The first challenge is settlement talks are now going in an appeal brought by BCD Properties, Inc. to the Environmental Hearing Board on a DEP determination their ongoing road dumping of wastewater did not meet the co-product requirements of the Residual Waste Regulations.
The second challenge is the formation of a “Produced Water” Subcommittee made up of members of the Council and DEP that is tasked with coming up with recommendations on allowing road dumping and other possible disposal or reuse options for conventional wastewater.
The third challenge was brought up by a Council member who said an unnamed company contacted him saying it is working with DEP’s Northwest Regional Office to use water treatment technology covered by an NPDES water quality permit it thinks would allow the road dumping of the treated discharge.
DEP Supports Ban On Road Dumping
In June 2024, the Department of Environmental Protection told the House Environmental Committee it supports legislation to ban road dumping of conventional oil and gas wastewater.
DEP’s existing regulations covering shale gas wells already bans road dumping wastewater from unconventional wells. [Read more here.]
In December 2024, the Shapiro Administration reiterated its support of a ban on road dumping. [Read more here.]
In January 2025, Rep. Greg Vitali (D-Delaware), Majority Chair of the House Environmental and Natural Resource Protection Committee, again introduced legislation to ban road dumping of conventional wastewater. Read more here.
Penn State University experts who conducted multiple studies of the health and environmental impacts of road dumping conventional oil and gas wastewater told the House and Senate there is “no more research that needs to be done” to justify a ban on road dumping” this wastewater. Read more here.
Unfortunately, the road dumping of conventional wastewater on dirt and paved roads has continued unabated, even though it is now illegal-- but not banned. Read more here. Read more here.
Pending EHB Appeal
BCD Properties, Inc. owns the Danylko 4 conventional gas well in McKean Township, Erie County that produces very little gas, but a lot of wastewater, according to the appeal filed by BCD. [EHB Docket 2025066]
BCD Properties, Inc. holds 104 DEP permits, including four conventional wells listed as abandoned by DEP.
BCD has been producing wastewater and marketing it for road dumping since at least 2019.
In 2023, Pennfield Energy LLC entered into a contract with Harmony Township, Forest County to road dump the wastewater. Pennfield obtained the wastewater it road dumped from BCD, according to the appeal.
In July 2024, Harmony Township provided DEP with copies of the coproduct determination provided by BCD as required by the Residual Waste Regulations [Read more here] comparing the BCD wastewater with another similar wastewater conventional well owned by Seneca Mineral Company and a “product” Seneca distributes for road dust suppression as LS25.
[Note: A 2023 Penn State study found the Seneca LS25 “product” contains the same harmful chemicals and radioactivity exceeding NRC discharge standards as oil and gas wastewater regulated by DEP. Read more here.
BCD’s appeal notes at about this same time, the state Office of Attorney General Environmental Crimes Section contacted BCD as part of an investigation of its production and sales of wastewater for road dumping.
On April 16, 2025, DEP issued a letter invalidating the coproduct determination for the Danylko 4 wastewater prepared by BCD saying it did not meet the requirements of the Residual Waste Regulations and continued road dumping of wastewater may result in enforcement action.
On May 14, 2025, BCD appealed DEP’s letter invalidating the coproduct determination to the Environmental Hearing Board.
BCD maintains wastewater from the Danylko 4 conventional well is a product not a waste, in part, because it is comparable to wastewater sold by Seneca Mineral Company as the commercial product LS25.
BCD said DEP’s failure to establish “acceptable parameters and practices of brine roadspreading since the Siri Lawson case is unreasonable.”
In 2017, Siri Lawson, a resident of Warren County that has been impacted by road dumping, filed an appeal with the Environmental Hearing Board that resulted in a settlement in 2018 that led DEP’s Oil and Gas Program to stop issuing approvals for road dumping conventional wastewater. [EHB Docket: 2017051] Read more here.
The Lawson case, however, did not prohibit DEP’s Waste Management Program from considering coproduct determinations under the Residual Waste Regulations to allow road dumping. Read more here.
On July 14, 2025, both BCD Properties, Inc. and DEP wrote a letter to the EHB Judge presiding over the BCD saying the parties are having discussions to settle the appeal.
The public is not involved in these settlement discussions and would only know the outcome of these discussions if and when a settlement is announced and the appeal is dismissed.
