Ohio Waste Treatment Facilities Charged with Clean Water Act Violations

“The centralized waste treatment plant owned and operated by Patriot Water Treatment LLC and the city of Warren’s publicly-owned wastewater treatment plant in Trumbull County (Ohio) were sued by the FreshWater Accountability Project (www.FWAP.org) for significant and ongoing violations of the Clean Water Act. Fair Shake Environmental Legal Services (www.fairshake-els.org) brought the lawsuit on behalf of FreshWater Accountability Project through the Citizen Suit provision of the Clean Water Act that allows “any citizen” to “commence a civil action on his own behalf…against any person…who is alleged to be in violation of (A) an effluent standard or limitation under ⦋the Act⦌ or (B) an order issued by the Administrator or a State with respect to such a standard or limitation.”

It appears that the pretreatment standards may have not been meet and there is a question if the proper wastewater treatment assessments or wastewater characterization were conducted as part of an Industrial Pretreatment Permit.   I am not sure if the issue of “were not carried out to protect public health and safety or the bio-accumulative impact ”  is a real issue, because it would depend on the nature of the contaminant and potential to exposure.  With respect to radiological parameters radon half life is about 3 days and most radium and uranium would likely be bound to sludge and solids, so monitoring of the waste sludge would be a big concern.   No matter what – proper waste characterization and treatability studies should always be conducted.

Read more at http://fwap.org/ohio-waste-treatment-facilities-charged-with-clean-water-act-violations/

Lawyers –  lawsuit can be accessed at http://fwap.org/wp-content/uploads/2017/06/Time-Stamped-FWAP-v.-Patriot-Water-Treatment-et-al.-Complaint.pdf


“Fracking” Environmental Consequences

Protecting People Against Terrorist Attacks: Chemical, Biological, and Radiological (CBR) Threat Protection
Ethical Decision Making Webcast

Training Professionals – Career Training 

Ben Franklin’s SGICC Releases Updated Study Summarizing Shale Gas Wastewater Treatment and Disposal

Ben Franklin’s SGICC Releases Updated Study Summarizing Shale Gas Wastewater Treatment and Disposal in Pennsylvania in 2014

 STATE COLLEGE, PA – In 2012 the Ben Franklin Shale Gas Innovation & Commercialization Center (www.sgicc.org) commissioned a study on the status of wastewater being produced in the Commonwealth of Pennsylvania.  Now, three years later, SGICC is updating the report, not only because of the slowdown in the drilling process across the Commonwealth, but also due to the rapid change the shale industry has made in management techniques for the wastewater from shale gas and NGL extraction. See the new 2015 report, as well as the 2012 version, on the SGICC web site at http://www.sgicc.org/research–reports.html.

SGICC hired Wunz Associates, LLC to undertake the study as a follow up to their 2012 effort. An exhaustive search of the Pennsylvania Department of Environmental Protection (PADEP) wastewater reporting records was undertaken, coupled with discussions with leading companies treating the wastewater for the industry. In addition to posting the Wunz Associate report at the link above, a second report generated by Eureka Resources, LLC regarding their Standing Stone treatment facility operations in Bradford County, PA and published in SPE International in 2015 is also available.

The most significant finding in the 2015 Wunz report is that volumes classified as “produced water” exceeded those classified as “frac fluid” in 2014.  Bill Hall, SGICC Director notes, “This has occurred largely due to the slowdown in drilling and fracturing of wells by the industry and could reverse again in the future when natural gas and NGL prices rebound and drilling picks up again. Additionally, the amount of produced water is likely to decline over time since it is generated in proportion to the amount of gas or NGLs a well is producing, and that tends to drop off fairly rapidly after the initial years of production.”

Hall also stressed that the majority of the wastewater generated as both “produced” and “frac fluid” are recycled by the industry. In fact, the PADEP records indicate that over 91% of the water is recycled by being used in a future completions project. Recycling is typically done after the water is partially treated to remove solids and other unneeded constituents.

“There may be a point in the future where total frac flowback fluid and produced water volumes do exceed the total volume of water used to fracture wells in the state. But that point has not been reached yet,” noted Hall. “The industry continues to look for innovations in the area of shale wastewater treatment and disposal to address future challenges.”

