The bills include--
-- House Bill 84 (Vitali-D-Delaware) prohibiting the spreading of conventional and shale gas oil and gas wastewater on roads and by land application;
-- House Bill 1567 (Mullins-D-Lackawanna) requires public consideration of host community benefit agreements for power plants between communities and school districts and establishes minimum requirements for those agreements; and
-- House Bill 426 (Pielli-D-Chester) encouraging the construction of new habitats for monarch butterflies and native insects at Commonwealth-owned facilities.
The meeting will be held in Room B-31 Main Capitol starting at 11:00 a.m. Click Here to watch online.
Rep. Greg Vitali (D-Delaware) serves as Majority Chair of the House Environmental & Natural Resource Protection Committee and can be contacted by calling 717-787-7647 or sending email to: gvitali@pahouse.net. Rep. Jack Rader, Jr. (R-Monroe) serves as Minority Chair and can be contacted by calling 717-787-7732 or click here to send an email.
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.
The following is a summary of research and experience with this issue since the 1990 which all points to the need to ban the practice of road dumping conventional oil and gas wastewater like DEP did shale gas wastewater in 2016.
The science on this issue was summarized by Dr. William Burgos, a Penn State Professor of Environmental Engineering who has done research studies on road dumping oil and gas wastewater and told both the Senate and House committees-- “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.”
Conventional wastewater isn’t even any more effective than plain water in suppressing dust on dirt and gravel roads-- its advertised benefit-- but has documented environmental risks from 25 pollutants that exceed recognized environmental and health standards.
The Department of Environmental Protection supports this legislation as do environmental and conservation groups.
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.
(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]
Related Article This Week:
-- Independent Fiscal Office Reported First Quarter PA Natural Gas Production Declined Slightly From 4th Quarter, Lowest In Any Quarter Of 2025 [PaEN]
-- Guest Essay: Pennsylvania's Native Insects Need Help Now - By Nate Reagle, Ecologist [PaEN]
NewsClip:
-- Bloomberg Columnist: A LNG Natural Gas Glut Is On Its Way - By Javier Blas
[Posted: June 2, 2026] PA Environment Digest

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