CDAC Wastewater Work Group
At its August 21 meeting, DCED’s PA Grade Crude [Oil] Development Advisory Council voted to form a Produced Water Subcommittee-- “produced water” being the euphemism used for conventional wastewater.
The Subcommittee is to be made up of members of the Council, which includes no members of the public.
The Subcommittee is charged with trying “to come up with some findings and some options on how to move forward with produced water,” looking at options like road dumping, water treatment, reuse and other available options.
There was also discussion of exploring funding options for water treatment facilities through the PA Infrastructure Investment Authority.
DEP suggested the Subcommittee scheduled a meeting in September or early October before the December 4 full Advisory Council meeting.
Meetings of CDAC subcommittees or workgroups have not been the subject of public notice and as a result the public has not been able to observe the meetings.
NPDES- Covered Discharge
The third challenge was brought up by a Council member who said an unnamed company contacted him saying it is working with DEP’s Northwest Regional Office to use GCI Water treatment technology to treat conventional wastewater under an NPDES water quality permit to the point where the discharge theoretically could be dumped on roads as a dust suppressant.
The Council member noted GCI Water itself went bankrupt after the state Office of Attorney General made inquiries into road dumping the wastewater discharge from its plant in Titusville, Crawford County. Read more here.
Changes To Coproduct Regulations
In May 2024, DEP announced it is developing proposed changes to the coproduct determination process in the Residual Waste Regulations that allow a material, that would otherwise be regulated as a waste, to be used as a commercial product without any restrictions or upfront review or approval by DEP. Read more here.
That intention was reaffirmed in DEP’s Regulatory Agenda published in February 2025. Read more here.
No details of possible changes were provided. The draft, however, will be presented to DEP’s Solid Waste Advisory Committee for comment.
Next Meeting Dec. 4
The next scheduled meeting of A Grade Crude [Oil] Development Advisory Council is tentatively set for December 4, with a location to be announced.
Visit the DCED’s PA Grade Crude [Oil] Development Advisory Council webpage for more information on the Council. Questions should be directed to: Adam Walters 717-214-6548 or adwalters@pa.gov.
A Good Time For A Road Dumping Review
Now is a good time to review how far the science has come on this issue and provide an update on the continued efforts of the conventional industry to dispose of millions of gallons of its contaminated wastewater on dirt, gravel and paved roads at the public’s expense.
DEP has tried for decades to regulate this practice but failed because the conventional industry simply does not comply.
But, they haven’t tried an outright ban on road dumping like DEP has for unconventional shale gas wastewater.
Any new framework has to be measured against the failure of all past attempts and what DEP, itself, calls the industry’s “culture of non-compliance.”
The Science - Road Dumping Should Be Banned
Dr. William Burgos, a Penn State Professor of Environmental Engineering, who has done research studies, several for DEP, of the environmental and health risks of road dumping oil and gas wastewater for years, told a Senate Committee in 2024-- “There’s no more research that needs to be done” to justify adopting a state ban on the road dumping of conventional oil and gas wastewater.”
Last June, he told a House Committee “Pennsylvania should ban road spreading of O&G PW [oil and gas wastewater].” Read more here.
“There is no public benefit to road spreading O&G PWs [oil and gas wastewater]…. It is all risk, no reward. The only beneficiaries are the O&G [oil and gas] operators who choose this disposal option.” Read more here.
“The ineffectiveness and potential pollution of wastewater spreading make the practice an unsuitable alternative for dust suppression on Pennsylvania roads.” Read more here.
Dr. Burgos noted DEP has already banned the road dumping of unconventional shale gas drilling wastewater for its environmental and health risks.
He said Penn State’s research found-- “The chemical characteristics of conventional and unconventional oil and gas-produced waters overlap considerably with respect to major constituents as well as [radioactive] radium activity. So there's not a whole lot of difference.” Read more here.
Penn State studies found the amounts of at least 25 of the chemicals they tested for exceeded environmental and health standards and radioactive radium exceeded industrial waste discharge standards. Read more here.
Penn State also found from 2008 to 2014, “spreading O&G PW [oil and gas wastewater] on roads released over 4 times more radium to the environment than O&G [oil and gas] wastewater treatment facilities, and 200 times more radium than spill events.” Read more here.
Dr. Burgos pointed to several other contaminants of concern.
“The contaminants of concern include chloride with respect to freshwater salinization, and also impacts on infrastructure as far as corrosivity and other sorts of things.