Online Training Courses

Hydraulic Fracturing (Fracking) – Environmental Issues
Hydraulic Fracturing – The Process
Industrial Water Treatment  and Underground Injection Control
Comprehensive – Petrochemical – Shale Gas Course

Ohio Announces Tougher Permit Conditions for Drilling Activities Near Faults and Areas of Seismic Activity

Ohio Announces Tougher Permit Conditions for Drilling Activities Near Faults and Areas of Seismic Activity

4/11/2014 Oil & Gas – Source- http://oilandgas.ohiodnr.gov/oil-gas-home/post/ohio-announces-tougher-permit-conditions-for-drilling-activities-near-faults-and-areas-of-seismic-activity

“Ohio Announces Tougher Permit Conditions for Drilling Activities Near Faults and Areas of Seismic ActivityOhio Department of Natural Resources (ODNR) Director James Zehringer announced new, stronger permit conditions for drilling near faults or areas of past seismic activity. The new policies are in response to recent seismic events in Poland Township (Mahoning County) that show a probable connection to hydraulic fracturing near a previously unknown microfault.New permits issued by ODNR for horizontal drilling within 3 miles of a known fault or area of seismic activity greater than a 2.0 magnitude would require companies to install sensitive seismic monitors. If those monitors detect a seismic event in excess of 1.0 magnitude, activities would pause while the cause is investigated. If the investigation reveals a probable connection to the hydraulic fracturing process, all well completion operations will be suspended. ODNR will develop new criteria and permit conditions for new applications in light of this change in policy. The department will also review previously issued permits that have not been drilled.“While we can never be 100 percent sure that drilling activities are connected to a seismic event, caution dictates that we take these new steps to protect human health, safety and the environment,” said Zehringer. “Not only will this reasonable course of action help to ensure public health and safety but it will also help us to expand our underground maps and provide more information about all types of seismicity in Ohio.”“ODNR’s directives are a sensible response to a serious issue that regulators across the country are closely examining,” said Gerry Baker, Associate Executive Director of the Interstate Oil and Gas Compact Commission. “IOGCC is pleased to work with Ohio and other states to share scientific data to better understand the nature of these occurrences.”

“These additional standards add even more strength to Ohio’s already comprehensive regulatory program,” said Mike Paque, Executive Director of the Groundwater Protection Council. “State regulators are taking an aggressive lead in tackling tough and complicated oil and gas issues and ODNR is no exception.”

More than 800 wells have been drilled in Ohio’s Utica and Marcellus shale play, including as many as 16,000 hydraulic fracturing stages from those wells. Regarding the seismic events in Poland Township, Mahoning County, ODNR geologists believe the sand and water injected into the well during the hydraulic fracturing process may have increased pressure on an unknown microfault in the area. Further hydraulic fracturing at the site is suspended but the company will be permitted to recover resources from five of the previously drilled wells located on the pad. This is also expected to have the beneficial effect of reducing underground pressure and decreasing the likelihood of another seismic event.

Under ODNR’s lead, Ohio has joined a consortium of state regulators dedicated to learning more about seismic activity, especially as it relates to oil and gas activity. The members of this consortium are currently working with the Interstate Oil and Gas Compact Commission and Groundwater Protection Council to share information and knowledge. The working group also hopes to draw upon current and future research to develop common procedures for how to monitor for seismic activity and respond if activity occurs.

The Ohio Seismic Network, coordinated by ODNR and operated by various partners, began recording seismic events in 1999. Before that time, the recording of seismic events varied from distant machines and felt reports. Ohio has a history of seismic activity, and since the network has established, Ohio has experienced 109 events greater than 2.0 magnitude. Data from the Ohio Seismic Network will be used as part of our new application review process.

A map of underground seismic faults and past seismic events is available as a PDF documentoilandgas.ohiodnr.gov/portals/pdf/EG-2_2014_MAPONLY.pdf, and as a geographic information system Shape File http://apps.ohiodnr.gov/geodata/Statewide/Earthquake_shapes.exe.”

Earthquakes in Ohio and Seismic Risk

Seismic Risk – PA

Earthquake EpiCenters in PA

Map 69 – Earthquake Catalog PA

PAGIS Map – Earthquakes – Some Ohio Data

New Educational Resources / Training Programs

Crude Oil Origins – In this course we will discuss the formation of oil and review the theories of its origin. You will get comprehensive information about oil reservoirs including their structure, oil accumulation, as well as distribution, migration and transformation of reservoir fluids. We will cover classification and evaluation of reservoirs and estimation of fuel reserves. We will also review fuel reserves focusing on quality, quantity, patterns, and benefits. Drilling Techniques.

