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# Marcellus Shale Gas Play Tetra Tech Capabilities Decreasing Costs of Waste Stream Analysis by Implementing a Testing Reduction Program and Utilizing Generator Knowledge Oil and Gas Compliance Conference AWMA Megan Allison MPH, CPH May 13, 2014 Washington, PA

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# Introduction/Agenda

• Introduction
• Define and Describe

– Generator Knowledge (GK)

– Testing Reduction (TR)


## • Applying GK

• Administering a TR Program
• Case Study

• Open Discussion/Questions

# Generator Knowledge

• No regulatory definitions in Pennsylvania!
• Generator Knowledge is the collection of sources that substantiate a waste evaluation.
• Common E&P sources may include:

– Diagram/Description of the generating process,

– List of ingredients/materials used in the generating process and corresponding SDs, and/or

– Statistics/Data obtained from approved methods of sampling and laboratory analysis.

# Applying Generator Knowledge

• Profiling

– Form U

• Chemical Analysis Waiver Request
• Disposition Facility and Waste Stream Specific



### – Other Waste Profile Types

• Submit “Generator Knowledge Package” 

## • Reporting

– Form 26R

• Submit “Generator Knowledge Package” in lieu of laboratory report(s)



### – Other waste data requests

# Testing Reduction

• No regulatory definition.

• Testing Reduction is a program to manage waste stream sampling, specifically related to waste streams sampled with reduced frequency or analyzed for a reduced parameter list.

• Reduces sampling, analysis, and staging costs.

# Administering a Testing Reduction Program

• Develop/Update the Waste Sampling Strategy

– Maintenance of Generator Knowledge

– Track Waste Stream and Disposition Specific Requirements

– Strategically collected additional samples



# • Manage the recertification process

– Change in generation process  Chemical Analysis Waiver (Form U)

– Every 5 years for 26R

# Case Study

• Generator Knowledge & Testing Reduction Achieved for:

– Compressor Station Filters

– Produced Water

– Drilling Fluids, liquefied

– Flowback

– Frac Filters

– Frac Sand

– Air
- Based Drill Cuttings

– Mud
- Based Drill Cuttings

– More to come! 

## • At 2012 activity levels

– Approximately $500,000 (60%) reduction in sampling costs, including:

• Sample Collection

• Laboratory Analysis

• Data Management

• Data Verification



### – Majority of staging costs eliminated

– Full regulatory compliance!

# The Pathway to Savings & Compliance! Implement a Testing Reduction Program

• Develop Standards & Guidelines
• Organize Defensible Data
• Create a Sampling & Disposition Strategy Develop Generator Knowledge Statements

• Generator Knowledge Package
• Chemical Analysis Waiver Requests

67% Reduction in Sample Collection 60% Cost Reduction!

# Key Points

• Compiling/Developing Generator Knowledge is the pathway to Testing Reduction.

• A properly administrated Testing Reduction program maintains Generator Knowledge.

• Substantial cost savings can be realized where generator knowledge is utilized and Testing Reduction programs are properly implemented.

## Key Products and Services for Defensible Data Program Products

• Laboratory Technical Scope of Work

• Sample Nomenclature Standards

• Parameter Lists

• Chain of Custody and Documentation Templates

• Sampling SOPs

– Required per Form 26R
• Sampling/Disposal Strategy

• Data Management Standards Sampling Program Services

• Sample Planning/Collection

• Data Management/Verification

– Reduces risk and provides defensibility
• Generator Knowledge Development

– Generator Knowledge Package Development

– Chemical Analysis Waiver Request Development
• Site/Event Management

• Reporting

– Form 26R

– Production Reporting

– Internal/External Requests, etc. Program Services

# Open Discussion/Questions

For More Information: Megan Allison MPH,CPH Megan.Allison@TetraTech.com 412
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