“So chloride for stream health and [radioactive] radium and petroleum hydrocarbons primarily for human health.
“And of course there's, unfortunately, there's lead, arsenic and a couple other trace metals that might be of concern.
“But really from a risk-based standpoint, [radioactive] radium being a known carcinogen.
“And these petroleum hydrocarbons in produced waters that have elevated petroleum hydrocarbon concentrations, which might be visible to you and I as the oily sheen, these were the ones that had that direct human receptor cell-based response with respect to potentially causing toxicity, maybe even cancer.”
Destabilizes Dirt, Gravel Roads Causing More Dust
He also pointed out, oil and gas wastewater destabilizes dirt and gravel roads.
“Oil and gas produced waters destabilize roads. So what we saw is that they produce a tremendous amount of dust in the dust generation experiments.
“But we also did these rainfall runoff experiments, and we measured the solids, which we can think of as a proxy for aggregate or dollars of maintenance materials with respect to putting stuff back on your gravel road.”
“And these things led to a greater loss of solids from the roads during this heavy storm event that we used to simulate this stuff, compared to rainwater being spread onto the test cell at the beginning of the experiment.
“Because of these findings, oil and gas produced waters fail to meet the EPA's [US Environmental Protection Agency’s] criteria for beneficial reuse of industrial waste.”
Click Here for a copy of Dr. Burgos’ testimony.
More Studies - Health, Environmental Risks
A 2018 Penn State study concluded, “Spreading O&G [oil and gas] wastewater on roads can harm aquatic life and pose health risks to humans.” Read more here.
“... O&G wastewaters transported from the road to surface water after rain events are likely the major potential threat to aquatic toxicity.” Read more here.
“These wastewaters could require up to 1,600 times dilution to reach drinking water quality standards or approximately 100 times dilution to reduce acute toxicity to aquatic organisms,” according to the Penn State study. Read more here.
Another study concluded, “Anticipatable levels of toxic contaminants added to road dust by a single application of OGB [oil and gas brine] are at, or well above, relevant cleanup levels. It is reasonable, therefore, to conclude health risks are appreciably increased by exposure to dust from OGB-treated roads.” Read more here.
“The spreading of O&G [oil and gas] wastewaters on roads could be a significant contributor of inorganic and organic micropollutants to the environment and has been largely ignored in environmental studies on O&G development.” Read more here.
“...[B]rines that are used for road maintenance activities such as deicing and dust suppression raise concerns about increasing the salinity of proximate water resources, because once applied, much of the salt becomes mobile and travels offsite with surface and groundwater which has negative consequences for agriculture, infrastructure, and aquatic life.” Read more here.
Other studies have found little difference in basic, potentially harmful contaminants in wastewater from conventional and unconventional (shale) drilling operations.
A 1997 industry sponsored study by Moody & Associates documents adverse groundwater impacts from the land application disposal of conventional oil and gas wastewater concluding-- "The water quality data generated from this study indicates that the long term discharge of shallow oil field produced water to the ground surface is not a viable management practice." [page 26] Read more here.
These study results are relevant to the controversy today over the road dumping of conventional oil and gas wastewater as a disposal method.
The repeated and heavy road dumping of conventional oil and gas wastewater that continues on Pennsylvania dirt and gravel roads and amounts to the repeated "ground surface" application of oil and gas wastewater evaluated in the Moody study.
The 250 mg/l limit of chlorides in groundwater contamination limit DEP established for the Moody study is significant because a Penn State study released in May 2022 found water runoff from conventional oil and gas wastewater dumping on dirt and gravel roads contained from 7,550 to 10,000 mg/l of chlorides. Read more here - page 50.
The original chloride content of the oil and gas wastewater tested in the latest Penn State study contained from 47,900 to 49,700 mg/l of chlorides. Read more here - page 39.
A 1985 study released in 2010 by the Department of Conservation and Natural Resources found high concentrations of barium in conventional oil and gas brines was the "likely the source of barium contents exceeding the drinking-water limits in some private wells and small municipal water supplies in western Pennsylvania." [Read more here.]
The study went on to explain, "Contents of barium and strontium are limited by the solubility of sulfates and carbonates but can be relatively high, so that admixture of even small amounts of the brine with near-surface freshwater can produce barium levels above current limits established by the U.S. Environmental Protection Agency for drinking water." [Read more here.]
