Within all of Antero’s operational processes, best management practices are utilized to ensure responsible environmental stewardship.
Antero’s waste program is led by the Senior Environmental and Regulatory Manager of Midstream, Water and Waste. Special permits, mandates, and company responsibilities related to waste are developed at the corporate level. Waste program details, such as Standard Operating Procedures (SOPs), regulatory compliance, Safe Work Practices and vendor (e.g. supplier and contractors) audits, are developed at the field-level and approved at the corporate level to guarantee quality and consistency. The inclusion of field level operational staff promotes a well-balanced platform to monitor and regulate waste on a day-to-day basis.
The typical waste hierarchy involves four steps: Identification & Source Reduction, Recycle/Reuse, Treatment, and Disposal. Each department takes its own steps to eliminate, minimize or recycle their waste streams with oversight provided by Antero’s Environmental Department and data is collected and reported at the corporate level.
The waste hierarchy involves four steps;
Waste generated from all of Antero’s operations are characterized and managed according to their final destination. Antero waste streams are primarily treated, recycled, or disposed of within the Appalachian Basin; West Virginia (WV), Ohio (OH), and Pennsylvania (PA). Each state’s regulatory requirements dictate the organization and direction of the disposal process. The only instances whereby waste is disposed of outside of these three states has been for NORM/TENORM waste that exceeds the acceptance criteria for oil and gas waste as defined by State-specific regulations. These NORM/TENORM wastes are disposed of at approved facilities out of area.
All disposal facilities, regardless of waste type, must meet Antero’s environmental and regulatory compliance standards. Prior to use, facilities are pre-approved by performing regulatory record audits prior to onboarding, and their approval status is maintained by routine site visits and audits from Antero representatives.
Tracking waste from cradle to grave, regardless of operational origin and characterization, is the responsibility of Antero’s Environmental Department. Non-hazardous waste manifests are generated at the point of origin and signed by Antero representatives. Manifests identify the type and quantity of waste, transportation company, final disposal facility, and require signatures to identify the responsible parties. For production and flowback waters, “Bill of Lading” are used to track the same information as the non-hazardous waste manifest. Antero’s permanent facilities at well locations are equipped with electronic metering devices that send live data from the well sites to confirm wastewater volumes leaving the site. The non-hazardous waste manifests and Bills of Lading are returned to Antero when the disposal facility submits its invoices. These documents are filed within a database at Antero.
Antero’s HSSE Department has developed and implemented a safe work practice as part of Antero’s identification and management of NORM/TENORMs associated with our operations such as wastewater pit cleanouts and tank cleaning operations. The safe work practice requires Antero’s contractors and subcontractors who perform or supervise work-related functions involving NORM/TENORM on Antero’s assets to have a Radiation Protection Program (RPP) in place. At a minimum their RPP shall comply with worker and members of the public regulatory occupational dose limits, outline as low as reasonably achievable (ALARA) principles, and provide for audits to verify compliance. The level of NORM/TENORM is generally ascertained through either a dose rate survey of activity (uR/hr or mR/hr) or lab analytical samples of radionuclide concentration (pCi/g). Based on these results, Antero and our contractors will determine the most appropriate means of transport, treatment and/or disposal. In addition to the SWP, Antero maintains a Radiation Safety Officer (RSO) who is a trained, full-time employee who ensures radiation activities are performed safely and in accordance with regulatory requirements, ALARA principles, and Antero’s policies and procedures.
Antero’s waste streams associated with the exploration, development or production of natural gas are considered non-hazardous in accordance with EPA’s RCRA Exclusion for Oil and Gas E&P Waste. There are certain activities, such as production tank cleanings, that may cause waste to be classified as a hazardous material under current U.S. Department of Transportation (DOT) regulations. DOT Hazardous Materials require proper packaging, segregation, marking, labeling and placarding for the transport of the material, but does not dictate whether or not the material is a hazardous waste under RCRA regulations.
The above numbers do not include completions, production and water from activities such as frac tank, production tank and pit cleanouts and drillouts. Antero started tracking these waste totals in 2018 and will be reporting on them in the future. Antero does not incinerate our waste.