Shale Gas Development – The course provides an overview of modern shale gas development, as well as a summary of federal, state, and local regulations applicable to the natural gas production industry, and describes environmental considerations related to shale gas development. It describes the importance of shale gas in meeting the future energy needs of the United States including its role in alternative energy strategies and reducing greenhouse gas (GHG) emissions. The course is intended to serve as a technical summary document, including geologic information on the shale gas basins in the U.S. and the methods of shale gas development. By providing an overview of the regulatory framework and the environmental considerations associated with shale gas development, it will also help facilitate the minimization and mitigation of adverse environmental impacts. By so doing, the course can serve as an instrument to facilitate informed public discussions.

Environmental Concerns Hydraulic fracturing is done with surprising precision and with an eye on the environment, yet it is interesting how the public reacts to the practice in relation to other techniques used throughout the world. Valid points are made on both fronts. The major concern against fracking resides in the overall health and well-being of people close to a well site, as well as the land, water, and air that might be adversely affected. With proper examination and logic, this course was developed to provide insight and reason in a practice fueled by profit for some and by civil concern for others. We will explore the history, public and media perception, and environmental and economic impacts.

Comprehensive Course on Hydraulic Fracturing. Summary Course on Hydraulic Fracturing.

Go to http://webdesignpros.redvector.com

The online education courses are provided to help educate the community and professionals.  Courses are fee based, but a portion of the fee ultimately aids in groundwater education and outreach.    The portal also offers online training in renewables, biomass,  and other topics.


We seek new people at all skill levels for a variety of programs. One thing that everyone can do is attend meetings to share ideas on improving the Keystone Clean Water Team (CCGG Program), enabling us to better understand and address the concerns of well owners.  We look for people that can forward solid articles, help coordinate local education efforts, and more.  Become part of the Keystone Clean Water Team!.

Everything we do began with an idea.

We realize your time is precious and the world is hectic. CCGG’s volunteers do only what they’re comfortable with. It can be a little or a lot.  Get YOUR WATER Tested – Discounted Screening Tests !   Get educated on Drinking Water Quality in Pennsylvania.

For more information, please go to CCGG’s About Page or contact us.

Keystone Clean Water Team /Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.  The IRS Officially Approved Name change to the Keystone Clean Water Team by the IRS.  Unsolicited donations are appreciated (Helps us complete our mission).

Help the Organization and Get Your Water Tested or Order the Private Well Owner Guide (proceeds benefit This Organization).

Hydraulic Fracturing Defined Fracking Words Matter Debate on Energy, Environmental, Humans

The word fracking – First, I personally and professionally dislike the word for a number of reasons. First it is jargon and second it is industry slang.  The word lends itself to redefinition and misuse.

Definitions – We are defining slang terms?

1) frack·ing, noun \ˈfra-kiŋ\ the injection of fluid into shale beds at high pressure in order to free up petroleum resources (such as oil or natural gas)  (Source: http://grist.org/news/the-dictionary-finally-admits-fracking-is-here-to-stay/)

My comments – not a bad definition – but the process is called hydraulic fracturing – they miss the issue of the use of chemicals to change the characteristics of water to reduce friction loss and prevent bacterial growth.  Also – there  is no Freeing up of a resource – the process creates an artificial pathway that causes the fuel to escape through the pipe or borehole rather than taking millions of years to migrate up through the rock strata.  Also – does not indicate that the process is regulate under the EPA UIC Program under special cases.

2) Fracking is the process by which the oil and gas industry undermines the public right to safe drinking water, clean air and healthy communities by using toxic chemicals and large volumes of water to extract unsustainable fossil fuels from the earth for profit.(Source: Food & Water Watch – http://www.foodandwaterwatch.org/blogs/fracking-shows-its-viral-nature)

This is a great example of the lack of fact, but more about environmental spin doctors.  Now – this is not only an approach used by certain organizations.  Definition is more about a philsophical point than an actual definition that explains the process, but presents the potential things could happen.  The only part that is correct is “toxic chemicals are used”, “large volumes of water are used (but more is used to produce other sources of electricity), “extract fossil fuels”, “fossil fuels are not infinitely sustainable (but neither is any building or structure we build or even our cities), it does happen on earth, and it is done for a profit.  (Profit is not bad – non-profit organizations make a profit – they do not call it profit and this is a Capitalist society).   This definition tells you more about the Organization than the process.

3) Fracking – A slang term for hydraulic fracturing. Fracking refers to the procedure of creating fractures in rocks and rock formations by injecting fluid into cracks to force them further open. The larger fissures allow more oil and gas to flow out of the formation and into the wellbore, from where it can be extracted. (Source: http://www.investopedia.com/terms/f/fracking.asp)
Misses the mark related to the nature of the chemicals that are used and the use of a propent to hold the fractures open so the gas and oil can migrate out of the formation into the borehole or pipeline, i.e., the artificial low pressure point, and not up through thousands of feet of rock.  I do like they indicate it is a slang term and the proper term is hydraulic fracturing.  It is a procedure – it is part of a process – NOT the whole process.

