# WV0023124

CITY OF 

# MORGANTOWN LETTERACCEPTING OIL & GASWASTEWATER DATED:8/11/09

# dep

westvirginla

department ofenvlronmental protection
Division of Water andWaste Management 601 57thStreet, S.E. Charleston, WV 25304 Phone 304-926-0495 Fax 304-926-0496 JoeManchin III, Govemor RandyC. Huffman, Cabinet Secretary

www.wvdep.org
August 11, 2009 Mr. Terry Hough City ofMorgantown 389 Spruce Street Morgantown, WV 26505 

# 9z7 .08 39_36 2, 7S 2 4

CERTIFIED RETURN RECEIPT REQUESTED Re: WV/NPIDES Permit No, WV0023124 Accepting Oil and Gas Wastewater Dear Mr. Hough: Recently, the WVDEP has become aware that some POTWs are receiving nondomestic wastewaters associated with oil and gas operations. In addition, the agency has also received numerous inquiries from POTWs with approved pretreatment programs regarding these wastewaters. As such, the agency isproviding this correspondence to remind the permit-tee ofits responsibilities and obligations as an approved pretreatment program, provide information related to these wastewaters, identify the agency's minimum expectations for assessing and permitting the acceptance ofthese wastewaters, and to identify the minimum requirements to be imposed upon the POTW by the agency ifthe permittee decides to accept these wastewaters. The USEPA and WVDEP discourage POTWs from accepting wastewater from oil and gas operations such as coal bed methane gas and marcellus shale wastewaters because these wastewaters essentially pass through sewage treatment plants and can cause inhibition and interference with treatment plant operations. The wastewaters from these types ofoperations contain high levels ofchloride, dissolved solids, sulfate, and other pollutants. POTWs provide little tono treatment ofthese pollutants and could potentially lead towater quality issues inthe receiving stream. The permittee discharges to the Monongahela River basin which flows into the State ofPennsylvania. Pennsylvania has recently experienced exceedances ofwater quality standards with respect to total dissolved solids_aiid Sulfate inthe Monongahela River. Therefore, prior to accepting these types ofwastewaters, the permittee must evaluate and establish local limits accordingly. The agency strongly encourages the permittee to ensure that appropriate local limits be established toprevent inhibition, pass-through, and interference with allPOTW operations. Prior tothe permittee issuing apermit for the acceptance ofthese wastewaters, the permit-tee must establish appropriate local limits through apermit modification and adopt them into its sewer use ordinance. The following bullets list the agency's expectations and Promoting a healthy environment.Accepting Oil and Gas Wastewater

August 11,2009 Page 2of4 requirements that would be imposed, at aminimum, ifthe permittee decides to pursue accepting oil and gas related wastewaters.

® The agency has determined that the following pollutants are pollutants ofconcern associated with oiland gas related wastewaters and may have apotential for inhibition, interference, andpass-through: total dissolved solids (TDS), sulfate, chloride, arsenic, titanium, cobalt, nickel, silver, zinc, vanadium, tin, cadmium, lead, chromium, hexavalent chromium, copper, fluoranthene, cyanide, mercury, selenium, antimony, beryllium, barium, ammonia nitrogen, fluoride, nitrite nitrogen, nitrate nitrogen, oil and grease, total suspended solids, iron, aluminum, chloroform, benzene, phthalate esters, strontium, strontium-90, boron, lithium, gross alpha radiation, gross beta radiation, and radium 226 +radium 228.

® The permittee must conduct ahead-works analysis and establish aMaximum Allowable Headworks Loading (MAHL) forthe pollutants ofconcern listed above. Ifthe actual loading ofany ofthe pollutants is more than 20% ofthe MAHL, alocal limit must be developed for the pollutant and adopted. Regardless, the permittee must develop local limits for all pollutants that may cause interference, inhibition, orpass through at the POTW including sludge disposal and toprotect POTW workers.
Wastewater shall notbe introduced or connected into a combined sewer at apoint where there are combined sewer overflows (CSOs) between the introduction/connection point and the head-works. Additionally, ifthe permittee is not acombined sewer system and contains sanitary sewer overflows (SSOs), wastewater shall not be introduced or connected into the sewer ata point where there are SSOs between the introduction/connection point and the head-works.
No pollutants can be introduced into aPOTW (including the collection system) that can create afire or explosion hazard. Wastewaters with aclosed cup flashpoint ofless than 140 degrees Fahrenheit using test methods specified in 40 CFR 261.21 of the code of federal regulations are prohibited from being introduced into POTWs. Due tothe nature ofthe organic pollutants present inthis nondomestic wastewater, the permittee must conduct thorough testing on this nondomestic wastewater to determine ifitispermissible. Additionally, this should also be imposed as alimit inany permit issued by the City for this type ofwastewater.

