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Thank you for the opportunity to submit comments on the proposed regulations for oil and gas surface activities (amendments to 25 Pa. Code Chapter 78, Subchapter C). Because Pennsylvania’s regulatory framework should have been updated and strengthened several years ago—before the state’s shale gas boom began—there is no time to waste in doing so now.

Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the impacts of mineral and energy development while seeking sustainable solutions. For more than two decades, we’ve worked to advance policy reforms, improve corporate practices, and safeguard land and public health. The Oil & Gas Accountability Project of Earthworks works with local communities, partner organizations, public agencies, and elected officials to advance these goals nationwide, including across Pennsylvania.

Earthworks is pleased to have contributed and signed on to the extensive technical comments on the proposed revisions to Chapter 78 submitted by Earthjustice. In the following pages, we submit additional comments that focus on a critical aspect of oil and gas regulations: the handling, processing, and disposal of solid and liquid waste.

The rapidly growing volume of waste resulting from the shale gas boom poses a significant risk to environmental quality and the health of both people and wildlife. Oil and gas field waste can be contaminated with chemicals, oil, heavy metals, naturally occurring radioactive material (NORM), and a range of other toxic and polluting substances.

Marcellus Shale operators reported a 70 percent increase in wastewater generated just between 2010 and 2011, when the volume reached 613 million gallons.[i] Not surprisingly, the industry is constantly seeking new methods and locations to dispose of the waste it produces. In the last few years, the Pennsylvania Department of Environmental Protection (DEP) has received permit applications to conduct Research & Development for the creation of new products from gas field waste, for example construction materials made from drill cuttings.[ii] Last summer, a shipment of highly radioactive waste produced in Pennsylvania had to be trucked to a specialized facility in Idaho, since the operator failed to find a proper disposal option anywhere in the Commonwealth or the surrounding region.[iii]

Such challenges are the direct result of the industry’s insistence on forging ahead with more and more drilling before appropriate waste management practices could be determined and established. The DEP and the Environmental Quality Board (EQB) have both the responsibility and the authority to stop allowing industry’s problems and preferences to take precedence over the protection of residents and the environment from exposure to dangerous substances—and to do so before the impacts associated with oil and gas field waste become insurmountable. 

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