December 2011, Vol. 23, No.12

Worth the headache?

News art Many POTWs interested in treating natural-gas drilling wastewater are stuck in limbo because of evolving regulations and the tangled politics of hydraulic fracturing 

In August, the U.S. Geological Survey (USGS) estimated that there was about 2.4 trillion m3 (84 trillion ft3) of undiscovered, technically recoverable natural gas in the Marcellus Shale — a low-density, organic-rich sedimentary rock formation that extends throughout much of Ohio, West Virginia, Pennsylvania, New York state, and small areas of Maryland, Kentucky, Tennessee, Virginia, and New Jersey.

Not only has USGS had to increase its 2002 estimate of undiscovered, technically recoverable natural gas in the Marcellus Shale by 2.3 trillion m3 (82 trillion ft3), but there also is a lot more money to be made in the Marcellus Shale — and not just by natural-gas drillers. Industrial and municipal wastewater treatment plants (WWTPs) have seen the opportunity to generate additional revenue by treating the flowback “frac water,” which is a mix of water and friction-reducing chemical additives used by drillers for hydraulic fracturing.

One of these WWTPs is the Niagara Falls (N.Y.) Wastewater Treatment Plant. In September, the Niagara Falls Water Board announced it was interested in accepting flowback from natural-gas drilling sites.

Paul Drof, executive director of the water board, said the facility already had conducted bench-scale tests to determine if it could treat the wastewater. The facility originally was designed to treat wastewater from industries around the Buffalo, N.Y., area, but many of those industries have left the region over the years.

“We are sitting with a 48-mgd [182,000-m3/d] plant, and we aren’t operating close to capacity,” Drof said. “We have an unused public benefit here.”

Drof said the water board also is looking into whether it could sell this treated frac water back to the drillers. “We know that they’re always looking for sources of water for hydrofracturing,” he said.

But all these ambitions have been put on hold until the plant knows for sure what the pretreatment requirements will be, said Rick Roll, director of technical and regulatory services at the water board. U.S. Environmental Protection Agency (EPA) Region 2 and the New York State Department of Environmental Conservation (DEC) still haven’t established those goals, he said.

EPA is working on effluent guidelines for onshore oil and gas extraction, but they are not expected to be available until next year, said Catherine C. Milbourn, senior press officer at EPA. States also are grappling with hydraulic fracturing and frac water treatment and disposal regulations, seemingly proposing new regulations every year or drilling moratoriums. This lack of guidance has left some utilities wondering if they want to enter the hydraulic fracturing fracas at all.

 

Considering recommendations

Pennsylvania has become one of the big hydraulic fracturing battlegrounds where environmental advocates argue that the practice should end entirely. The Pennsylvania Department of Environmental Protection (DEP) has proposed more-stringent regulations regarding drilling, storage, and frac water treatment, and the oil and gas industry has spoken out against these more-stringent regulations.

This year, Pennsylvania Gov. Tom Corbett convened the Marcellus Shale Advisory Commission, which issued 96 policy recommendations in July. These included tougher regulations for drilling, such as tripling well-setback distance from waterbodies from 30 m (100 ft) to 90 m (300 ft), doubling fines for civil violations from $25,000 to $50,000, creating jobs related to the drilling industry, and promoting the use of natural-gas-fueled vehicles.

“The recommendations were made to the governor, and the implementation of them will happen based upon his discretion and, in certain instances, the legislature,” said Kevin Sunday, a DEP press aide.

In early 2010, DEP proposed setting a new discharge standard for some WWTPs that accept industrial wastewater from drilling sites to 500 mg/L for total dissolved solids, 250 mg/L for chlorides, and 10 mg/L for barium and strontium. These standards applied to WWTPs that expanded or increased their existing daily discharge load, accepted wastewater from drilling sites, and discharged to state surface waters directly or indirectly, said Dana Aunkst, director of the Bureau of Water Standards and Facility Regulation at DEP, in September 2010.