4) Fracking is the process of drilling down into the earth before a high-pressure water mixture is directed at the rock to release the gas inside. Water, sand and chemicals are injected into the rock at high pressure which allows the gas to flow out to the head of the well.The process is carried out vertically or, more commonly, by drilling horizontally to the rock layer. The process can create new pathways to release gas or can be used to extend existing channels. (Source; http://www.bbc.com/news/uk-14432401)

It is a process Yes – no mention of the slang nature of the work and the correct term – hydraulic fracturing.  It is NOT a Drilling Process – this is JUST Wrong.  Yes – Water, sand and chemicals are injected.  Chemicals are toxic    The sentence starting – “the process …..”  Is Just Wrong !

5) Fracking, or hydraulic fracturing, is the process of extracting natural gas from shale rock layers deep within the earth. Fracking makes it possible to produce natural gas extraction in shale plays that were once unreachable with conventional technologies. Recent advancements in drilling technology have led to new man-made hydraulic fractures in shale plays that were once not available for exploration. In fact, three dimensional imaging helps scientists determine the precise locations for drilling. (Source: http://www.what-is-fracking.com/)

No mention it is a slang term- statement is true, but does it create a definition?  I do like the mention of the word recent.  Because it is the recent improvements in the process that makes this feasible.

6) Hydraulic Fracturing – a method of mining in which cracks are created in a type of rock called shale in order to obtain gas, oil, or other substances that are inside it (Source: http://www.macmillandictionary.com/us/dictionary/american/fracking)

Used the correct work – definition is clearly wrong.  The definition makes it sound like the old water mining techniques that were used in the 1800s to mine for gold by eroding mountains with high pressure water.

7)  fracking, fracking also spelled fracing or fraccing, also called hydrofracking, in full hydraulic fracturing,  in natural gas and petroleum production, the injection of a fluid at high pressure into an underground rock formation in order to open fissures and allow trapped gas or crude oil to flow through a pipe to a wellhead at the surface. Employed in combination with improved techniques for drilling horizontally through selected rock layers, hydraulic fracturing has opened up vast natural gas deposits in the United States. At the same time, the rapid rise of the practice, frequently in regions with no history of intensive oil and gas drilling, has raised concerns over its economic and environmental consequences.

Not a bad definition – lacks clarity on the nature of the fluid, but then goes on to add the “positive spin” of the Industry.  I do like the closing sentence – “The Rapid Rise” of the practice in areas with “no historic knowledge of the process” has created concerns that are economic and environmental.

If you are going to allow a definition to present a point – then – it would be appropriate to add to this “definition” at the end. These same individuals or communities did not care or were not concerned when these activities that produced fossil fuels for their consumption occurred in other communities or countries and these same communities were happy to develop in a manner that made them dependent on other communities to sustain themselves, i.e., NIMBY.

8. hydraulic fracturing – Also referred to as hydrofracking, hydrofracturing, and fracking, is a well development process that involves injecting water under high pressure into a bedrock formation via the well. This is intended to increase the size and extent of existing bedrock fractures.  (Thanks USGS- http://energy.usgs.gov/GeneralInfo/HelpfulResources/EnergyGlossary.aspx#h)

Not a great definition and the second sentence is misleading.

I do not like the term.  This term was the slang word used in the Batttlestar Galatica series as the “F” word – “Frac”.  This series was about an epic battle between man and machine.  NOW – it possible to view this change in energy production as a battle between big oil and humans- this is not the battle.  The battle is with us – We are the users, consumers, and wasters of this valuable resource that has been developed on this Earth over millions of years.  It is not renewable, but a high energy source that has powered the improvement of our health, safety, and welfare.  As our technology grows – we will develop new and more “renewable energy sources”, but we have to do our part to conserve energy and use it wisely.

My definition

1. Use the word – hydraulic fracturing and is one phase of an overall process.  The phases include drilling, installing protective casing, cementing, hydraulic fracturing, developing, and production.