Another study also found “produced waters from conventional oil and gas wells in Pennsylvania and New York also have elevated levels of radioactivity, similar to those from the Marcellus Formation.” Read more here.
The 2010 DCNR study also found "radium values are high enough that a possible radiation hazard exists, especially where radium could be adsorbed on iron oxides and accumulate in brine tanks." [Read more here.]
“The release of [radioactive] radium, a known carcinogen, is a potential threat to human health. In Pennsylvania, we found that radioactivity associated with radium released to the environment via road spreading exceeds the radioactivity of radium released by spill events or wastewater treatment plants.” Read more here.
Not Effective Dust Control, Heavily Salting Roads
Eric Chase, Assistant Teaching Professor and Assistant Director of the Penn State Center for Dirt and Gravel Road Studies said road spreading oil and gas wastewater is “not effective at suppressing dust and pose potential environmental harm and due to high levels of chloride and radium would not pass the testing requirements to be eligible for Program funds.”
Adding-- “the use of O&G PWs on Program funded [Dirt & Gravel Road] projects is in opposition with not only the fundamental goals of the Program, but the law that created the Program.”
“My research in support of the Program focuses on road surface aggregate selection, road maintenance and dust/sediment production from unpaved roads in collaboration with agencies such as the US Forest Service, US Fish and Wildlife Service, Susquehanna River Basin Commission and Trout Unlimited.”
“In recent years I have collaborated with the [Penn State] Department of Civil and Environmental Engineering at Penn State on research evaluating the environmental impacts of oil & gas produced water disposal practices, including brine spreading in Pennsylvania. I have been a co-author and advisor on several papers that have been published in well regarded peer-reviewed scientific journals.
“On the topic of effectiveness, our research has shown through bench scale testing that O&G PWs do not perform as well as commercially available dust suppressants due to the high sodium content.
“The high sodium content decreases the dust suppression effectiveness compared to commercial calcium based brines and can also destabilize the road.”
“[Oil and gas wastewaters] raise potential environmental concerns due to the chemicals found in the waters. One study on the chemical composition of conventional O&G PWs spread on roads in Pennsylvania published in 2018 found elevated concentrations of total dissolved solids (TDS), chloride, bromide, radium, barium, and in some cases, petroleum hydrocarbons [Tasker et al 2018].”
“This study showed that the median chloride concentration was 183,000 mg/L, as compared to the drinking water standard for chloride of 250 mg/L, which is used in the Program’s Product approval process testing requirements as a maximum concentration limit (for reference chloride in seawater is around 20,000 mg/L).
“This Program’s product approval limit of 250 mg/L chloride has been in place for over 20 years and no chloride-based dust suppressants have ever been used within the Program because of the difficulty meeting this criteria.”
“Additionally, the Program’s Product approval process includes aquatic toxicity testing for rainbow trout and chloride concentrations have been shown by the USEPA to be toxic to trout species at levels 20 times lower than found in O&G PW [oil and gas wastewater].”
“Finally, five O&G PWs from Pennsylvania contained radium levels from 84 to 2,500 pCi/L, which fall above the Program’s product approval process limit of 15 pCi/L,” Chase said.
“Therefore, O&G PWs would not qualify for use or funding within the program due to failing multiple environmental testing protocols and posing a potential environmental harm which are counter to the Program’s goals.”
“In summary, O&G PWs are not effective at suppressing dust and pose potential environmental harm and due to high levels of chloride and radium would not pass the testing requirements to be eligible for Program funds.
“Ultimately, the use of O&G PWs on Program funded projects is in opposition with not only the fundamental goals of the Program, but the law that created the Program.”
Rusting Out Vehicles
Constant road dumping conventional oil and gas wastewater accelerates the process of rusting out vehicles in the dumping areas and literally eats holes in paved roads that make them look like swiss cheese.. [Read more here]
DEP Banned Similar Shale Gas Wastewater Road Dumping
The 2016 update to DEP’s regulations for unconventional shale gas drilling bans the practice of road dumping wastewater from those operations because of the threats it posed.
A 2020 Penn State study formally concluded there were not a lot of differences between conventional and unconventional shale gas wastewater, according to Dr. William Burgos. Read more here.
DCNR Bans Road Dumping
The Department of Conservation and Natural Resources has banned the use of oil and gas wastewater for any purpose on its over 6,500 miles of roads in State Forests-- a majority of which are dirt and gravel roads-- and on State Park roads. Read more here.
