Quebec Bans Hydraulic Fracturing for Oil and Gas

According to the Montreal Gazette, Quebec’s Bureau d’audiences publiques sur l’environnement (BAPE) has banned the hydraulic fracturing technique of stimulating oil and gas wells throughout the province.

Details are not yet posted on the English section of the BAPE website. According to the article, the ban is in place immediately, but does not affect the 31 wells which have already been drilled. Additionally, hydraulic fracturing can be conducted if it is determined by a panel of experts to be for scientific purposes.

Gas Drilling Waste Pollution Permit Under Scrutiny

March 16, 2011

Gas Drilling Waste Pollution Permit Under Scrutiny
Bowing to industry pressure, state has bent the rules for wastewater treatment plant

HARRISBURG, PA – Environmental groups are challenging a new proposal to allow a gas drilling wastewater treatment plant operated by Shallenberger Construction, Inc. to dump 500,000 gallons of water polluted by toxic chemicals into the Monongahela River each day without adequate protections for drinking water.

The nonprofit environmental law firm Earthjustice filed comments (PDF) on behalf of Clean Water Action and 18 other organizations, disclosing that – for the second time in the short history of the treatment plant – the Pennsylvania Department of Environmental Protection (“DEP”) has made an exception to the rules for Shallenberger. The comments also highlight a host of other problems with the plant’s permit, which could result in the contamination of the Monongahela River, a drinking water source for 350,000 people.

Earlier this month, the New York Times published a series of investigative articles on the environmental impacts of the gas drilling boom in Pennsylvania, highlighting the lax regulations governing the gas drilling industry. Yesterday federal lawmakers, including Senator Bob Casey (D-PA), introduced legislation aimed at protecting drinking water from gas drilling pollution.

“Pennsylvania is being held up nationwide as a poster child for gas development gone wrong. And this shoddy pollution permit certainly won’t do anything to change its reputation. Even as state officials try to appear as if they are being tough on polluters, they keep bending over backwards to accommodate an industry that is clearly uninterested in anything but short-term profits,” said Earthjustice attorney Deborah Goldberg. “It’s high time that state leaders recognized that the health of the 350,000 people who depend on the Mon for their drinking water clearly comes first.”

The sole purpose of the Shallenberger plant (located in Masontown, PA, in the southwestern corner of the state) is to treat polluted water from industrial gas development in the Marcellus shale, including wastewater from the controversial process known as hydraulic fracturing – in which drillers blast millions of gallons of chemically-treated water into the earth to extract the gas. Clean Water Action has been in litigation (PDF) since 2009 over a prior secret agreement to allow the plant several years to discharge incompletely treated wastewater, in spite of legal requirements that new wastewater treatment plants be built with adequate controls right from the start.

“As we detail in our comments, DEP has twice told the public that Shallenberger’s permit will contain one set of limits, while the agency is planning to enforce completely different standards. DEP needs to come clean with its true intentions and protect our drinking water from dirty gas extraction wastes,” stated Myron Arnowitt, PA State Director for Clean Water Action.

DEP first issued an unlawfully lenient discharge permit to Shallenberger in September 2008. After pollution in the Monongahela River exceeded water quality standards, the State entered into negotiations with Shallenberger to amend the permit. DEP gave the company more than three years from the end of August 2009 to meet new limits, however, and even those were inadequate. The negotiations were conducted behind closed doors, and the deal was never subject to public notice or review. The new draft permit also is subject to toothless deadlines and other deficiencies.

Heather Panek, a Clean Water Action member living in nearby Monongahela, PA, stated, “As a life long resident of the Mon Valley, I can’t understand why the state would allow Shallenberger to start polluting our drinking water. This plant has been operating successfully for a about a year without discharging a drop. Not only could there be health problems, if DEP allows untreated pollution into the river, but our businesses could be hurt as well. What person or business is going to want to move into a community without access to clean water?”

For a copy of the comments filed, click here (PDF).

Deborah Goldberg, Earthjustice, (212) 791-1881, ext. 227
Kathleen Sutcliffe, Earthjustice, (202) 667-4500, ext. 235
Myron Arnowitt, Clean Water Action, (412) 592-1283, cell

Clean Water Action, with over 150,000 members in Pennsylvania, has been empowering people for more than 37 years to take action to protect America’s waters, the health of our families and to make democracy work.

