Study of Oil and Gas Extraction Wastewater

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Study of Oil and Gas Extraction Wastewater ( study-oil-and-gas-extraction-wastewater )

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A key question that arises with respect to oil and gas extraction activities and CWT facilities is how to determine if a facility is located off-site. The EPA defines site at 40 CFR 122.2 as “the land or water area where any ‘facility or activity’ is physically located or conducted, including adjacent land used in connection with the facility or activity.” Facility or activity means any NPDES “point source” or any other facility or activity (including land or appurtenances thereto) that is subject to regulation under the NPDES program.” The EPA issued a compliance guide and associated frequently asked questions (FAQs) to explain, among other things, the relationship between the CWT ELGs and the oil and gas extraction ELGs for natural gas drilling in the Marcellus shale (U.S. EPA, 2011c, 2011d). In the FAQs, the EPA indicates that for gas drilling activities: (T)he land identified in the drilling permit; including the locations of wells, access roads, lease areas, and any lands where the facility is conducting its exploratory, development or production activities, or adjacent lands used in connection with the facility or activity, would constitute the site. Land that is outside the boundaries of that area is considered to be “off-site.” While these FAQs are not legally binding they provide information that may be useful to permitting authorities to help inform decisions on what constitutes off-site in the context of Marcellus shale gas extraction activities. 3.3.2 Water Quality-Based Effluent Limitations WQBELS are the second component of NPDES permits. When drafting a NPDES permit, a permit writer must consider the impact of the proposed discharge on the quality of the receiving water. Water quality goals for a waterbody are defined by water quality standards. By analyzing the effect of a discharge on the receiving water, a permit writer could find that technology-based effluent limitations alone will not be sufficient to meet the applicable water quality standards. In such cases, the CWA and its implementing regulations require development of WQBELs. WQBELs help meet the CWA objective of restoring and maintaining the chemical, physical, and biological integrity of the nation’s waters and help to ensure attainment of the designated uses of waters established by the state which include the protection and propagation of fish, shellfish and wildlife, and recreation in and on the water (fishable/swimmable). WQBELs are designed to protect water quality by ensuring that water quality standards are met in the receiving water. When TBELS based on the requirements of 40 CFR 125.3(a) are not sufficient to meet water quality standards, additional or more stringent effluent limitations and conditions, such as WQBELs, are included in NPDES permits. CWA section 301(b)(1)(C) requires that permits include any effluent limitations necessary to meet water quality standards. To satisfy that requirement, permit writers evaluate effluents to determine if pollutants in the effluent would cause, have the Study of Oil and Gas Extraction Wastewater Management 14 Section 3−Background

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