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Centralized Impoundments

Centralized impoundments are wastewater-holding facilities that are:

  • A natural topographic depression, manmade excavation or diked area formed primarily of earthen materials.
  • Designed to hold fluids or semifluids associated with oil and gas activities, including wastewater, flowback and mine influenced water, the escape of which may result in air, water or land pollution or endanger persons or property.
  • Constructed solely for the purpose of servicing multiple well sites.[1]

Centralized impoundments are frequently used by drilling operators to hold vast quantities of hazardous fracking flowback and produced water generated by unconventional shale wells. Centralized impoundments differ from other types of impoundments by being associated solely with hazardous waste, as compared to freshwater dams, and by serving to hold waste from multiple wells and/or well pads in the area surrounding them.

Centralized Impoundment Permits

In order for an operator to build a centralized impoundment (CI) in Pennsylvania, they must apply for a Centralized Impoundment Permit. Parts of the permit application beyond basic operator, certification, and engineering information for the process include:
  • Permit application fee: An application fee which is determined by how high the proposed dam embankment will be.
  • Act 14 Notification: Essentially, this requires operators to inform the local and county governments that they want to build a CI at least 30 days before permits are issued and construction begins.
  • Cultural Resource Notice: Requires operators to inform the Natural Heritage Program of their intentions, in the case where the impoundment may be near historic and/or archaeological sites.
  • PNDI Search Receipt: This checks that operators complete a Pennsylvania Natural Diversity Inventory (PNDI) before construction. This is of particular importance if the proposed site is in a state or national natural area.
  • Color Photographs: Photos which clearly illustrate the area watercourses, wetlands, and current water conditions.
  • ESCGP-2: Another type of permit, this stands for Erosion and Sedimentation Control Plan.
  • Maps, Plans, Profiles, and Cross-Sections
  • Impacts from Dam Failure: This is an estimate of what the impacts and damages could be if the well were to break, with attention to houses, roads, serious property damage, and other human structures.
  • Groundwater Protection Requirements: Verifies operators know the impoundments must be lined with impermeable membranes (at least 40 mils thick), and requires a working leakage detection system and working groundwater monitoring system be installed.[2]

Notable Lawsuits and Spills

Known Pennsylvania Centralized Impoundments

Summary of Results
There have been 53 recorded Centralized Impoundment permits submitted since 2009, when the records start. Of those 53, 29 of them were formally issued. Of the remaining, 3 of them were returned, 7 are currently pending, and 14 of them were withdrawn. RANGE RESOURCES APPALACHIA LLC has submitted the most total CI permits, though Range also has the largest number of withdrawn permits. CNX GAS CO LLC has the most issued + pending permits, and has no withdrawn permits. A majority of CI's are located in Washington County, though there are several in Susquehanna County and other area counties as well.
PA Centralized Impoundments Table
Notes on Compilation of PA Centralized Impoundments Table
The data from this table comes primarily from the PA DEP "eFacts" website. To locate this data, go to the eFacts search tool, and do an Authorization Search with "Centralized Impoundment permit," "New," and "Oil & Gas" selected.
Other data in the table comes from the Pennsylvania Bulletin, published by the Commonwealth of Pennsylvania. To locate this data, go to their search tool and enter "Centralized impoundment" in the search box. Data taken from the PABulletin includes geocoordinates, wells serviced (when information was available), and volume (when information was available). Interestingly, the PABulletin only included data for roughly half the wells mentioned in the eFacts guide. The reason for this discrepancy is unknown.
When constructing this table, 51 of the CI's were located with the eFacts tool. The final two were found in the PABulletin. The lack of overlap is explained by the nature of the permit applications--the final two were requests to convert existing freshwater impoundments into centralized impoundments, and so did not show up in the "new" category of eFacts authorizations.
This table was compiled by user crenee on June 12th, 2014.

References

  1. ENVIRONMENTAL QUALITY BOARD (14 December 2013). "Environmental Protection Performance Standards at Oil and Gas Well Sites". Proposed Legislation (25 PA. CODE CH. 78 : PA DEP). Retrieved 12 June 2014. 
  2. Bureau of Waterways Engineering and Wetlands, Office of Oil and Gas Management (Nov. 2013). "Application Instructions for a Dam Permit for a Centralized Impoundment Dam for Oil and Gas Operations". 8000-PM-OOGM0084 (Commonwealth of Pennsylvania Department of Environmental Protection).  Check date values in: |date= (help)Category:CS1 errors: dates