2. Process that uses a slick water solution – This chemical solution is dangerous to handle and not suitable for consumption or direct contact without proper training and personal protective equipment.  The chemical solution is made up of 99.5 % water  that has been modified through the use of chemicals and other agents that prevent bacterial growth (i.e., biocide), dissolve carbonate scales (acids- HCL and citric acid), friction reduces (change the density of water – can be toxic- mineral oil, polyacrylamide (used in agriculture and soil stabilization potential health issue), corrosion inhibitors (n,n-dimethylformamide,  glycols (toxic)), surfactants (soaps/isopropanal),  gelling agents (gums/cellulose), crosslinkers (borate salts), breakers (ammonia persulfate), salts (KCL)  and propant (sand /ceramics)- Nice Image and Other Pdf.

An aside: The issue is not the chemicals used – but the potential for exposure – the primary exposure potential would be related to chemicals and releases in the environment during transport or surface storage and use.  The main defense would be controlling the movement of the chemicals into and through the community and the use of multiple containment systems for surface storage.  When the target formation is 3000 + feet below grade, the vertical migration of the fluid up to freshwater zones has an extremely low probability of occurrence.  Is it zero – NO, but the other pathways are more likely.

3. The fluid is injected under high pressure to overcome the weight of the material over the target formation.  Since the target formation is a shale, the shale has natural bedding plane fractures (looks like a book from the side), near vertical stress fractures, and curvilinear fractures associated with internal gas stress.  These fractures are not interconnected.  The hydraulic process aids in the parting of existing fractures, removing carbonate scales or coatings along bedding planes/fractures, and parting the formation enough to push sand or other proppant into this location to hold the fractures apart.  This stabilized pathway permits the gas and/or oil to escape at the lowest point of pressure, i.e., the casing and borehole that were constructed during the drilling phase.

This is a work in progress.  We would suggest viewing the following websites:

Private Well Owners Guide – http://www.private-well-owner.org
Links to presentations on water quality issues, movies/videos on well drilling, hydraulic fracturing, and gas production.   Movies and information about problems- Methane gas migration, loose of circulation, chemical changes, spills, and the need for changes in oil and gas law.


We seek new people at all skill levels for a variety of programs. One thing that everyone can do is attend meetings to share ideas on improving the Keystone Clean Water Team (CCGG Program), enabling us to better understand and address the concerns of well owners.  We look for people that can forward solid articles, help coordinate local education efforts, and more.  Become part of the Keystone Clean Water Team!.

Everything we do began with an idea.

We realize your time is precious and the world is hectic. CCGG’s volunteers do only what they’re comfortable with. It can be a little or a lot.  Get YOUR WATER Tested – Discounted Screening Tests !   Get educated on Drinking Water Quality in Pennsylvania.

For more information, please go to KCWT’s About Page, Brochure,  or contact us.

Keystone Clean Water Team /Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.  The IRS Officially Approved Name change to the Keystone Clean Water Team by the IRS.  Unsolicited donations are appreciated (Helps us complete our mission).

Help the Organization and Get Your Water Tested or Order the Private Well Owner Guide (proceeds benefit This Organization).





Methane in Groundwater in Pennsylvania – Published Report

Journal Article Evaluates Methane Sources in Groundwater in Pennsylvania— Opponents of shale development have pointed to cases of alleged methane contamination of water wells in northeastern Pennsylvania as evidence of hydraulic fracturing contaminating water. A new study in the journal “Groundwater” suggests that naturally-occurring methane is ubiquitous in northeastern Pennsylvania as the region’s groundwater is contained in a hydrocarbon bearing rock that is interspersed with water wells that lack structural integrity (Carbon County Groundwater Guardians Support this Effort) of the private water well construction standards bill discussed above).  Additional information can be found via the following link:


If you are in Pennsylvania, you can contribute to the Citizen Groundwater Database and help track change for FREE and if you would like to learn about our Natural Gas Related Information, please visit us at http://www.private-well-owner.org

We seek new people at all skill levels for a variety of programs. One thing that everyone can do is attend meetings to share ideas on improving CCGG, enabling us to better understand and address the concerns of well owners.

Everything we do began with an idea.

We realize your time is precious and the world is hectic. CCGG’s volunteers do only what they’re comfortable with. It can be a little or a lot.

For more information, please go to CCGG’s About Page or contact us.

Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.

High Arsenic Levels Well Water Testing Found in 8 Percent of Groundwater Wells Studied in Pennsylvania

The Need for Well Water Testing In Pennsylvania and other states

NEW CUMBERLAND, Pa. – Eight percent of more than 5,000 wells tested across Pennsylvania contain groundwater with levels of arsenic at or above federal standards set for public drinking water, while an additional 12 percent – though not exceeding standards – show elevated levels of arsenic. 

These findings, along with maps depicting areas in the state most likely to have elevated levels of arsenic in groundwater, are part of a recently released U.S. Geological Survey study done in cooperation with the Pennsylvania Departments of Health and Environmental Protection.