By December 2010, DEP had amended its Chapter 102 regulations, which govern the discharge of total dissolved solids and other contaminants in wastewater to include these new standards, Sunday said. But “some facilities [that] were permitted prior to these amended regulations were not required to treat to the new standard,” he said, as long as those plants did not increase their input load of wastewater. “As such, in April, DEP Secretary Michael Krancer called on oil and gas operators to stop sending wastewater to these facilities,” he said.

Sunday said the natural-gas industry agreed to stop sending wastewater to the 15 remaining WWTPs. “This administration got compliance within 28 hours, not 28 months,” he said. “A drastic sea change occurred, and our waterways are now better protected.”

 

Monitoring the situation 

New York also has been wrestling with how it might adequately regulate hydraulic fracturing. Former Gov. David Paterson issued a temporary executive order in 2008 that banned high-volume hydraulic fracturing (HVHF) in the state, though not the practice of natural-gas drilling entirely. The current governor, Andrew Cuomo, did not extend Paterson’s temporary order, but he did mandate that DEC issue no new permits on HVHF until a review of the environmental impacts of the HVHF process is completed.

“Hydraulic fracturing has been done in New York for over 50 years and continues today, but only for conventional vertical wells,” explained John A. Conrad, principal and senior hydrogeologist at Conrad Geoscience Corp. (Poughkeepsie, N.Y.) and member of the Independent Oil and Gas Association of New York (IOGA; Hamburg). “When horizontally drilled wells are hydraulically fractured, significantly more water is needed for the process. Gov. Paterson’s intent was to temporarily disallow deep horizontal gas wells that would undergo HVHF in order to provide the [DEC] an opportunity to study the potential impacts and risks associated with HVHF, and to prepare supplemental guidance and requirements that would minimize associated impacts and environmental risks.”

Conrad said oil and natural-gas drilling continues in New York “as long as the amount of water used in the process is less than 300,000 gal [1.1 million L]. If more than 300,000 gal are used, it is considered to be HVHF and must wait for the completion of the supplemental guidance review.”

In September, DEC began its 90-day public comment period on its revised draft of the Supplemental Generic Environmental Impact Statement (SGEIS), which proposes guidelines for horizontal drilling and HVHF, and in early October, DEC released its proposed regulations governing HVHF.

Conrad said that most of the oil and gas companies still are reviewing SGEIS, but the industry hopes that the guidelines aren’t too extreme.

“While the IOGA and its members expect and want a coherent set of guidelines, it is imperative that the final guidelines and association regulations be based on sound scientific and engineering principles,” Conrad argued. “Prohibitions, restrictions, or requirements that impair oil and gas extraction but offer no actual environmental or health protection, for example, would be considered problematic by IOGA.”

 

From state ban to 1-year moratorium 

While some states have imposed hydraulic fracturing moratoriums, others have passed legislation to ban natural-gas drilling entirely. In March, the New Jersey Legislature passed SB 2576, a bill that would have permanently banned hydraulic fracturing for natural gas in New Jersey.

New Jersey Sen. Robert Gordon sponsored the bill because environmental groups had encouraged him to do so and because he is on the New Jersey Senate’s Environment and Energy Committee, said Matt Marinello, Gordon’s deputy chief of staff.

Hydraulic fracking is “a priority issue for him,” Marinello said.

“The environmental dangers of this procedure and the risks they would pose to New Jersey residents are abundantly clear,” Gordon said in a March 10 press release. “In fact, I believe it poses the greatest risk we have seen to our drinking water in our lifetime. This is something we simply cannot allow to come to our state.”

Although hydraulic fracturing has not taken place in New Jersey, the Marcellus Shale reaches the northwestern tip of the state. “The bill is a precautionary measure,” Marinello explained. “You never know what will happen in the future.”

