Municipal Authority of the City of McKeesport, PA Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 20 11 i 

## Municipal Authority of the City of McKeesport, PA
NPDES Permit No. PA0026913 Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011

TABLE OF CONTENTS

PAGE

1.0 Introduction

................................ ................................ ................................ ...................... 1

1.1 Natural Gas Drilling W astewater Acceptance Policy and Protocol

.................... 1

2.0 MAHL Calculation: Methods Input and Considerations

................................ ........... 2

2.1 Sampling Phase

................................ ................................ ................................ .......... 2

2.2 Calculation Phase

................................ ................................ ................................ ....... 2

3.0 MAHL and MAIL Calculation

................................ ................................ ....................... 6

4.0 MAHL and MAIL Calculation Results

................................ ................................ ......... 6

4.1 MAHL Calculation Results

................................ ................................ ................... 6

4. 2 MAIL Calculation Results

................................ ................................ ..................... 7

4. 3 MA H L C omparison to Current Industrial Loads

................................ ............. 7

5.0 Summary and Conclusion

................................ ................................ .............................. 9

TABLES

Table I: POTW Removal Rates

................................ ................................ ................................ .... 4

Table II: Chronic Water Quality Criteria

................................ ................................ ................... 5

Table III: Maximum Allowable Headworks Loading (MAHL) Re sults

................................ 6 Table IV: Calculation of the Maximum Allowable Industrial Loading

................................ . 7

Table V: MAHL Comparison to Current Industrial Loads

................................ ..................... 8 Table VI: Proposed Maximum Headworks Industrial Allowa nc e

................................ ........ 9

APPENDICES

Appendix A: Data Summary and Raw Data Appendix B: M AHL CalculationMunicipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 

## Municipal Authority of the City of McKeesport, PA
NPDES Permit No. PA0026913 Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 20 11

1.0 INTRODUCTION

The Municipal Authority of the City of McKeesport (MAC M) owns and operates a Wastewater Treatment Plant (WWTP) under the terms of NPDES Permit No. PA0026913

and within the framework of a USEPA approved Pretreatment Program . The Publically Owned Treatment Works (POTW) provides a preliminary, primary and secon dary

treatment as well as disinfection of wastewater from the 1 1 communities that comprise the collection system service area . The POTW discharges a treated effluent to the Monongahela

River.

Although there are currently no categorical or significant i ndustrial users within the collection system service area, the MACM accepts wastewater from companies engaged in the drilling of the Marcellus Shale layer to tap natural gas wells. As regulatory agencies
consider this waste industrial in nature, the MACM has developed permits for acceptance of

the waste with contracted sources and haulers.

Pursuant to the findings of a September 2009 USEPA audit of the MACM pretreatment program, the MACM has been required to conduct a headworks loading analysis (HLA) fo r pollutants found in natural gas drilling waste water s and

, if necessary, develop local limits The purpose of this report is to provide explanation and detail s of the headworks loading analysis to fulfill the EPA requirement.



### 1.1 N ATURAL 

### G AS 

### D RILLING 

### W ASTEW ATER 

### A CCEPTANCE 

### P OLICY AND 

### P ROTOCOL

Natural gas drilling w astewater is accepted at the MACM WWTP after an onsite MACM employee screen s the wastewater for pH and once a sample from the hauling vehicle has

been taken. If the pH is beyond the acceptable ran ge of 5.0 to 12 pH units the hauler is turned away. Provided that the wastewater is within an acceptable pH range, the wastewater is discharged from the hauler into an excess capacity aerated basin. The Authority policy is to limit the amount of wastewate r accepted from one source (well site) to less than 25,000 gallons per day and cumulatively 1% of the average day forward flow from all sources per a PADEP administrative order issued October 23, 2009. The “co

- mingled” gas well wastewater is diluted with WWTP primary effluent, aerated, and continuously introduced to the headworks of the facility at a slow rate through the WWTP internal recycle drain line, which also transmits belt filter press filtrate, V actor receiving stationMunicipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 drain and other WWTP drains to the wet well. Wastewater entering the wet well is then pumped through the treatment train of the WWTP.



### 2.0 HLA CALCULATION: METHOD S INPUT AND CONSIDER ATIONS

The Headworks Loading Analysis consisted of the sampling phase, and the calculation of

po tential local limits.