“The benefits of chemical dust suppressants usually do not outweigh potential maintenance and ecological concerns associated with their use,” DCNR’s guidelines say.
DCNR is the largest owner of dirt and gravel roads in the Commonwealth.
The Allegheny National Forest says “commercial dust suppressants now available render the practice of spreading oil and gas wastewater on roads unnecessary” within the National Forest in Elk, Forest, McKean and Warren counties, according to the U.S. Forest Service. Read more here.
Attempts To Regulate Road Dumping All Failed
There have been several attempts by DEP to regulate the road dumping of conventional wastewater to reduce its environmental and health impacts.
But, DEP hasn’t tried an outright ban on road dumping like DEP has for unconventional shale gas wastewater.
Conventional oil and gas well owners have reported road dumping between 3.5 and 4 million gallons of their oil and gas wastewater a year to DEP as recently as 2017, although those numbers have never been audited by DEP and are likely to be much higher.
In the early 1980s, DEP developed guidelines covering the use of drilling wastewater to suppress dust on unpaved roads. They were designed to “prevent adverse environmental impacts” from the practice.
The guidelines were administered by DEP under the Clean Streams Law, Solid Waste Management Act and the Oil and Gas Act.
Any person planning to spread wastewater had to receive approval from DEP before spreading and obtain signed authorizations from the municipality, the owner of the road or service company.
Approval was received by submitting a yearly plan to DEP that contained the road name and section they intend to spread, locations of wastewater storage areas, intended frequency and application rates and descriptions of operating procedures for spreading the wastewater.
The plan also had to contain a chemical analysis of the wastewater and the geologic formations from which the wastewater was produced.
The guidelines included limits on the frequency and rate of wastewater application.
There was a limit of 1 gallon per square yard of road surface and it could not be spread within 150 feet of a body of water, on a road with a grade exceeding 10 percent or on wet roads.
Wastewater “spreaders” also had to submit a monthly report to DEP indicating the county, township and roads where wastewater was spread as well as the volumes of wastewater spread, length of road treated and dates on which “spreading” occurred.
The industry never complied in numbers to make the program anywhere near effective at reducing the environmental impact of road dumping.
In 1996, the Ridge Administration looked at road dumping and the environmental impacts of this disposal method. Read more here.
A study begun in 1992 by DEP to “examine ground and surface water impacts from spreading brine on unpaved roads” concluded “there is a potential for brine to migrate from the roadway and impact ground or surface water quality.” Read more here.
The result was a new set of guidelines in 1998 that limited how much could be dumped on roads and where so it wouldn’t run off and pollute. Read more here.
The industry failed to comply with these limits too on how they dumped and the required reporting.
They just kept dumping.
The DEP Oil and Gas Program process for approving road dumping ended in 2018 with the settlement of an appeal before the Environmental Hearing Board. Read more here.
But, that did not stop the conventional well owners.
DEP’s own Oil and Gas Reporting system shows 3.5 million gallons of conventional oil and gas wastewater was dumped on Pennsylvania roads since the 2018 decision, but, as noted, it was probably a lot more.. Read more here.
Well owners turned to DEP’s Residual Waste Regulations and the “co-product” use process to get their waste approved for road dumping.
But, DEP’s Waste Management Program said the industry didn’t meet those requirements either. Read more here.
Municipalities As Waste Facilities
In 2021, DEP’s Oil and Gas Program listed 84 townships as “waste facilities” because conventional oil and gas wastewater has been dumped on their roads. Read more here.
In 2022, DEP took the extra step of advising 18 municipalities in four counties that road dumping of conventional wastewater is considered waste disposal and is illegal. Read more here.
Road dumping remains illegal as a result, but the “co-product” loophole still exists.
And, the industry keeps road dumping. Read more here.
A Culture Of Non-Compliance
Any framework DEP has tried to regulate the illegal practice of road dumping conventional oil and gas wastewater has failed.
Any new framework has to be measured against the failure of all past attempts and what DEP calls the industry’s “culture of non-compliance.”
In December, 2022, the Department of Environmental Protection released the first-ever assessment of how well conventional oil and gas drillers comply with state environmental laws and concluded, “(the) conventional oil and gas industry’s recent record of compliance with Pennsylvania law is simply not good, particularly with regard to improper abandonment of wells.” Read more here.
