List of Approved Modular Aboveground Storage Structures for Unconventional Well Sites

In addition to the current process for an operator to get a specific design for Modular Aboveground Storage Structure (MASS) approved using the Request for Approval of Alternate Waste Management Practices form (8000-PM-OOGM0071AU), the Department has developed a list of approved MASSs to allow operators to seek approval for use of any prior-approved MASSs on the list with a Request for Approval of Previously Approved Alternate Waste Management Practices form (8000-PM-OOGM0071BU). However, the operator will be attesting in their Request for Approval of Previously Approved Alternate Waste Management Practices form submission that the design and materials associated with the already-approved MASS will be followed in its entirety. If the operator submitting a Request for Approval of Previously Approved Alternate Waste Management Practices form cannot attest that this is the case, they will be required to submit a Request for Approval of Alternate Waste Management Practices form to account for any deviations from the initial design of the previously approved MASS. Deviations for auxiliary equipment may be approved upon review (e.g., high water level alarms, inflow apparatus, pumps).

Click here for a list of approved MASSs posted on the Office of Oil & Gas’ Informational Resources webpage that successfully went through the initial Request for Approval of Alternate Waste Management Practices (OG-71AU form) process for temporary storage.

Any operator may submit an OG-71BU form requesting to use an already approved MASS that is on the approved MASS list. However, the operator will be attesting in their OG-71BU form submission that the MASS design, liner materials and drain mechanisms proposed in the already-approved OG-71AU form will be followed in its entirety. When making such a request, the original eFACTS Authorization number (found on the approve MASS list) must be provided on the OG-71BU form, so the Department can cross reference the original MASS design and specifications that were previously approved.

Another option for MASSs that were approved prior to promulgation of Title 25 Pa. Code Chapter 78a on 10/6/2016, is for the operator to provide the Department with a copy of the original Request for Approval of Alternate Waste Management Practices authorization letter they received from the Department approving a specific design for a MASS. Department Oil and Gas staff will then retrieve the specifications that were approved and add the previously approved existing MASS to the list.

Industry Notices:

Act 537 Notice: The installation of a holding tank at a temporary construction/work-site with movable trailers, including permitted gas and/or oil well drilling pad sites, for the purpose of collecting blackwater and/or greywater (from toilets and sinks, respectively), requires a permit issued by the local municipality Sewage Enforcement Officer and/or multi-municipal agency. A holding tank ordinance incorporated into the municipality's "official plan" is a permit requirement. Please contact the regional DEP office covering the county in which the proposed work site is located for further information. All other structures and habitable trailer sites, such as "man camps," may require sewage facilities planning under the authority of the Act 537, Pennsylvania Sewage Facilities Act, prior to installation. Please contact the regional DEP office covering the county in which the proposed site is located for further information.

Recommended Practices Concerning Horizontal Directional Drilling Additives

Additives used in horizontal directional drilling (HDD) may not be used in a manner that causes pollution or a threat of pollution to the waters of the Commonwealth. HDD additives which are certified for conformance with NSF/ANSI Standard 60 (Drinking Water Treatment Chemicals - Health Effects) with a product function of drilling fluid are deemed acceptable to DEP, when used in the manner indicated in the certification of the additive. All conditions included as part of the additive's certification should be followed.

You may view a current listing of certified drilling fluids maintained by NSF on its website. Use of drilling additives certified for conformance with NSF/ANSI Standard 60 (Drinking Water Treatment Chemicals - Health Effects) with a product function of drilling fluid does not relieve operators from the requirement to obtain the necessary permits to conduct HDD operations. Use of certified additives does not relieve the operator of liability should an inadvertent return or other pollution of the waters of the Commonwealth occur as a result of drilling operations.

Any products not currently listed on the NSF/ANSI Standard 60 (Drinking Water Treatment Chemicals - Health Effects) with a product function of drilling fluid may be submitted to DEP for review. To request a review of an unlisted product, please submit a Safety Data Sheet (SDS) for the product to RA-epOilandGas@pa.gov. The SDS must list the product's common name and Chemical Abstracts Service Registry Number for a review to occur.

Below is a list of Safety Data Sheets for products that were reviewed and approved by DEP to be used as drilling fluid additives for HDD.

Safety Data Sheets - Approved HDD Additives

Act 9 Regulations

On Jan. 26, 2013, the Department published as final a rulemaking to incorporate regulations from Act 9 of 2012. The Act required DEP to develop regulations concerning emergency response requirements at well sites.

Information and Resources:

Technical Guidance Documents:

Links to other organizations and agencies:

Chapter 78 regulations (78.18) require two permits for any disposal or enhanced recovery well operating in Pennsylvania. Initially, since Pennsylvania does not have primacy to directly permit underground injection wells, applicants must first submit a well permit application and required documentation to the United States Environmental Protection Agency (EPA).

Upon issuance of a permit from EPA, applicants must then obtain a well permit from the Department under Chapter 78.11. If the well is an existing well, the department would re-issue the permit as an injection well with special conditions granting authority under the Solid Waste Management Act and the Clean Streams Law.

If the application is for a well that does not yet exist, the applicant must submit an application to the department for a new well. In all cases, the applicant must submit to the Department, in addition to the DEP permit application, a site-specific Erosion and Sedimentation Plan, a Control and Disposal Plan, and a copy of the EPA Underground Injection Control (UIC) permit.