### 2.1 S AMPLING 

### P HASE 

### :

The sampling phase was comprised of an EPA approved sampling plan, sampling and analysis. A copy of the approved sampling plan and analytical reports for the samples used are appended to this report in Appendi x A

.

As identified in the sampling plan:

a. An evaluation of the sampling data of the wastewater accepted by the MACM has identified eight (8) pollutants selected pursuant to pending regulations and historical higher source concentrations than other polluta nts scanned for samples analyzed.

b. For analyses yielding consistent non

- detectable results for various pollutants, it was determined that the background does not contain the pollutant and further analysis for that pollutant may be ceased and replaced with a nother pollutant.

c. Timed composites samples were obtained once a month for 12 months at designated locations to avoid contamination of samples from other sources that could dilute the strength of gas wastewater pollutants.

d. Samples were analyzed by a contrac ted third party laboratory using EPA approved

methods.

Pursuant to item b. above, l ithium was included in the ori ginal eight (8) pollutants and replaced in the third month of the sampling phase by iron.



### 2.2 C ALCULATION 

### P HASE

EPA Region III has developed a Mi crosoft Excel spreadsheet for evaluating data associated with pretreatment programs for the purpose of determining maximum allowable loadings and potential local limits . A digital copy of this spreadsheet was supplied to KLH Engineers, Inc. for the purpo se of utilizing the calculations incorporated therein to perform

the headworks loading analysis

. The base spreadsheet utilizes two linked worksheets

. The raw data is input in the Monitoring Data worksheet which automatically calculates the percent

remov als. The Limits Calculation Worksheet identifies where POTW and receiving stream data is required and directs the user to select the removal rate basis for the pollutants being

calculated. The Limits Calculation Worksheet then automatically calculate s th e headworks loadings using logical progressions based on the most stringent parameters through a series

of 19 Tables.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 The calculation included the following considerations used as information input into the

various Tables in the EPA Spreadsheet :

1. Table 1

– Unit Operations in the Limits Calculation Worksheet requests the user to input which of the listed unit operations are present at the POTW. Since the MACM WWTP does not have a trickling filter or anaerobic digester and is not designed for the removal

o f ammonia nitrogen, only the activated sludge choice was selected.

2. Table 2

- Flow and Receiving Stream Data in the Limits Calculation Worksheet request the user to input data about the POTW and receiving stream.

a. The average annual flow for the sampling p eriod of 9.4 MGD was input where requested.

b. A value of 0 .0 36645 MGD was entered as input to account for the wastewater accepted from haulers associated with the drilling of gas wells

.

c. The average annual flow of sludge wasted to the sludge stabilization pro cess for the 2008 Operating Year was calculated as 0.03572 MGD and input where requested. 1

d. The average annual flow of dry sludge disposed of from the WWTP for the 2008 Operating Year was calculated as 2.87 dry metric tons and input where requested. 1

e. The av erage annual flow of hauled municipal waste accepted at the WWTP for the 2008 Operating Year was calculated as 0.03582 MGD and input where requested. 1

f. T he 7Q10, and hardness utilized in determining the NPDES Permit limits were furnished by the PADEP . The 1Q10 and Harmonic Mean Flow determined using a mixing factor procedure advised by USEPA. The input values are as follows:

NPDES Permit 7Q10 1
(Chronic Stream Flow) 650 cfs = 420 MGD

NPDES Permit 1Q10 1
(Acute Stream Flow) 84 MGD

NPDES Permit Harmo nic Mean Flow 1 420 MGD
Hardness 193 mg/L as CaCO 3

It should be noted that although the water quality standards that would apply to the pollutants of concern are actually appli cable at drinking water intakes; and

u nderstanding that the nearest drink ing water intake is approximately 11 miles downstream, the various stream flows would be larger values as there are

1 This value is consistent with the most recent HLA performed for the evaluation of the MACM local limits required by the NPDES Permit.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 several tributaries to the Monongahela River between the MACM outfall and the next drinking water intake. As such, it was decided that the conservative approach would be to utilize the aforementioned flows at the MACM outfall.



### 3. The data collected for influent with recycle to include the target wastes, and POTW

effluent samples were input into the M onitoring D ata worksheet . Pollutant mean va lues were calculated and outlying data points (data more than twice the standard deviation of the data population) were removed from the calculation.