DEP concluded-- “A significant change in the culture of non-compliance as an acceptable norm in the conventional oil and gas industry will need to occur before meaningful improvement can happen.”
“This record of non-compliance will require DEP to further develop and refine its techniques for deterring violations and encouraging compliance with relevant statutory and regulatory provisions.
This conclusion was reinforced again by DEP on June 12, 2025 testimony before the House Environmental and Natural Resource Protection Committee. Read more here.
Kurt Klapkowski, DEP Deputy Secretary for Oil and Gas Management said DEP continues to see “widespread non-compliance with laws and regulations in the conventional oil and gas industry, particularly regarding improper abandonment of oil and gas wells, but also not reporting hydrocarbon and waste production [and disposal] and conducting mechanical integrity assessments.” Read more here.
The 2022 report looked at environmental compliance in the industry between 2017 and 2021.
Specifically, the report found--
-- Abandoning oil and gas wells most frequent violation, noting conventional operators were issued 3,123 notices of violation for the practice during the five years reviewed;
-- Huge gaps exist in reporting waste generated by conventional wells: Over 56 percent of conventional well operators fail to report the amount of waste they generate and how it is disposed of meaning more than half of the wastewater being produced may be unaccounted for-- roughly 118 million gallons-- but we don’t know for sure due to the lack of reporting.
-- Failure to report mechanical integrity of wells by over 59 percent of conventional well operators means they are not making sure their oil and gas wells are not leaking fluids into groundwater or surface water or natural gas into the air or operating their wells safely.
It’s Gotten Worse
Since that report was issued, things have only gotten worse--
-- 86% of conventional oil and gas well owners did not submit a 2023 annual production and waste generation and disposal report to DEP for each well they own which means DEP has no idea how much waste those wells generate and where it is being disposed. These 4,265 conventional oil and gas well owners own 33,505 wells-- 32% of the conventional wells required to report Read more here.
To put the environmental impact of noncompliance with waste reporting into perspective, in 2017, approximately 44 percent of conventional operators reported generating a total of 93,416,526 gallons of wastewater for disposal or treatment. Read more here.
Given current compliance numbers, that means an estimated 118 million gallons of conventional wastewater or more has not been accounted for in the annual waste reports.
Where did it go?
-- 89% of conventional oil and gas well owners failed to submit a 2023 annual well integrity report for each of the wells they own to assure they are not contaminating groundwater, surface water or venting gas into the atmosphere. These 4,359 owners own 34,455 wells-- 34% of the conventional wells required to file these reports. Read more here.
-- In 2024, DEP issued a record 860 notices of violation to conventional oil and gas well owners for abandoning and not plugging their wells. Read more here.
-- An estimated 4,719 conventional oil and gas well owners have yet to comply with a 2022 Air Quality regulation reducing methane emissions from their wells and infrastructure because of a court challenge they filed. Read more here. DEP’s Air Quality Program is developing a new methane reduction program using General Permits, but has not yet developed a strategy for getting conventional facility owners to comply with anything. Read more here.
Violations Increased Dramatically
The number of total violations issued to conventional oil and gas well owners by DEP’s Oil and Gas Program have increased dramatically since 2015--
-- 2024-- 7,294 Read more here.
-- 2023-- 6,860 Read more here.
-- 2022-- 5,416 Read more here.
-- 2021-- 4,514 Read more here.
-- 2015-- 1,024 Read more here.
The culture of non-compliance continues in full force.
Conclusion
So, given--
-- What DEP says is the culture of non-compliance by the industry;
-- The failure of any attempt to regulate road dumping for decades, due to industry non-compliance;
-- Clear science over several decades that says oil and gas wastewater and road dumping has the potential for negative environmental and health impacts;
-- That researchers say no more research is needed to conclude road dumping should be banned (when have you heard researchers ever say that?);
-- That DEP already bans road dumping of unconventional shale gas wastewater that is hard to distinguish from conventional wastewater in chemical and physical make-up;
-- That conventional wastewater is not an effective dust suppressant because of its chemical make-up;
-- That conventional wastewater actually breaks up dirt and gravel roads making them dustier and literally eats road pavement making it look like swiss cheese;
-- That constant road dumping accelerates the rusting of vehicles…
There is ample justification for a straight-forward ban on road dumping.
I guess we wait to see what happens.