But in August, Gov. Chris Christie vetoed the bill and issued a 1-year moratorium on hydraulic fracturing in New Jersey instead. In an Aug. 24 press release, the governor’s office noted that “no known natural gas deposits necessitating use of the fracking process have been proposed for development in New Jersey” and that “significant facts and studies on the issue are still outstanding with the federal U.S. Environmental Protection Agency and Department of Energy.”

“I am placing a 1-year moratorium on fracking so that the [New Jersey Department of Environmental Protection] can further evaluate the potential environmental impacts of this practice in New Jersey as well as evaluate the findings of still outstanding and ongoing federal studies,” Christie said in the press release.

Marinello said Gordon was “not particularly pleased” with the governor’s bill veto and the 1-year moratorium alternative.

“He thought the moratorium should be longer, maybe 3 to 5 years,” Marinello said. “A longer moratorium would have allowed more time to study the issue and consider both sides.”

Marinello said at press time that Gordon’s office was considering what to do next in light of the governor’s veto. “Our options include a veto override,” he said.

A dream deferred 

With the federal government still trying to determine how to properly regulate natural-gas drilling and frac water disposal, and states still grappling over the same issues, many wastewater utilities’ interest in treating this flowback water is beginning to waiver.

In summer 2010, Scott Dunn, superintendent of the Bethel Park (Pa.) Wastewater Treatment Plant, said his 190,000-m3/d (50-mgd) facility was eager to accept drilling wastewater. “We could stand to make a lot of money if we do,” he said.

Dunn said the facility was best positioned to receive the frac water because its large equalization tank would enable it to slowly bring the additional wastewater into the facility. Subsequently, the new load — what he estimated to be an additional 114 to 230 m3/d (30,000 to 60,000 gal/d) — would have little impact on the facility, he said.

At the time, Dunn perceived the only major obstacle to accepting frac water at the plant to be the additional cost incurred for installing and maintaining the treatment technologies necessary to treat the industrial wastewater, such as a membrane bioreactor or reverse osmosis.

Now, more than a year later, Dunn said the facility is no longer interested. The financial realities of such a move proved too overwhelming.

“We can’t do it,” Dunn said in a recent interview. “We can take leachate from landfills [that] is high in dissolved solids,” but the new technologies required to treat the frac water, “we just can’t afford right now,” he said.

It would require the utility to raise rates, and “our citizens just couldn’t take it at this point,” Dunn said. He said the utility’s customers already are experiencing rate increases because of the consent decree among the Allegheny County Sanitary Authority (ALCOSAN), EPA, Pennsylvania DEP, and the Allegheny County Health Department for ALCOSAN to achieve compliance with the Clean Water Act during wet weather periods.

Dunn said that there simply is not enough money to be made by accepting frac water, and he wonders whether continual pressure from environmental groups will lead to the shutdown of natural-gas drilling in Western Pennsylvania anyway.

In 2009, managers at the Binghamton–Johnson City Joint Sewage Treatment Plant (Vestal, N.Y.), had plans similar to the ones in Bethel Park. The managers wanted to conduct a feasibility study to determine whether they could treat flowback water from drilling sites and sell back recycled wastewater to drillers for hydraulic fracturing. The facility had a maximum flow of 130,000 m3/d (35 mgd) but was only operating at 83,000 m3/d (22 mgd). At the time, Catherine Aingworth, superintendent of environmental protection and control, said the facility wanted to take advantage of the extra capacity. Managers even had traveled to Dallas — a hub of natural-gas drilling — to discover what issues may arise at WWTPs that receive frac water from these operations, Aingworth said.

But by October 2011, plans to accept drilling wastewater had to be put on hold.

“We weren’t able to go forward with the feasibility study,” Aingworth said.

Plant managers recently upgraded their plan to reduce total nitrogen “and we had problems meeting the new permit requirements,” Aingworth said. They subsequently decided to focus on that rather than facing another challenge of treating frac water.

The idea to accept flowback from drilling sites has been tabled, “but we haven’t given up on it completely,” Aingworth said.

