• • III mAJ_ ¢mlh €_lh all_cqh

_NVUUZ__UZ

CLARKSBURG

SANITARY BOARD

ACCEPTING OIL & GAS

WASTEWATER

7/23/09
westvirginiadepartmentofenvironmentalprotection

Division of Water and Waste Management

601 571h Street, 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 a result 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 in the

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 of wastewaters, 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 a permit for the acceptance of these wastewaters, the CSB must establish the

appropriate local limits through a permit modification and adopt them into its sewer use

ordinance. The lbllowing bullets list the agency's expectations and requirements that would be

imposed, at a minimum, if the permittee decides to continue to pursue accepting oil and gas

related wastewaters.

• The agency has determined that the following pollutants are pollutants of concern

associated with oil and gas related wastewaters and may have a potential for inhibition,

Promoting a healthy environment.
Mr. William Goodwin

July 23, 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 and grease, total

suspended solids, iron, aluminum, chloroform, benzene, phthalate esters, strontium,

strontium-90, boron, lithium, gross alpha radiation, gross beta radiation, radium 226 +

radium 228.

0: The CSB must conduct a head-works analysis and establish a Maximum Allowable

Headworks Loading (MAHL) for the pollutants listed above. If the actual loading of any

of the pollutants is more than 20% of MAHL, a local limit must be developed for the

pollutant and adopted.

• Wastewater shall not be introduced or connected into the combined sewer at a point

where there are CSOs between the introduction/connection point and the head-works.

No pollutants can be introduced into a POTW (including the collection system) that can

create a fire or explosion hazard. Wastewaters with a closed cup flashpoint of less than

140 degrees Fahrenheit using test methods specified in 40 CFR 26 ! .21 of the code of

federal regulations are prohibited from being introduced into POTWs. Due to the nature

of the organic pollutants present in this nondomestic wastewater, the permittee must

conduct thorough testing on this nondomestic wastewater to determine if it is permissible.

Additionally, this should also be imposed as a limit in any permit issued by the City for

this type of wastewater.

No pollutants can be introduced into a POTW (including the collection system) which

result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that

may cause acute worker health and safety problems. Due to the nature of the organic

pollutants present in this nondomestic waslewater, the permittee must evaluate the

necessity of limitations to be protective of POTW workers. Information on this type of

evaluation is available in an EPA guidance document entitled Guidance to Protect POTW

Workers from Toxic and Reactive Gases and Vapors (EPA Document No. 812-B-92-001

issued June 1992).

• The acceptance of this wastewater during wet weather events shall not lead to increased

wet weather discharges from CSOs.

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

O1.

O'

Due to issues with TDS and sulfate in the Monongahela River in Pennsylvania, the

agency will impose limits for TDS and sulfate without the benefit of a mixing zone on

Outfall 001 in orderto be protective of Pennsylvania's water quality criteria.

The agency will also impose effluent limitationsfor chronic toxicity, chloride, and

possibly other pollutants.
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