The results highlight the importance of private well owners testing and potentially treating their water.  While public water supplies are treated to ensure that water reaching the tap of households meets federal drinking water standards, private wells are unregulated in Pennsylvania, and owners are responsible for testing and treating their own water.

For this study, USGS scientists compiled data collected between 1969 and 2007 from industrial, public, and private wells. Arsenic levels, along with other groundwater quality and environmental factors, were used to generate statewide and regional maps that predict the probability of elevated arsenic.   The study examined groundwater from carbonate, crystalline, and shale/sandstone bedrock aquifers, and from shallow glacial sediment aquifers. Similar maps have been produced for other states.

“This research is not intended to predict arsenic levels for individual wells; its purpose is to predict the probability of elevated levels of arsenic in groundwater to help public health efforts in Pennsylvania,” said USGS scientist Eliza Gross, who led the study.  “The study results and associated probability maps provide water-resource managers and health officials with useful data as they consider management actions in areas where groundwater is most likely to contain elevated levels of arsenic.”

For more details go here (Some mapping available)

The Pennsylvania Department of Health plans to use the maps as an educational tool to inform health professionals and citizens of the Commonwealth about the possibility of elevated arsenic in drinking water wells and to help improve the health of residents, particularly in rural communities.  Please consider forward you certified testing data to the Citizens Groundwater Database.

Private well owners can find testing and other information on Pennsylvania Department of Environmental Protection Arsenic in Drinking Water website.

or Check out the Arsenic Outreach Program here – Has links to treatment options and low cost informational water testing.


Website Provided for Educational Purpose.

Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.

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Pennsylvania May Use Coal Mine Water for Hydraulic Fracturing Senate Bill 411



Mine water for beneficial uses.–Notwithstanding any other provision of this chapter, landowners, mine operators and water pollution abatement project operators that are involved in treating mine drainage or mine pool water from a permitted mining activity site or water pollution abatement project shall not be deemed to assume legal responsibility for or to incur liability with respect to a cost, injury or damage that arises out of or occurs in connection with the use of mine drainage, mine pool water or treated mine water in connection with the hydraulic fracturing process or other development of a gas well, industrial or other water supply or other beneficial use of the water


Comments by Brian Oram

1. This may have some conflicting language when compared to the Oil and Gas Law and the assume liability that is associated with natural gas development. I may have missed this section, but it would be nice if the law clearly stated this did not resend current provisions and assumed liability related to exiting  Oil and Gas Law.

It does appears the assumed liability provision is limited to only the “Project Operators”- so that once the mine water leaves the site (i.e., the site where the mine water is collected or initially treated) – they, the Project Operators are no longer assumed liable for other uses beyond their control, i.e., liable for the use of the water by the Gas Company for Hydrofracturing.  (Clarification is needed)

A. Land-owner has mine drainage on the property- they or a third party – treat the mine water and then sell or give away to a water company.
B. The water is transported to a site.
C. Industry uses the water for hydraulic fracturing. 

Think the the limit of liability is intended to only extend to A related to conyence by B and the use by C   This type of liability provision is needed because many of the parties that fit the role of A are either 501 c3, watershed groups or public private partnerships that have nothing to do with the gas company.

2. This may require baseline testing be done in these regions to include additional parameters specific to the source and around treatment project sites.
3. It is possible this may result in decreased streamflows downgradient of withdrawal points – I am not sure how the river basin commissions will evaluate and if they may consider the need for a water withdrawal permit and consumption use fees, but I would assume a consumptive water use docket with provisions for treatment and by-pass flow maybe needed.

4. I like the provisions and hopefully this will more forward the use of degraded waters for hydraulic fracturing and help clean up impacted waterways in PA.

5. I do like the provisions, but for some streams baseflow associated with mine drainage may be a significant portion of the flow and it maybe necessary to maintain some by-pass flow with treatment.

6. Hope this encourages public private partnerships to address Acid mine drainage and mine drainage.

7. Would be nice if this program could be applied indirectly to the Northern Fields –No Gas Development, but it would be great to treat and clean the mine drainage and then issue some type of credit.

8. The law looks like it could be applied to discharges and releases of brine water associated with historic oil and gas development and not just mine drainage?  (Clarification is needed)

9. I am not sure of the eligible land provision? Unless this relates to building some type of treatment structure, etc (Water pollution abatement project operator).  (Clarification is needed)

10. The exemptions near the end of the document seem reasonable – I would assume this came from Senator Yaw – Very Nice.

11. I would recommend the Senators that support this document make the necessary clarifications of the intent, but this is something that is needed.  I think this would have been a better approach then all the press releases on the topic. The goal should be to fix issues and get them resolved.   