The worksheet then calculates the percent removal comparing influent to effluent and influent to sludge . Table I demonstrates the calculated removal rates through the POTW

and identifies the removal selected in Table 3 of the limits calculation

.



### Table I: POTW Removal Rates

Parameter POTW Influent/Effluent Removal Percentage Selected Removal Rate

Barium 7 1.64 % Influent/Effluent

Bromide 26.99 % Influent/Effluent

Chloride 4.44 % Influent/Effluent

Iron 89.32 % Influent/Effluent Magnesium 6.62 % Influent/Effluent

Strontium 18.47 % Influent/Effluent

Sulfate 3.94 % Influent/Effluent

Total Dissolved Solid s 6.43 % Influent/Effluent

Sampling analysis results from the influent (without recycle) were input the Monitoring

Worksheet as the background level of pollutants in this analysis as they are commensurate with the POTW influent sampling results. The dat a was evaluated for outliers and the calculated mean values for application to the calculation.

4. Available receiving stream concentrations for pollutants of concern were obtained from data published by the West Virginia Water R esearch Institute in their “ Monongahela River Water Quality Study”. The data is from a monitoring station at River Mile 23 approximately 7 miles upstream. Because the Youghiogheny River confluences with the Monongahela River downstream of the POTW discharge, the Monongahela River background pollutant concentrations obtained from the upstream monitoring station have been used, since these more nearly represents the mixing of the effluent with the

stream flow. The data available for the study period was averaged and input as designa ted in Table 4 of the Limits Calculation Worksheet.

5. Table 4 of the Limits Calculation Worksheet requires input for chronic water quality standards. As not all pollutants had existing statewide water quality standards, potential state, and national water quality standards were applied as chronic standards

.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 Given the conservative approach of utilizing stream flows upstream of the drinking
water intake, applying these criteria against the 7Q10 Stream flow would account for mixing within the river between th e MACM outfall and next drinking water intake.

Table II identifies the c hronic water quality standard applied for the various pollutants:



### Table II: Chronic Water Quality Criteria 1

Parameter Concentration (in mg/L) Governing Source

Barium 10 Proposed PA WQS 2

Bromide Not Available

Chloride 250 PA Statewide WQS 3

Iron 1 National WQS 4
Magnesium Not Available

Strontium 10 Proposed PA WQS 2

Sulfate 250 PA Statewide WQS 3

Total Dissolved Solids 500 PA Statewide WQS 3

Notes:

1. Water quality standards appl ied as chronic standards

. 2. As published in the Keystone Water Quality Manager , “Marcellus Shale Gas Well Operations Impact on Pretreatment Programs”

- Judy Musselman

, Jul

- Sep 2009; p. 20

. 3. As published in Pennsylvania Code Title 25, Chapter 93 Water Quality Standards.

4. As published by EPA in National Recommended Water Quality Criteria , 2006

6. Table 5 of the Limits Calculation Worksheet requires input for acute water quality standards. No acute water quality criteria were available and thus not applied to the

c alculations for this report.

7. Table 6 of the Limits Calculation Worksheet requires input for human health water quality standards. Applicable human health national water quality standards were applied to the calculations for this report.

8. T he activated sl udge inhibition default threshold values in Table 8 of the Limits

Calculation Worksheet for all applicable pollutants were input

. The only pollutant evaluated herein with a potential for inhibition was iron, wi th a US EPA published 2

threshold level concent ration r a n ge of 5

- 500 mg/L published. The inhibition threshold applied was the most stringent value 5 mg/L as a matter of conservatism.

9. Table 10 of the Limits Calculation Worksheet evaluate s the loading with respect to nitrification inhibition. Althoug h the MACM does not have regulatory limits no r is the

POTW designed to intentionally remove nutrients, an inhibition threshold for Magnesium 2 was applied, because no other water quality criteria was available to compare the data obtained against. Also giv en the lack of regulatory requirements, it is again considered conservative to apply such a standard.

2 Guidance Manual for Preventing Interference at POTWs , USEPA, September 1987Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 10. Data entry for Tables 9, 11, 12, and 14 w as not performed as evaluations with respect to trickling filter inhibition, anaerobic digestion inhibition, and sludge disposal were not applicable to this study.

