P020212-1

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

1
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

412-829-3612