(Photos: Row 1-- Late night road dumping on March 21, 2025, note triangular spray pattern; Row 2-- Morning-after March 21 dumping fingerprint; Row- 3 Telltale bluish sheen from road dumping on paved road, water collected after road dumping on Scranton Hollow Road on September 17, 2024)
Resource Links -Conventional Wastewater Road Dumping:
-- Late Night Road Dumping: Conventional Oil & Gas Wastewater Continues To Be Dumped On Dirt, Gravel, Paved Roads; DEP Expected To Provide Update At April 24 Meeting [4.9.25]
-- Late Night Dumping II: Conventional Oil & Gas Wastewater Dumping Continues On Roads, This Time With Bigger Trucks; New Research On Harmful Wastewater Impacts [5.22.25]
-- Senate Hearing: Penn State Expert: ‘No More Research That Needs To Be Done’ To Justify A Ban On Road Dumping Conventional Oil & Gas Wastewater [4.17.24]
-- House Hearing: Penn State Expert Says ‘Pennsylvania Should Ban Road Spreading Of Oil & Gas Wastewater;’ Contaminants Exceed Health, Environmental Standards [6.10.24]
-- House Hearing: Penn State Center For Dirt & Gravel Road Studies Says Road Spreading Oil & Gas Wastewater Is Not An Effective Dust Suppressant, Does Not Meet Environmental Testing Standards [6.10.24]
-- Moody & Associates Study Finds Discharge Of Conventional Oil & Gas Wastewater To The Ground Surface ‘Not A Viable Management Practice'; Supports Ban On Road Dumping; Onsite Disposal [5.13.24]
-- Senate Hearing: First-Hand Account Of Health, Environmental Impacts From Road Dumping Conventional Oil & Gas Wastewater - ‘Inhaling Oil & Gas Wastewater 24-Hours A Day’ [4.17.24]
-- House Hearing: A First-Hand Account Of How Repeated, Unlimited Road Dumping Of Oil & Gas Drilling Wastewater Is Tearing Apart Dirt Roads And Creating Multiple Environmental Hazards [6.10.24]
-- House Hearing: Protect PT - Road Dumping Oil & Gas Wastewater ‘Is Disproportionately Responsible For Negative Impacts On Human Health,’ Especially From Radioactive Radium [6.10.24]
-- Senate Hearing: 3.5 Million Gallons Of Conventional Oil & Gas Wastewater Dumped On PA Public Roads Since DEP’s ‘Moratorium’ On Dumping Started 6 Years Ago [4.17.24]
-- House Hearing: On Road Dumping Oil & Gas Wastewater - ‘We Studied This For Nearly 30 Years And The Conclusions Are The Same - The Wastewater Contains Harmful Contaminants’ [6.10.24]
-- Senate Hearing: The Case For An Immediate, Total Ban On Road Dumping Conventional Oil & Gas Wastewater [4.17.24]
-- House Hearing: Shapiro Administration Supports Bill Banning Road Dumping Oil & Gas Wastewater, Prohibiting Its Use As Coproduct Under Residual Waste Regulations [6.10.24]
-- Guest Essay: Take A Deep Breath! Now Think What You Just Inhaled. If You Live Along A Dirt Road You Could Be Inhaling Oil & Gas Wastewater - By Siri Lawson, Warren County [8.2.23]
-- Environmental Health Project - Part 1: Personal Narrative Of Environmental, Health Impacts From Oil & Gas Drilling On Siri Lawson, Warren County [7.16.21]
-- Environmental Health Project - Part II: Personal Narrative Of Environmental, Health Impacts From Oil & Gas Drilling On Siri Lawson, Warren County [8.5.21]
-- Op-Ed: Why Is the General Assembly About To Hurt Us By Authorizing Road Dumping Of Oil & Gas Wastewater? - By Siri Lawson [9.22.19]
-- Op-Ed: Will Our Dirt Roads Again Be Used As Dumping Sites For Oil & Gas Well Wastewater - By Siri Lawson [3.22.19]
-- Op-Ed: The Story Behind Stopping Conventional Oil & Gas Brine Spreading On Dirt Roads - By Siri Lawson [6.26.18]
PA Oil & Gas Industry Public Notice Dashboards:
-- PA Oil & Gas Weekly Compliance Dashboard - August 16 to 22 - Conventional, Shale Gas Wastewater Spilling All Over, Seeping From Hillsides; 4th Pipeline Construction Spill; Where Did You Put That Waste? [PaEN]