— LaShell Stratton-Childers, WE&T 


More news


 

Nutrient trading: A solution in search of a mandate? 

Despite lagging somewhat in the absence of strong regulatory drivers, nutrient trading is expected to increase as more-stringent requirements come to fruition

Under the right conditions, water quality trading has shown its effectiveness in reducing pollutant loads to impaired waterbodies. However, in the absence of regulatory “drivers” to compel participation by point sources, trading programs may languish, if they begin at all. Nutrient trading offers a clear case in point. In some jurisdictions with nutrient requirements, trading has helped, or is beginning to help, facilitate cost-effective compliance. Meanwhile, trading programs in jurisdictions lacking nutrient requirements have had a harder time getting started.

Drivers are key 

Nutrients make good candidates for trading programs for two reasons, said Bob Rose, policy analyst in the Office of Water at the U.S. Environmental Protection Agency (EPA). They are not subject to the Clean Water Act’s technology-based effluent limits, he said, and their environmental effects tend to occur far downstream as a result of the collective loadings of numerous sources. When states impose nutrient criteria or are moving in that direction, “they almost always look to water quality trading” as an option for facilitating compliance, Rose said.

However, states have been slow to impose numeric nutrient criteria or other nutrient-related requirements that would prompt trading. Yet states generally agree that they need to continue working with EPA toward enacting numeric nutrient criteria, said Brent Fewell, vice president for environmental compliance at United Water (Harrington Park, N.J.) and former principal deputy assistant administrator in EPA’s Office of Water. Once in place, such criteria “will help promote water quality trading,” Fewell said.

 

Connecticut’s clear-cut driver 

Perhaps the nation’s most successful nutrient trading program, Connecticut’s Nitrogen Credit Exchange has helped 79 of the state’s wastewater treatment plants (WWTPs) comply with discharge requirements for nitrogen that were imposed as part of a total maximum daily load (TMDL) to reduce hypoxia in Long Island Sound. Overseen by the Connecticut Department of Energy and Environmental Protection (DEEP), the exchange enables WWTPs that reduce their nitrogen loadings below a certain level to sell the difference as credits. Meanwhile, other plants may purchase credits to ensure compliance.

The exchange has successfully reduced nitrogen loadings to the sound, said Dennis Greci, supervising sanitary engineer at DEEP. In 2010, aggregate treatment plant performance amounted to 4456 equalized kg/d (9823 equalized lb/d) of nitrogen, well within the required limit of 4733 equalized kg/d (10,434 equalized lb/d).

For the Stamford (Conn.) Water Pollution Control Authority (WPCA), the program has been a success. For the past 3 years, the authority has generated approximately $1 million annually by selling credits, said Jeanette Brown, former executive director of WPCA and past president of the Water Environment Federation (Alexandria, Va.).

 

Trading without drivers 

In Ohio, the absence of numeric nutrient criteria has inhibited efforts by the Miami Conservancy District (MCD; Dayton, Ohio) to develop its nutrient trading program beyond the pilot phase, said Dusty Hall, MCD’s program development manager. Begun in 2006, the Great Miami River Watershed Water Quality Trading Program uses funding provided by participating WWTPs to pay farmers to implement agricultural best management practices. To date, the program has funded approximately 400 projects, reducing nutrient loadings by more than 454,000 kg (1 million lb).

Despite its success, the pilot program is being put on hold. Since starting the program, MCD has expected that the Ohio Environmental Protection Agency would implement numeric nutrient criteria. “We were looking for those nutrient criteria 5 years ago,” Hall said. Without the criteria in place, WWTPs have less incentive to purchase credits.

 

Future trading hotbed? 

In 2010, EPA finalized a TMDL that calls for significant reductions of nutrients and sediment throughout the Chesapeake Bay watershed, which includes the District of Columbia and portions of Delaware, Maryland, New York, Pennsylvania, Virginia, and West Virginia. The TMDL likely will make the bay region a “hotbed” of trading in the future, said Cy Jones, senior associate and head of the water quality team at the World Resources Institute (Washington, D.C.).