11. A safety factor of 10% of the calculated allowable load was applied to Table 16 of the

Limits Calculation Worksheet. The entry of this safety factor is consistent with the

conservative approach throug hout this calculation and in accordance with EPA recommendations for the application of safety factors.



### 3.0 MAHL AND MAIL CALCULATION

The pages contained in Appendix B are a printout Tables 1

- 1 9 of the Limits Calculation

Worksheet that calculat e s the Maximum Allowable Headworks Loading (MAHL) and the Maximum Allowable Industrial Loading (MAIL) for the POTW

.



### 4.0 MAHL AND MAIL CALCULATION RESULTS

4.1 MAHL C ALCULATION 

### R ESULTS

The results of the calculation using the Excel spreadsheet and based on the foregoing input

consider ations are presented in Table I I I . The table presents the result of the MAHL, and the criteria governing the calculation of the MAHL.



### Table II I : Maximum Allowable Headworks Loading (MAHL) Results 1

Parameter MAHL in pounds p er day Governing C riteria

Barium 12

, 627.37 Proposed PA WQS

Bromide Surveillance and Monitor 2 Not Applicable

Chloride 853

, 141.27 PA Statewide WQS

Iron 391.98 Activated Sludge Inhibition Magnesium 3

, 919.80 Nitrification Inhibition

Strontium 43

, 926.59 P roposed PA WQS

Sulfate 463

, 215.07 PA Statewide WQS

T otal D issolved S olids 808

, 963.31 PA Statewide WQS

Notes:

1. Information presented as calculated in Table 1 5 of the Limits Calculation Worksheet in Appendix B

. 2. No numeric MAHL value could be calculated.

It should be recognized that as no MAHL value could be calculated for Bromide due to the lack of water quality criteria and inhibition values, it has been determined that the MAHL

will continued to be evaluated and monitored until such time that standards for comparison are available.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 

### 4. 2 MAIL C ALCULATION 

### R ESULTS

From Table 1 6 of the spreadsheet calculations, the MAHL has been converted into a Maximum Allowable Industrial Loading (MAIL) by applying aforementioned safety factors

and subtracting the backg round concentrations from the collections system. Table I V presents this conversion.



### Table I V : Calculation of the Maximum Allowable Industrial Loading

Parameter MAHL 1


### in lb/day MAHL 2


### in lb/day Background 3


### Loading in lb/day MAIL 4


### in lb/day

Barium 12

, 62 7.37 6

, 313.68 27.12 11

, 337.51

Bromide S &M 5 282.15 S &M 5

Chloride 853

, 141.27 426

, 570.64 18

, 755.10 749

, 072.05

Iron 391.98 195.99 104.36 248.42 Magnesium 3

, 919.80 1

, 959.90 1

, 178.73 2

, 349.09

Strontium 43

, 926.59 21

, 963.29 28.62 39

, 505.31

Sulfate 463

, 215 .07 23

, 1607.53 6

, 231.83 410

, 661.73

T otal D issolved

S olids 808

, 963.31 404

, 481.65 4

, 6126.66 681

, 940.31

Notes:

1. MAHL

– Maximum Allowable Headworks Loading

2. MAHL

– Maximum Allowable Headworks Loading with a Safety Factor of 2 applied.

3. Background Loads: Influen t (without recycle load) Samples Average concentrations converted from mg/L to lbs/day

4. MAIL

– Maximum Allowable Industrial Loading (with 10% Safety Factor) = MAHL less Background

Loads

5. S &M

- Surveillance and Monitor



### 4.3 MA H L C OMPARISON TO 

### C URRENT 

### I NDUS TRIAL 

### L OADS

Typically, the MA H L is compared to the current industrial maximum and average pollutant loadings, and the allocation on current IU permits. Currently there are no values on the existing permits with waste originators and haulers and no other i ndustries within the collection system regulated by the Pretreatment Program . Therefore, a comparison can only be made to the current industrial maximum and average pollutant loadings to determine the need for local limits. Table V represents the results of Table 17 of the spreadsheet calculations which makes this comparison.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 

### Table V: MAHL Comparison to Current Industrial Loads

Parameter MAHL in lb/day Current

Industrial

Average

Load 1 

### in lb/day Average

Percent

Loaded vs.

MAHL 2 Current

Industrial

Max imum

Load 3 

### in lb/day Maximum

Percent

Loaded vs.