® No pollutants can be introduced into aPOTW (including the collection system) which result inthe presence oftoxic gases, vapors, or fumes within the POTW ina quantity that may cause acute worker health and safety problems. Due to the nature ofthe organic pollutants present inthis nondomestic wastewater, the permittee must evaluate the necessity of limitations to beprotective of POTW workers. Information on this type of evaluation is available in an EPA guidance document entitled Guidance toProtect POTW Workers from Toxic and Reactive Gases and Vapors (EPA Document No. 812-B-92-001 issued June 1992). The acceptance ofthis wastewater during wet weather events shall not lead to increased wet weather discharges from CSOs or SSOs.Accepting Oil and Gas Wastewater

August 11,2009 Page 3 of4



### • The agency will impose monitoring atthedischarge fromthepermittee's outfall forthe pollutants listed above. Due toissues with TDS and sulfate inthe Monongahela River inPennsylvania, the agency will impose limits for TDS and sulfate without the benefit of amixing zone on the permittee's discharge outfall in order to beprotective ofPennsylvania's water quality criteria."



### • The agency will alsoimpose effluent limitations forchronic toxicity, chloride, and possibly other pollutants.
IfaPOTW accepts wastewater at the POTW treatment facility via truck, train, or dedicated pipeline, including oil & gas extraction wastewater, the POTW must evaluate whether ornot the wastewater isahazardous waste (for instance a characteristic waste under 40 CFR 261.24). Ifthe Wastewater is ahazardous waste, the POTW must evaluate whether itqualifies as apermit by rule facility under 40 CFR 270.60(e) and meet notification, manifest, and reporting requirements including any more stringent state hazardous waste and corrective action requirements. Ifthe POTW accepts hazardous waste at the treatment plant and does not qualify as apermit by rule facility, itmust check with the state hazardous waste agency to determine its requirements. For further information regarding hazardous waste requirements, please contact Carroll Cather ofthe WVDEP at 304-926-0499 extension 1317. USEPA and WVDEP recommend that POTWs not accept hazardous waste at the treatment plant.
I Technologically Enhanced, Naturally Occurring Radioactive Materials (TENORM) are regulated by the Nuclear Regulatory Commission (NRC) and/or the West Virginia Department ofHealth and Human Resources (WVDHI-IR) per 60 CSR 23 ofthe West Virginia Legislative Rules. This regulation requires facilities accepting TENORM tobe certified by either the WVDHHR orthe NRC prior to acceptance. Further, TENORM includes requirements with respect toradioactive exposure levels that may need imposed as local limits and/or effluent limits to beprotective ofPOTW workers and water quality standards. The permit-tee must coordinate with the NRC and/or WVDHHR to obtain any necessary approvals and provide its findings tothe WVDEP. While some ofthe requirements noted above are specific tooil and gas related wastewaters; the permit-tee must consider the pollutants ofconcern, pass through and interference, the impacts on CSO or SSO discharges, the impacts on the permittee's Long-Term Control Plan and meeting water quality, and the need for new/modified local limits and revisions to its sewer use ordinance when evaluating new or expanded discharges ofany nondomestic wastewaters.Accepting Oiland Gas Wastewater

August 11,2009 Page 4of4 Ifyou have any comments or questions, feel free to contact Netar (Nate) Wadhwa ofour office at 304-926-0499 extension 1013. Sincerely,



### Scott G.Mandirola Acting Director SGM:mls

cc: Environmental Enforcement Inspector Environmental Enforcement Inspector Supervisor US EPA Region 3

### ST4TES

POST4L SER E.

Date: 08/24/2009
Iori derrick:
The following is in response to your 08/24/2009 request for delivery information on your Certified MaiI(TM) item number 7108 2133 3936 2975 0214. The delivery record shows that this item was delivered on 08/17/2009 at 12:02 PM in MORGANTOWN, WV 26505. The scanned image of the recipient information is provided below.

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