In planning for the TMDL, the states and D.C. have opted to allocate all of their allotted nutrient loadings to existing sources only, Jones said. Therefore, entities seeking to build new WWTPs will have to design such facilities to meet the limits of technology regarding nutrient removal and acquire credits to offset all nutrients discharged by their facilities. Therefore, “continued growth and economic development in the bay states are dependent on a viable offsets program, which means a viable nutrient trading program,” Jones said. “That kind of driver hasn’t existed anywhere else in the country yet.”

 

Virginia, Pennsylvania look to expand trading 

Virginia began its nutrient trading program in 2007. To meet their initial wasteload allocations, point sources in the state’s five major basins that drain to the bay were allowed to trade only among themselves but not with nonpoint sources. A consortium of more than 100 point sources formed an exchange to oversee and facilitate trading among its members. “It’s been quite an active program,” said Allan Brockenbrough, nutrient trading coordinator for the Virginia Department of Environmental Quality (DEQ). For 2011, 52 of the exchange’s members signed advance trade agreements pertaining to nitrogen, while 45 signed such agreements for phosphorus.

Virginia’s agricultural community is expected to help offset nutrients in stormwater runoff from new development. DEQ requires that new development reduce phosphorus loadings to certain rates. However, compliance may prove difficult and expensive. Rather than having to implement onsite controls, developers are interested in purchasing offsets from farmers who reduce their nutrient loadings. “It’s looking like it’s going to be a robust market,” Brockenbrough said.

Since 2005, the Pennsylvania Department of Environmental Protection (DEP) has allowed nutrient trading among point sources, nonpoint sources, and third parties located in the watersheds of the Potomac and Susquehanna rivers. To date, the department has approved 95 proposed trading projects submitted by 23 entities, including WWTPs, individual farmers, and nutrient aggregators, said Ann Roda, DEP program analyst. At press time in mid-October, parties had entered into 10 contracts lasting from 3 to 20 years.

 

Ambitious plan 

Stretching across portions of eight states, the Ohio River Basin is home to numerous WWTPs, thousands of farmers, and many coal-fired power plants, a potentially ideal combination for nutrient trading. To test trading’s prospects in this region, the Electric Power Research Institute (EPRI; Palo Alto, Calif.) is collaborating with the Ohio River Valley Water Sanitation Commission (ORSANCO; Cincinnati) and others to develop a first-of-its-kind interstate nutrient trading program known as the Ohio River Basin Trading Project. When fully implemented, the program likely will be the “largest of its kind in the country,” said Alan Vicory, ORSANCO’s executive director and chief engineer.

A driving force behind the program’s development is the need for power plants to find affordable approaches for complying with increasingly stringent wastewater discharge requirements. Anticipating future implementation of numeric nutrient criteria, some power providers are looking for more cost-effective methods for ensuring compliance, said Jessica Fox, senior project manager at EPRI.

Project participants aim to conduct pilot trades in the next couple of years. The current focus is on implementing agricultural best management practices in the spring, Fox said, followed by another round of conservation practices in 2013. The exact timeframe for marketing credits to power plants and WWTPs remains undecided.

— Jay Landers, WE&T 


 

Preparing for the storm  

In New Jersey, a water treatment plant’s flood walls are put to the test during Hurricane Irene

When Hurricane Floyd struck in 1999, it left upheaval in its wake. The Raritan Millstone Water Treatment Plant in Bridgewater, N.J., which serves 212,000 customers, was not immune. The plant, which is positioned below the floodplain between the Raritan and Millstone rivers, had to be shut down for 6 days after the hurricane because of flooding, said Bob Schaefer, director of production at New Jersey American Water (Voorhees), which owns the plant. Water had to be rerouted to a neighboring plant for treatment.

“Floyd was considered a 500-year storm that had about a 0.2% chance of occurring every year,” Schaefer said. “Prior to this flood, we had only 100-year storm-level protection.”