Additional Comments
Mine Drainage and/ or Acid Mine Drainage is the result of natural discharges and legacy issues related to the mining of the anthracite and bituminous fields in Pennsylvania.

Over 4,000 miles of streams in Pennsylvania are adversely impacted by mine and/or acid mine drainage. The most cost effective treatment approaches of these problems tend to be a mixture of land-reclamation and passive treatment systems. Many watershed groups and other organizations in Pennsylvania have been active in attempting to minimize the adverse impacts of mine drainage. One main limitation to the effective management and control of these discharges is the significant capital investment to implement the reclamation process and install the passive or semi-passive remediation system, but the largest hurdle is typically the long-term cost of maintaining these systems and liability that is associated with the operations and maintenance of these systems. The Senate Bill creates an opportunity for public and private partnerships to cover the initial cost for the installation of a more rapid and active treatment system and there is then the opportunity to put in place long-term funding for a passive treatment approach.
The Senate Bill has some key liability provisions. These provisions appear to be:
1. Provisions granted to the landowners and operators of the treatment system so they are no liable for the conveyance and ultimate use of the water. This is critical, because a watershed group or small business that is treating the water only and not hauling should not be liable for the conveyance and final use. This liability should rest with the individuals and companies that are transporting and using this water.

2. The proposed bill provides limits of liability associated with downgradient stream conditions. This provision is needed because it is possible that augmenting the flow of the stream by removing mine drainage will likely decrease water levels and flow volumes, but should eliminate the long-term pollution source. Even though it is not stated in this Senate Bill, it is likely that the river basin commission would play a significant role in reviewing consumptive use permits and may require a baseflow of treated water to maintain stream temperature and flow.

Some missing parts

The bill does require more context and specific language; because it appears the bill will extend to historic oil and natural gas development areas. Therefore, it is possible that some of the sites are releasing water that contains a mixture of brine, heavy oil residues, and other fugitive emission.

The bill may not address the status of the “sludge” generated by the remediation efforts. Does this sludge have a beneficial use or is it classified as a solid waste?

The bill does not address the issue of the need for a water withdrawal permit if the water is used for a consumptive water use
There needs to be a balance on the amount of withdrawal because in special cases excess water withdrawal may induce significant surface and subsurface impacts, such as subsidence and mine fire propagation.
This activity should not be conducted in combination with efforts to produce coal-bed methane gas.

Missing provisions for bonding.


Support Groundwater Education in Pennsylvania and Consider Scheduling an Education Workshop for Your Community – just email bfenviro@ptd.net

Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.

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Using Nitrogen and other Gases to Hydraulicly Fracture Black Shale Fields

“Typically, nitrogen is delivered to the well site as a refrigerated liquid that is gasified prior to injection and then is injected into the well to enhance recovery.  As the primary component of the air we breathe, the benefits of nitrogen include it being inert, environmentally friendly, non-flammable, and when gasified, exhibiting very low densities with large expansion factors. These properties make nitrogen the perfect choice for safely and efficiently tackling the toughest well needs.”

Interesting Links

Ferus Website on Nitrogen
Superior Well Services- B.F. Environmental (Nitrogen Gas Frac Library)
Gas Frac B.F. Environmental (Nitrogen Gas Frac Library)
EPA Report on Types of Hydraulic Fracturing Fluids
Information on FracWater Chemistry and Flowback Water

Website Provided for Educational Purpose.

Carbon County Groundwater Guardians is a 501(c)(3) IRS approved nonprofit, volunteer organization and your donation is tax deductible to the extent allowed by law.

 Carbon County Groundwater Guardians on Facebook

Fact Sheet: Methane Gas Migration and Mitigation

Methane gas has been a “hidden” problem in Northeastern Pennsylvania.  The gas is typically associated with wetlands, bogs, landfills, coal-producing formations, natural saline seeps, some glacial deposits, and gas storage areas.  Because of the development of the Marcellus Shale, the presence of methane gas and the potential for methane gas migration is a growing concern.   Methane is a colorless, odorless gas that is lighter than air.   Natural gas is mostly methane (70 – 90 % CH4), carbon dioxide (0 to 8 % CO2), plus other gases.  The other gases may include ethane (C2H6), propane (C3H8), butane (C4H10), and hydrogen sulfide (H2S) as well as small amounts of helium.