Earthjustice is a non-profit public interest law firm dedicated to protecting the magnificent places, natural resources, and wildlife of this earth, and to defending the right of all people to a healthy environment.

Environmental Injustice Letter on Impact of Shale Gas Drilling

The Center for Constitutional Rights and Columbia Environmental Law Clinic submitthis letter to provide background on hydraulic fracturing in the United States. The Center forConstitutional Rights is dedicated to advancing and protecting the rights guaranteed by theUnited States Constitution and the Universal Declaration of Human Rights. CCR is based inNew York but works throughout the United States and internationally to promote and protecthuman rights. Supervised by clinical faculty, Columbia Environmental Law Clinic studentsrepresent local, regional and national environmental and community organizations working tosolve critical environmental challenges facing the New York metropolitan region as well as otherparts of the world. The Clinic is part of a team of lawyers from local, state and nationalorganizations who bring their legal resources to address impacts of gas drilling in the MarcellusShale, a shale formation that cuts across New York and Pennsylvania. This joint letter withbackground and recommendations identifies substantial deficiencies in the U.S. Government’sregulation and monitoring hydraulic fracturing.

In the last several decades the United States has experienced political and economicpressure to decrease its dependence on foreign fossil fuels and increase domestic fossil fuelproduction. New technological developments have allowed the fossil fuel industry to extractnatural gas from shale resources previously thought too expensive and difficult to tap. One suchdevelopment, hydraulic fracturing, has been used in the industry for over 60 years and is nowutilized in around 90 percent of the nation’s oil and gas wells.1 The process involves injectingwater, chemicals and natural materials into the well to release trapped gases. Unfortunately,government regulators and industry leaders have historically ignored the substantial health and welfare costs associated with the process.2 Government regulators and industry leaders havehistorically ignored the substantial health and welfare costs associated with the process.Residents living in areas near fracturing sites have higher incidents of cancer and have reportedthat water itself is often discolored, pungent and contains bubbles because of the high levels ofmethane gas.3

PA Wastewater spills by county (small)
Demo: PA Wastewater Spills by County
Click to work with map.

The most substantial risk associated with hydraulic fracturing is massive water sourcecontamination in regions where the process is employed. Residents in such jurisdictions havereported drinking water contamination in every state where hydraulic fracturing wells exist;sometimes so severe that flammable tap water caused homes to explode.4 In a two and a half yearperiod, hydraulic fracturing operations committed around 1,500 violations of Pennsylvania oiland gas law alone, all of which potentially endangered local water quality and many of whichwent un-publicized.5 State and Federal agencies have declared the drinking water in several ruraltowns, like Dimock, Pennsylvania and Pavilion, Wyoming undrinkablecontaminants used in near-by hydraulic fracturing operations.6

The impacts of such contamination risks disproportionately affect rural, economicallyunderdeveloped communities throughout the country. Water withdrawal and contaminationdisproportionately impacts farmers and fishermen. Politics and economics make it substantiallymore likely that hydraulic fracturing wells will be located in rural regions. Local communities inrural areas throughout the United States are more likely to agree to the environmentallydestructive practices of the fossil fuel industry in exchange for the promise of economicstimulation because they have less diverse economies. Large urban metropolises are betterequipped to resist pressure from the natural gas industry. For example, despite the existence ofvaluable Marcellus Shale Resources in the region, the New York City Department ofEnvironmental Protection has declared that, “hydraulic fracturing poses an unacceptable threat tothe unfiltered water supply of nine million New Yorkers and cannot safely be permitted with the New York City watershed.”7 One of the strategies employed by the City of New York topreserve the quality of water is to acquire key plots of land surrounding the watershed so theymay be protected from hydraulic fracturing operations. This might prove too costly for othermunicipalities, especially those in economically disadvantaged areas.

