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DCED’s Conventional Oil & Gas Drilling Advisory Council Meets Dec. 15 On Radioactive Drilling Waste; Road Dumping Wastewater; Limits On Methane Emissions; More

The agenda for the December 15 meeting of DCED’s PA Grade Crude [Oil] Advisory Council includes a variety of current issues of interest to the conventional oil and gas industry and the affected public--

-- Final regulation limiting VOC/methane emissions from conventional oil and gas facilities [See below];

-- Presentation on radioactive material in drilling wastewater by a consultant-- Perma-Fix Environmental Services;

-- Update on proposed Chapter 78 conventional waste management regulations [Read more here];

-- Update on new federal conventional oil and gas well program [Read more here];

-- Update on the leak of an estimated 1 billion cubic feet of natural gas from Rager Mountain gas storage area in Cambria County [Read more here]; and

-- Response from Dr. William Burgos on how the Council misrepresented his positions on the Penn State study of the environmental impacts of spreading drilling wastewater on roads [See below].

Click Here for the complete agenda.

Final VOC/Methane Limits

The meeting packet includes a three-page list of questions for DEP on the final regulation setting VOC/methane emission limits on conventional oil and gas operations for discussion.

As reported by Marcellus Drilling News, three industry groups representing the conventional oil and gas industry filed a lawsuit in Commonwealth Court December 5 in an attempt to block implementation of DEP’s emergency final VOC/methane limits regulation on conventional oil and gas facilities. [Read more here.]

Because of that litigation, it is unlikely DEP will be able to respond to those questions.

Misrepresentations Of Road Spreading Study

Dr. William Burgos, lead author of the Penn State study released in May on the environmental impacts of road spreading conventional drilling wastewater, wrote a memo to the Council on how the conventional industry misrepresented his positions on the study and its contents in a resolution it passed in August.

On May 26, Penn State University and the Department of Environmental Protection released a new study of spreading conventional oil and gas wastewater on unpaved roads by Penn State researchers, who found the wastewater running off the roadways after spreading contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards.

The study also found the wastewater is only about as effective as rainwater at controlling dust, but worse for the environment.

“The ineffectiveness and potential pollution of wastewater spreading make the practice an unsuitable alternative for dust suppression on Pennsylvania roads, the team reported to the DEP’s Office of Oil and Gas Management.” Read more here.

On August 18, conventional oil and gas drillers on DCED’s PA Grade Crude [Oil] Development Advisory Council passed a motion recommending DEP's acceptance of the Penn State study showing their drilling wastewater dumped on roads is bad for human health and the environment be rescinded and industry representatives by involved in rewriting the study. Read more here.

Among the ways Dr. Burgos said the conventional oil and gas industry misrepresented his positions were--

-- The request to rescind DEP’s acceptance of the Penn State report by the industry is “unwarranted because it is unsupported by scientific fact.”

-- On the statement in the industry resolution that he agreed samples were not representative of conventional wastewater in Northwest Pennsylvania-- “CDAC misunderstood and misrepresented my position” “I did not agree.”

-- The “CDAC misunderstood and misrepresented my position” -- “I did not agree” 2,500 pCi/L of combined radium is not representative of conventional wastewater. “...2,500 pCi/L is representative” and wastewater spread on roads “could readily equal or exceed this value.” [60 pCi/L is the Nuclear Regulatory commission standard]

-- The resolution pointed out the new Penn State study did not reference three previous studies done by DEP on the issue of road spreading and radioactive elements. Dr. Burgos responded, “While the validity of a study’s scientific results does not depend on references to previous work, I reviewed those reports and plan to cite them in future publications. All three reports support our findings.”

[Note: One of the three studies was DEP’s 2013/2016 TENORM study of naturally occurring radioactive material in oil and gas wastewater, drill cuttings and natural gas itself completed with the help of Perma-Fix Environmental Services.]

Click Here for the full response from Dr. Burgos.

The conventional industry responded to the memo from Dr. Burgos by picking small sections from a transcript of his remarks that supported their position and annotated the resolution the Council passed in August.

It’s clear the full transcript supports Dr. Burgos’ position because it puts those hand-picked remarks in context.

The meeting packet also includes draft minutes from the August 18, 2022 meeting for Council action.

New In-Person Location

The meeting will be held at the Pennsylvania Western University campus (former Clarion University) Room 248 (2nd Fl) at the Gemmell Student Center, Clarion starting at 10:00 a.m.

Click Here to join the meeting online via Microsoft Teams [Meeting ID: 236 209 630 931 Passcode: Y6H28Y] or by telephone - +1 267 332 8737 Phone Conference ID: 369 090 892# .

Visit DCED’s PA Grade Crude [Oil] Advisory Council webpage. Questions should be directed to Adam Walters, adwalters@pa.gov or call 717-214-6548.

DEP Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - Dec. 3 to 9 [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment [PaEN]

-- DEP Posted 50 Pages Of Permit-Related Notices In The Dec. 10 PA Bulletin [PaEN]

Related Articles This Week:

-- Sign Petition Urging Governor-Elect Shapiro To Prioritize Banning Roading Dumping Of Conventional Drilling Wastewater [PaEN]

-- DEP Issues Orders To Equitrans To Plug Additional Wells At Cambria County Underground Natural Gas Storage Facility, Bring Other Wells Up To Current Casing Standards And Take Other Actions [PaEN]

-- Delaware River Basin Commission Adopts A Ban On Discharging Wastewater From Hydraulic Fracturing Drilling Operations, Strengthens Rules On Exporting, Importing Water To Support Fracking [PaEN]

-- Bob Donnan Blog: Comparing How The Delaware River Basin Commission And The Ohio River Valley Water Sanitation Commission Address Shale Gas Industry Wastewater

-- Bay Journal: Hellbender Habitat Slammed By Pollution From Shale Gas Development In PA's Loyalsock Creek - By Ad Crable, Chesapeake Bay Journal [PaEN]

-- DCED’s Conventional Oil & Gas Drilling Advisory Council Meets Dec. 15 On Radioactive Drilling Waste; Road Dumping Wastewater; Limits On Methane Emissions; More [PaEN]