 0.0002 mg/L	OK
Heptachlor	< 0.000048 mg/L	< 0.0004 mg/L	OK
Aldrin	< 0.000048 mg/L	no standard	OK
Heptachlor epoxide	< 0.000048 mg/L	< 0.0002 mg/L	OK
Endosulfan I	< 0.000048 mg/L	no standard	OK
Dieldrin	< 0.000048 mg/L	no standard	OK
4, 4' DDE	< 0.000048 mg/L	no standard	OK
Endrin	< 0.000048 mg/L	< 0.002 mg/L	OK
Endrin Ketone	< 0.000048 mg/L	no standard	OK
Endrin Aldephyde	< 0.000048 mg/L	no standard	OK
Endosulfan II	< 0.000048 mg/L	no standard	OK
4,4'-DDD	< 0.000048 mg/L	no standard	OK
Endosulfan sulfate	< 0.000048 mg/L	no standard	OK
4,4'-DDT	< 0.000048 mg/L	no standard	OK
Methoxychlor	< 0.000048 mg/L	< 0.040 mg/L	OK
alpha Chlordane	< 0.000095 mg/L	no standard	OK
gamma Chlordane	< 0.000048 mg/L	no standard	OK
Toxaphene	< 0.0038 mg/L	< 0.003 mg/L	OK
2,4-D	< 0.0038 mg/L	< 0.070 mg/L	OK
Dalapon	< 0.0048mg/L	< 0.2 mg/L	OK
2,4-DB	< 0.0038 mg/L	no standard	OK
Dicamba	< 0.0019 mg/L	no standard	OK
Dichlorprop	< 0.0038 mg/L	no standard	OK
Dinoseb	< 0.00086 mg/L	< 0.007 mg/L	OK
MCPA	< 0.380 mg/L	no standard	OK
MCPP	< 0.380 mg/L	no standard	OK
Pentachlorophenol	< 0.00048 mg/L	< 0.001 mg/L	OK
Silvex	< 0.00095 mg/L	< 0.050 mg/L	OK
2,4,5-T	< 0.00095 mg/L	no standard	OK

The following are my general comments:

1. Based on the available data, I do not see any specific problems or concerns.

2. It would have been advisable to test for more of the regulated and unregulated volatile organics and MTBE.  They only tested for BTEX (Bold).

3. It would have been good if the arsenic was tested to a lower detection limit.

4. The letter R- means it was a recommended standard – not regulated.

5. Ethylene glycol – the method did not have a detection limit that is below the lowest standard for a state in the United States.  There is no Federal Drinking Water Standard. The same comment applies to Cobalt.

6. Thallium – the detection limit was not below the limit for the Safe Drinking Water Act.

Recommend retesting.

Thanks for supporting the Citizens Groundwater Database - Submit your data today - get a free evaluation and help your community.

I would like to personally thank Sylcosan Inc. Manchester Wayne County PA and a proud member of the NWPOA for releasing data to the Citizens Database.

Thanks for Helping to Track Change in Pennsylvania

Mr. Brian Oram, PG
Water-Research Center – Free Information on Water Quality

http://www.water-research.net

Questions – 570-335-1947

Please Participate in Our Private Well Survey at:

http://www.surveymonkey.com/s/NMG6RQ3

If you would like a free booklet on Private Well Water Quality, go to:

http://www.bfenvironmental.com/pdfs/Waterbooklet070610.pdf

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