The placement of natural gas extraction in rural areas increases the likelihood that the watercontamination will go undetected because rural water supplies are difficult to monitor. TheEnvironmental Protection Agency (EPA) of the United States has more stringent water qualityreporting requirements for suppliers providing to 10,000 or more consumers (metropolitansuppliers),8 and the EPA lacks jurisdiction to monitor private water wells.9 As a result,contamination due to hydraulic fracturing can go largely undetected in rural areas.

The negative effects of hydraulic fracturing may also disproportionately affect indigenouspopulations. Many of the largest shale deposits with developmental potential reach into triballands, which tend to be rural, underdeveloped and susceptible to promises of economicdevelopment. Even if wells are not drilled on tribal lands, wells in neighboring rural lands couldstill impact the water supply of tribes. Many tribes have expressed a deep moral opposition to thepractice of hydraulic fracturing.10

While state and municipal regulation of hydraulic fracturing does exist, federal law isseverely deficient. In 2005, Congress exempted hydraulic fracturing in the oil and gas industryfrom being regulated under the Safe Drinking Water Act.11 This is the only industry allowed to inject known toxins into the ground near water supplies without any federal oversight. Wastesgenerated during the production of natural gas are categorized as “special wastes” and thus areexempt from regulations that cover “hazardous wastes” under the Safe Drinking Water Act.Furthermore, many of the chemical mixtures injected into ground water supplies are protected bylaws governing “trade secrets”, making it impossible to definitively identify the hydraulicfracturing as the cause of the deterioration of water quality.


  • FRAC Act) (H.R. 2766) (S. 1215),which aims to repeal the exemption for hydraulic fracturing under SDWA and wouldrequire complete disclosure of chemicals used in the hydraulic fracturing process. TheBill was introduced to both houses on June 9, 2009.12
  • State governments must continue to actively monitor and regulate the industry and theEPA must seek to ensure maximum monitoring of water contamination in hydraulicfracturing regions. The U.S. Government should increase and supplement currentmonitoring of water sources near coal bed methane sites where increasing levels ofmethane have been documented.
  • Congress should repeal the exemption for hydraulic fracturing from the purview of theSafe Water Drinking Act (SWDA), and regulate hydraulic fracturing under section 1425of the SWDA, since all other extractive industry injection activity has been regulatedunder the flexible terms of that provision for decades.
  • Congress should ensure greater transparency on all levels of the industrial and regulatoryprocesses, by requiring public disclosure of chemicals used in hydraulic fracturing, whichcurrently is considered a trade secret.
  • Congress should ratify the International Covenant on Economic, Social, and CulturalRights (ICESCR) protecting the right to water.13

Please contact Susan Kraham with any further questions or concerns at (212)854-5008 Thank you for your attention to this matter.

This letter was originally sent to:

Dr. Catarina de Albuquerque
Independent Expert on the Issue of Human Rights Obligations
Related to Access to Safe Drinking Water and Sanitation.
ESCR Section
Human Rights Council and Special Procedures Division
Palais des Nations
CH-1211 Geneva 10, Switzerland


Susan Kraham, Senior Staff Attorney
Lauren Daniel, Student
Surya Binoy, Student
Columbia Environmental Law Clinic
435 W. 116th St.
New York, New York 10027

Rachel Meeropol
Sunita Patel
Krystle Gan
Center for Constitutional Rights
666 Broadway, 7th Floor
New York, New York 10012