-- DEP Issues Violations For Failing To Report How Waste Was Disposed Of Safely From 133 Conventional Oil & Gas Wells, Including 50 Owned By CNX Gas Company [PaEN]
-- DEP: 3rd & 4th Spills From Horizontal Drilling At EQM Gathering Pipeline Project In Washington County; Overflowing Tanks; Water Supply Complaint Investigated [PaEN]
-- DEP: Contaminated Wastewater Found Seeping From Saturated Shale Gas Well Pad Fill Slope In Great Bend Twp., Susquehanna County [PaEN]
-- DEP: Day 38 Of Cleanup: Borehole Found Under Stormwater Basin During Continuing Cleanup Of Repsol Shale Gas Well Pad After A 34-Hour Uncontrolled Wastewater Release In Bradford County [PaEN]
-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - August 23 [PaEN]
-- DEP Now Accepting Bids To Plug 7 Conventional Gas Wells In Washington County [PaEN]
-- Susquehanna River Basin Commission Approved 57 Shale Gas Well Pad Water Use General Permits In June/July; 282 In 2025 [PaEN]
-- DEP Posted 61 Pages Of Permit-Related Notices In August 23 PA Bulletin [PaEN]
Related Articles This Week:
-- Conventional Oil & Gas Well Owners Pushing 3 More Ways To Legalize Road Dumping Their Wastewater; Not Clear How The Public, Put At Risk By Dumping, Will Be Involved [PaEN]
-- Susquehanna River Basin Low Flow Water Conditions Trigger Water Withdrawal Restrictions On 47 Shale Gas Development Water Withdrawal Points In PA [PaEN]
-- Joint State Government Committee Identifies 382 Potential Sites For Geothermal Facilities Using Abandoned Mine Pools; Geothermal Energy Could Reduce A.I. Data Center Energy Demand By 30-40% [PaEN]
-- In Case You Missed It: A.I./Data Center Articles & NewClips From Last Week - August 24 [PaEN]
NewsClips:
-- Middle Susquehanna RiverKeeper Blog: More Than 1.3 Million Gallons Of Oil & Gas Wastewater Stored At Eureka Resources Facility In Williamsport Without Required Alarms Among Violations DEP Issued 10 Days Prior To River Spill
-- Middle Susquehanna RiverKeeper Blog: Initial Radioactivity Scan Show No Elevated Levels From Eureka Resources Oil & Gas Wastewater Spill In Williamsport
-- Middle Susquehanna RiverKeeper Volunteers Find Persistent Oily Waste From Eureka Resources Oil & Gas Wastewater Treatment Plant Spill In Williamsport; Advise Public To Avoid Recreational Use Of River For Now
-- PennLive - John Beauge: DEP Issued Violation 10 Days Before Tank At Eureka Resources Oil & Gas Wastewater Facility Leaked Oily Discharge Into Susquehanna River
-- PennLive - John Beauge: Oily Substance From Tank In Closed Oil & Gas Wastewater Treatment Plant Leaks Into Susquehanna River [PDF of Article]
-- Williamsport Sun: Extensive Cleanup Underway After Oil Substance Leaks Into River In Williamsport [PDF of Article]
-- The Derrick: Leak Found In Service Station Underground Gasoline Tank In Downtown Titusville, Crawford County
-- Post-Gazette/Inside Climate News: Pennsylvania Lured The Shell Petrochemical Plant To The State With A $1.65 Billion Tax Break, Now The Company Wants To Sell The Plant
-- PA Capital-Star/Inside Climate News: Pennsylvania Lured The Shell Petrochemical Plant To The State With A $1.65 Billion Tax Break, Now The Company Wants To Sell The Plant
-- The Allegheny Front/Inside Climate News: Pennsylvania Lured The Shell Petrochemical Plant To The State With A $1.65 Billion Tax Break, Now The Company Wants To Sell The Plant
-- Williamsport Sun Editorial: Natural Gas Remains ‘Keystone’ Of Future Economic Growth [PDF of Article]
-- Reuters: Drop In Natural Gas Demand Signals 2 Top LNG Gas Exports Facilities May Have Outages
-- The Guardian: US Pipeline Protester’s Obstruction Conviction Overturned By Minnesota Appeals Court Finding ‘Pervasive’ Prosecutorial Misconduct
[Posted: August 21, 2025] PA Environment Digest

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