But when Hurricane Irene struck nearly 12 years later in August, the Raritan Millstone Plant was better prepared, Schaefer said. It had created additional flood preparation mechanisms and a flood response plan. This time around, there was no damage, and the plant stayed operational during and after the storm.

 

A stainless steel shield 

In addition to being protected by a series of berms, the 227,000-m2 (56-ac) Raritan Millstone Plant is surrounded by flood walls that were erected in 2001 because of the damage the plant suffered as a result of Hurricane Floyd.

“The flood walls give us an elevation of 45 ft [14 m], which is enough to bear a 500-year flood,” Schaefer said.

“We have two floodgates installed,” said Oleg Kostin, production manager at the plant. “The gate and frame system is made from stainless steel. The primary gate is located at the main entrance to the plant,” Kostin said. “The secondary gate is located in the back of the plant near filters 29 and 30 and allows secondary egress in case we are prevented from using the main gate.”

Both gates are equipped with a pneumatic seal, Kostin explained. “The pneumatic seal is a rubber bladder that must be inflated in order to make the door and frame system waterproof,” he said. “If the bladder were not inflated, water would seep through the gaps between the frame and the door, rendering them useless. These bladders have a [limited] life expectancy due to the threat of dry rot and must be changed out on a regular basis, typically every 5 to 7 years.”

Schaefer said the flood walls have been used four times.

“These gates are not fully deployed until there is a risk of a flood event, which is typically when the river reaches elevation 39; in the meantime, they act as a security gate,” Kostin said.

During the times that the gates were deployed, water has almost reached the top of the wall twice — in April 2007 and during Hurricane Irene, when “the water rose to the top of the wall and it was within an inch [25.4 mm] of going over,” Schaefer said.

The plant had received notice about the impending flood because the U.S. Geological Survey has gauging stations along the neighboring rivers.

The stations provided an approximate idea of when the water would reach the plant, Schaefer said.

Thanks to the warning system, most of the 65 people who usually work at the plant were told not to report that day, Schaefer said. “Only essential personnel were needed,” he said. This amounted to 18 people.

The flood walls were closed and kept closed for 24 hours. As part of the facility’s storm preparation plan, all treatment chemicals and diesel fuel for power generators were topped off, Schaefer said. Therefore, the plant was able to stay operational the entire time, he said.

“We didn’t really suffer any damage this time,” Schaefer said, though the plant did experience some minor issues. He said the plant took on some floodwaters through drains, but there was a significant number of dewatering pumps onsite to handle the overflow. The untreated water that entered the plant had significantly elevated turbidity levels because of the hurricane. It posed “significant treatment challenges,” Schaefer said. In addition, the facility lost electrical power during the storm. “We had to switch to our [diesel] gas engines,” Schaefer said.

 

 Future improvements 

Not all of New Jersey American Water’s facilities fared as well as the Raritan Millstone plant. The Canoe Brook Water Treatment Plant in Short Hills, N.J., experienced disrupted service because of floodwaters. As a result, customers in Summit, West Orange, Millburn, Maplewood, Irvington, and Springfield, N.J., had no water or low water pressure during the hurricane, according to an Aug. 29 New Jersey American Water press release.

“The facility is a challenge because it’s below the floodplain,” Schaefer explained.

The utility plans to replace the plant with a new one that will go on-line in June 2012. The $75 million facility will not only be certified under the Leadership in Energy and Environmental Design, or LEED, program, but also will include a preozonation treatment system that will put the facility in compliance with new 2012 requirements under the Safe Drinking Water Act, as well as a new water quality laboratory. It also will be built above the floodplain to prevent similar damage to what the old facility suffered during Hurricane Irene.

The construction site of the new facility did not suffer any damage because of the storm, Schaefer said.

— LaShell Stratton-Childers, WE&T 

 

©2011 Water Environment Federation. All rights reserved.