MAHL 4

Barium 12,627.37 191.71 1.52 % 1,200.63 9.51 %

Bromide S &M 5 393.69

- 1,262.18

- Chloride 853,141.27 29,513.96 3.46 % 65,311.71 7.66 %

Iron 391.98 135.91 34.67 % 265.45 67.72 % Magnesium 3,919.80 1 ,339.69 34.18 % 1795.82 45.81 %

Strontium 43,926.59 194.68 0.44 % 473.12 1.08 %

Sulfate 463,215.07 5,971.16 1.29 % 8,153.18 1.76 %

Total
Dissolved
Solids 808,963.31 67,135.48 8.30 % 122,376.16 15.13 %

Notes:

1. Current Industrial Average Load

– Average in fluent concentration from the monitoring data converted from mg/L to lbs/day

2. The Current Industrial Average Load as a percentage of the MAHL.

3. Current Industrial Maximum Load

– The single maximum influent concentration from the monitoring

data converted fro m mg/L to lbs/day.

4. The Current Industrial Maximum Load as a percentage of the MAHL.

5. S &M

- Surveillance and Monitor

As demonstrated in Table V, a comparison of the maximum and average industrial pollutant loadings received at the MACM headworks, in most c ases, represents single digit percentages for the pollutants evaluated. Pursuant to the Local Limit Development

Guidance document published by the USEPA, a POTW is recommended to adopt a local limit for a pollutant if the average percent loading exceeds 6 0% of the MAHL and the average percent loading is more than 80% of the MA H L. 3 In no case, as demonstrated in Table V do these conditions occur. Therefore, the MACM does not intend to adopt local limits for these parameters based on this evaluation.

Co nsistent with the diligence exerted by the MACM with respect to this waste , samples and analyses for these pollutants will continue to be obtained and the results compared to the

MA H L calculated herein. Should the influent loadings approach the threshold percentages for required local limits, or as required by regulatory agencies, the HLA will be re

evaluated.

3 As published by the USEPA in Chapter 6.1.1 of Local Limit Development Guidance.Municipal Authority of the City of McKeesport

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- Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants
March 2011 

### 5.0 SUMMARY AND CONCLUSI ON

The MACM owns and operates a WWTP with a n approved USEPA Pretreatment Program

that accepts wastewater from compa nies engaged in the drilling of the Marcellus Shale layer to tap natural gas wells. A September 2009 USEPA audit of the MACM pretreatment program, yielded the requirement for headworks loading analysis for pollutants found in natural gas drilling wastewat ers and, if necessary, develop local limits with respect to the results of the headworks loading analysis.

The headworks loading analysis was performed in two phases: the sampling phase, and the

calculation of maximum allowable loadings and potential loc al limits. The proposed

Maximum Allowable Headworks Loading and Maximum Allowable Industrial Loading

were calculated utilizing USPA recommendations and conservative input values. The

results were c ompared to current industrial maximum and average pollutan t loadings. In
no case, d id the influent loadings exceed the threshold perce ntages for required local limit adoption. T o this end

, no local limits will be adopted for the pollutants evaluated for this
report. Finally, MACM will continue to compare mont hly sample analysis results to the

MAHL and MAIL calculated herein and presented in Table V I , as a means of evaluation of the wastes accepted and to determine if local limits are necessary

.



### Table VI: Proposed Headworks Industrial Allowance

Parameter M A H L in lb/day MAIL in lb/day

Barium 12

, 627.37 11

, 337.51

Bromide Surveillance and Monitor Surveillance and Monitor

Chloride 853

, 141.27 749

, 072.05

Iron 391.98 248.42
Magnesium 3

, 919.80 2

, 349.09

Strontium 43

, 926.59 39

, 505.31

Sulfate 463

, 215.07 41

, 0661. 73

T otal D issolved S olids 808

, 963.31 68

, 1940.31Municipal Authority of the City of McKeesport

Headworks Loading Analysis
March 2009 

# A PPENDIX 

# A:

S AMPLING 

# P LAN



# , D ATA 

# S UMMARY

AND 

# R AW 

# D ATAMunicipal Authority of the City of McKeesport

Headworks Loading Analysis
March 2009 

# A PPENDIX 

# B:

MAHL C ALCULATION