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# CLARKSBURG SANITARY BOARD

ACCEPTING OIL& GAS WASTEWATER 7/23/09westvirginia departmentofenvironmental protection

Division of Water and Waste Management 601 571hStreet, S.E. Charleston, WV 25304 Phone 304-926-0495 Fax 304-926.0496 Joe Manchin III.Governor Randy C. Huffman, Cabinet Secretary

www.wvdep.org

Mr. William Goodwin, Superintendent Clarksburg Sanitary Board 222 West Main Street Clarksburg, WV 26301

Dear Mr. Goodwin: July 23, 2009

Re: WV/NPDES Pernfit No. WV0023302 Accepting Oil and Gas Wastewater

This correspondence shall serve as the agency's formal response to your e-mail daied May 10, 2009 in which the Clarksburg Sanitary Board (CSB) requested intbrmation as to the requirements that would be imposed upon the CSB as aresult of accepting oil and gas related wastewaters.
The USEPA and WVDEP discourages POTWs from accepting wastewater fi'om 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 of operations contain high levels of chloride, dissolved solid, sulfate, and other pollntants. POTWs provide little to no treatment of these pollutants and could potentially lead to water quality issues inthe receiving stream. The CSB discharges to the Monongahela River basin which flows into the State of Pennsylvania. Pennsylvania has recently experienced exceedances of water qualib, standards with respect to total dissolved solids and sulthte in the Monongahela River. Therefore, prior to accepting these types ofwastewaters, the CSB must evaluate and establish local limits accordingly. The agency strongly encourages the CSB to ensure that appropriate local limits be established to prevent inhibition, pass-through, and interference with all POTW operations. Prior to CSB issuing apermit for the acceptance ofthese wastewaters, the CSB must establish the appropriate local limits through apermit modification and adopt them into its sewer use ordinance. The lbllowing bullets list the agency's expectations and requirements that would be imposed, at aminimum, ifthe permittee decides to continue to pursue accepting oil and gas related wastewaters.

• The agency has determined that the following pollutants are pollutants ofconcern associated with oil and gas related wastewaters and may have apotential for inhibition, Promoting a healthy environment.

### Mr.William Goodwin

July23, 2009 interference, and pass-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 andgrease, total suspended solids, iron, aluminum, chloroform, benzene, phthalate esters, strontium, strontium-90, boron, lithium, gross alpha radiation, gross beta radiation, radium 226 + radium228.

0: The CSB must conduct ahead-works analysis and establish aMaximum Allowable Headworks Loading (MAHL) forthe pollutants listed above. Ifthe actual loading of any of the pollutants ismore than 20% of MAHL, alocal limit must be developed for the pollutant and adopted.

• Wastewater shall notbe introduced orconnected into the combined sewer at apoint where there areCSOs between the introduction/connection point and the head-works.
No pollutants can be introduced into a POTW (including the collection system) thatcan create afire orexplosion hazard. Wastewaters with aclosed cup flashpoint ofless than 140 degrees Fahrenheit using test methods specified in 40 CFR 26 !.21 ofthe code of federal regulations are prohibited from being introduced into POTWs. Due to the nature of theorganic pollutants present in this nondomestic wastewater, the permittee must conduct thorough testing onthis nondomestic wastewater to determine ifitis permissible. Additionally, this should also be imposed as alimit in any permit issued by the City for this type ofwastewater.
No pollutants can be introduced into a POTW (including the collection system) which result inthe presence of toxic gases, vapors, orfumes within the POTW in aquantity that may cause acute worker health and safety problems. Due to the nature ofthe organic pollutants present inthis nondomestic waslewater, the permittee must evaluate the necessity oflimitations to be protective of POTW workers. Information onthis type of evaluation is available in an EPA guidance document entitled Guidance to Protect POTW Workersfrom 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 leadto increased wet weather discharges from CSOs.

• The agency will impose monitoring at Outfall 001 forthe pollutants listed above.

O1.

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### DuetoissueswithTDS and sulfate intheMonongahela RiverinPennsylvania,the agency will impose limitsforTDS and sulfate withoutthebenefitofamixing zone on Outfall 001 inordertobeprotective ofPennsylvania's waterquality criteria. The agency will alsoimposeeffluent limitationsforchronictoxicity,chloride,and possibly otherpollutants.Mr. William Goodwin

July 123,2009 Technologically Enhanced, Naturally Occurring Radioactive Materials (TENORM) are regulated by the Nuclear Regulatory Commission (NRC) and/or the West Virginia Department of Health and Human Resources (WVDHHR) per 60 CSR 23 of the West Virginia Legislative Rules. This regulation requires facilities accepting TENORM to be certified by either the WVDHHR or the NRC prior to acceptance. Further, TENORM includes requirements with respect to radioactive exposure levels that may need imposed as local limits and/or effluent limits to be protective of POTW workers and water quality standards. The permittee must coordinate with the NRC and!or WVDHHR to obtain any necessary approvals and provide its findings to the WV.DEP.
If you have any comments or questions, feel free to contact Netar (Nate) Wadhwa of our office at 304-926-0499 extension 1013. Sincerely,

Scott G. Mandirola Acting Director SGM/pw