Dear Friend, Range Resources has applied to construct and operate a large fracking wastewater tank farm in Hanover Township, on the border of Beaver and Washington Counties. There are many troubling aspects of this application that raise serious concerns and the Pennsylvania Department of Environmental Protection (DEP) has already identified significant shortcomings in the application. One of the most concerning issues is the complete lack of communication between Range Resources and the Beaver County government. In its application, Range Resources consistently ignores that Beaver County has a local planning commission, a comprehensive plan and an Act 167 stormwater management plan. When asked about the existence of these commissions and plans in the permit application, Range Resources left all answers blank, demonstrating a clear unwillingness to work with local government. The Beaver County Comprehensive Plan lists “abundant farmland, unspoiled natural places, and recreational land” as among the region’s “significant strengths.” This application would reduce all of those strengths. Range Resources also presented outdated wastewater testing data in its application to DEP. This application to construct twenty 11,025-gallon fracking wastewater storage tanks claims that because it will only be receiving waste from other Range Resources drilling operations, it will not be testing wastewater entering the facility. This is alarming in its own right, but even more concerning because, in its application, Range Resources presented two outdated wastewater testing reports from 2009 and 2013. In order to store a maximum of 220,550 gallons of fracking wastewater, Range Resources should be required to conduct more recent testing of its generated wastewater in the region, especially for radiation. Naturally occurring and “technically enhanced naturally occurring” radiation deep beneath the earth’s surface is highly irregular and can contaminate drilling fluids. Because of this danger, Range Resources should be made to both test the wastewater entering this proposed tank farm and increase radiation testing at its well sites. Range Resources bizarrely claims that the additional 552 truck trips per day at the proposed Hanover Tank Pad will somehow reduce truck traffic in the region because the existence of this tank farm will allow nearby gas well sites to reduce truck traffic associated with the movement of fracking wastewater. Range Resources has not identified the nearby facilities it is referencing. To assume that this facility will reduce truck traffic at other facilities is counterintuitive speculation and should not be taken into consideration by DEP. Similarly, Range Resources appropriately describes how it will collect all gathered stormwater and store it in the 20 proposed tanks to be treated or reused in the future. However, the application does not explain how this will impact planned operations at the site, specifically how storing collected stormwater will impact the drilling fluid storage capacity. Range Resources should be required to explain what the procedure will be if storage capacity is reached because of a precipitation event and where incoming drilling fluid will be stored in that event. This application is simply not detailed enough to warrant approval from DEP, which has already correctly pointed out several deficiencies in the application. Please tell DEP to continue to demand answers and explanations from Range Resources regarding this application. | |
Joseph Otis Minott, Esq.
Executive Director and Chief Counsel | |
