Susquehanna River Basin Commission – Water Withdraws – Fact Sheet Registration.

The Susquehanna River Basin Commission (Commission) is contacting you because you may have clients who are affected by a new program for registration of unapproved water withdrawals and consumptive water uses in the Basin.  We are seeking your assistance to help ensure that facility managers are aware of and complete registration by the deadline of December 31, 2019.

An initial contact letter and registration factsheet (GFregistration-grandfathered-water-withdraws-factsheet) was sent to more than 1,300 facilities by direct mail this week. The targeted grandfathered facilities/sources are those where water withdrawals or consumptive uses equal or exceed the regulatory thresholds, but began operating before the applicable regulations became effective. These water withdrawals and uses are generally considered to be exempt from obtaining a Commission docket, provided there has been no environmental harm and no changes are made at the facility.

The Commission has initiated the registration effort after reviewing the results of our Cumulative Water Use and Availability Study that highlighted major gaps in the data the Commission needs in order to effectively manage the water resources of the Basin.  We estimated that there are possibly more than 700 older, unpermitted facilities with an estimated water use of nearly one billion gallons per day. If accurate, this volume of water use is roughly equal to the total amount currently accounted for, and managed, by the Commission across the entire Basin.

Informational webinars explaining the registration program will be conducted by Commission staff on November 14 and December 13, 2017. To register for a webinar, visit

If you need additional information or assistance, visit the website or contact Commission staff at

Thank you,

Susquehanna River Basin Commission

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 ( for significant and ongoing violations of the Clean Water Act. Fair Shake Environmental Legal Services ( 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.


Lawyers –  lawsuit can be accessed at


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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 ( 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–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