Methane gas is highly flammable between a lower explosion limit (LEL) of 5.53 percent by volume in air and an upper explosion limit (UEL) of 15 percent.  These percentages are equivalent to a methane concentration of 50,000 and 150,000 parts per million (ppm) in air.  The minimum concentration level at which the gas has the potential to explode is called the lower explosive limit (LEL); below the LEL level there is not enough gas to cause an explosion.  Above the UEL, there is inadequate oxygen to fuel combustion, but if the space is vented and the gas concentration drops below the UEL, the gas can become diluted enough to explode (it would require an ignition source).  Methane is not considered toxic, but it is an asphyxiant at a concentration of over 50 percent in air (it displaces oxygen).  Therefore, the primary risks for methane would be asphyxiation in a confined or poorly vented area or a potential explosion hazard.   As a safety measure, the natural gas industry adds mercaptans to the produced methane gas that enters the pipeline and your home. The mercaptans produce a very pungent odor so that gas leaks will be noticed, but unprocessed methane gas tends to have NO ODOR.  It is critical to note that some unprocessed methane gas may contain long chain hydrocarbon molecules that can create an odor.

From the available data in the Citizen Groundwater/Surfacewater Database, it would appear that the natural background level of methane in private wells in Northeastern Pennsylvania ranges from not detectable or trace levels to over 28 mg/L.  You may suspect the presence of methane gas in your water if you hear a “gurgling noise”, sputtering at the tap, the water has a lot of gas bubbles, is effervescent or fizzy.  

Note: If the pumping level of water in your well starts to fall below your pump intake, ordinary air may mix with the water and produce similar symptoms. When in doubt, contact a professional to determine the nature of the observed gas.

For more on this topic – Methane Gas Migration
Citizen Groundwater and Surfacewater Database

REMINDER – water webinar January 30 on baseline water testing for gas drilling

Bryan Swistock  <brs@psu.edu>

The next webinar in our Water Resources series will be Wednesday, January 30, 2013 from noon to 1 PM (EST). More details below. Hope you can join us!

When: Wednesday January 30, 2013 from noon to 1 PM
Topic: A Study of Pre-Drilling Groundwater Quality in 700 Water Wells and Springs in North Central Pennsylvania
Speaker: Jim Clark, Water Resources Extension Educator, Penn State Extension, McKean County
Where: The live webinar can be viewed at https://meeting.psu.edu/water1

Webinar Description:
Jim Clark, a Penn State Extension Water Resources Extension Educator based in McKean County, PA, will discuss the results of a study of approximately 700 private drinking water supplies covering eight counties in North Central Pennsylvania. Clark has been a Penn State Extension Educator for 24 years and has completed private water supply testing projects in McKean County in 2006 and Cameron County in 2011. This current water testing effort was administered by the Headwaters Resource Conservation and Development Council and the Clearfield County Conservation District. A grant from the Colcum Foundation funded the project. The Penn State Extension Water Resources Team partnered to offer a Water Test Report Interpretation Workshop in each of the eight participating counties and offered individual consultations for many of the private water supply owners who participated in the study. The combined workshop evaluation results and the results for the 21 parameters tested on the private water supplies will be shared and discussed.

About the Presenter:
Jim Clark is a native of Elmira, New York. He holds an Associate Degree in Animal Husbandry from Alfred State College and a Bachelor of Science and Masters in Arts and Teaching from Cornell University. He has been an Extension Educator with Penn State Extension since July of 1989, based in McKean County, Pennsylvania. He is Co Chair of the Penn State Water Resources Team.”

How to Participate
The live webinar will occur from noon to 1 PM and is accessible at: https://meeting.psu.edu/water1
You can access this webinar simply by signing in as a “guest”.
Taped versions of each webinar in the series are available at: http://extension.psu.edu/water/webinar-series/past-webinars
If you have not registered for past water webinars, please visit the following website to register so we can keep you updated about future webinar offerings: http://extension.psu.edu/water/webinar-series/schedule/registration.
If this will be your first webinar, you may want to test your
computer and internet connection for compatibility at:

Additonal Upcoming Webinars
Additional webinars on various water resources topics will be offered each month – generally on the last Wednesday of the month. A full schedule of webinars for the next 12 months can be found at: http://extension.psu.edu/water/webinar-series/schedule.

The February webinar will be offered on 2/27/13 at noon on Innovations in Youth Water Education by Jennifer Fetter, Water Resources Educator, Penn State Extension, Dauphin County.

Please pass this along to anyone that might be interested in attending these webinars.

Other Training and Presentations  on Common Water Quality Problems and baseline water testing.