1Riverkeeper Report, Fractured Communities: Case Studies of the Environmental Impacts of IndustrialGas Drilling, 3 (Sept. 2010) available here.
2See Environmental Protection Agency, Hydraulic Fracturing Research Study Fact Sheet (June 2010)available here (PDF). The final EPA Report’s anticipatedrelease is in 2012.
3 E.g., Laura Amos, Garfield County, Co: Family’s Water well was contaminated after hydraulicfracturing near home, EARTHWORKS, here (last visitedFeb. 22, 2011).
4The Ohio Department of Natural Resources Determined that a December, 2007 explosion at aBainbridge, OH home was cause by a high-volume hyradraulic fracturing operation in the nearby“Clinton” sandstone formation. Natural Gas migrated through the fractures into nearby acquifers and theninto local water wells fed by the aquifers. Report on the Investigation of the Natural Gas Invasion ofAquifers in Bainbridge Township of Geauga County, Ohio (Sept. 2008), available here.
5Riverkeeper Report, supra, note 1 at 5.
6 For a discussion of major reported instances of water contamination nationwide, see Riverkeeper Report, supra, note 1.
7Press Release, New York City Department of Environmental Protection, Department of EnvironmentalProtection Calls for Prohibition on Drilling in the New York City Watershed (Dec. 23, 2009), available here.
8Safe Drinking Water Act of 1974, 42 U.S.C. §300g et. seq. (2004).
942 U.S.C § 300g; US Environmental Protection Agency, Report on the Environment: Drinking WaterQuality (accessed Feb. 22, 2010), Here (“Private wells, cisterns, and other non-public water supplies are not subject to federalregulation…no national infrastructure, and few if any systematic state efforts, currently exist to collectdata on trends in the quality of these supplies.”).
10For example, the Haudenosaunee Environmental Task Force, a comprehensive indigenous responseorganization, has stated that, “The Haudenosaunee have a unique spiritual, cultural, and historicrelationship with the land…when humans tinker more and more with the natural balance, we do so at theperil of our grandchildren. In few cases is this more apparent than the proposed method of natural gasdrilling known as hydraulic fracturing or ‘hydrofracking’.” Haudenosaunee Statement on Hydrofraking: More.
11Energy Policy Act of 2005, Pub. L. No. 109-58, § 1(a), 119 Stat. 594 (2005). Paragraph (1) of section1421(d) of the Safe Drinking Water Act (42 U.S.C. 300h(d)) is amended to read as follows: (1)UNDERGROUND INJECTION – The term ‘underground injection’ – (A) means the subsurfaceemplacement of fluids by well injection; and (B) excludes – (i) the underground injection of natural gasfor purposes of storage; and (ii) the underground injection of fluids or propping agents (other than dieselfuels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities.
12The summary and status of this bill in both houses can be found at (site not presently working) (House); and here (Senate).
13The United Nations Human Rights Council derived the right to water implicitly in the Article 11 rightto “an adequate standard of living, particularly since it is one of the most fundamental conditions ofsurvival.” U.N. Comm’ee Econ. Soc. & Cultural Rights, Substantive Issues Arising in theImplementation of the International Covenant on Economic, Social and Cultural Rights, GeneralComment No. 15, U.N. Doc. E/C.12/2002/11 (2003), available here.

Additional Resources

  • Statement of Lisa P. Jackson Administrator, U.S. Environmental Protection Agency Legislative Hearing on EPA’s 2011 Budget Proposal Senate Committee on Environment and Public Works – Read

The Devil’s Details about Radioisotopes and Other Toxic Contaminants in Marcellus Shale Flowback Fluids

and Their Appearance in Surface Water Sources and Threats to Recreationalists, Private Well Water Users, and Municipal Water Supplies

By Conrad Dan Volz, DrPH, MPH – Director, Center for Healthy Environments and Communities, University of Pittsburgh Graduate School of Public Health

In yesterday’s FracTracker post, CHEC’s data manager Matt Kelso told the tale of two stories regarding radionuclides in Marcellus Shale flowback water and in river water as sampled by the PA DEP. As he said “the devil is in the details” and here are the “devil’s details” that put both stories into their proper public health context.
There are without doubt higher levels of radioisotopes in Marcellus Shaleflowback fluids than in the fracking fluids, which are injected under highpressure to fracture the shale layer. And in general problems related tonaturally occurring radioisotope buildup in the oil and gas industry arewell documented. The following is a passage from my expert testimony in theMatter of Delaware River Basin Commission Consolidated AdministrativeAdjudicatory Hearing on Natural Gas Exploratory Wells; Filed November23, 2010:

Elevated concentrations of naturally occurring radioactive materials(NORM), including 238U, 232Th and their progeny, are found inunderground geologic deposits and are often encountered during drillingfor oil and gas deposits (Rajaretnam G, and Spitz HB., 2000). Drill cuttingsfrom the Marcellus may be enriched in radium radionuclides and off-gas the radioelement radon. Also, the activity levels and/or availability ofnaturally occurring radionuclides can be significantly altered by processesin the oil, gas and mineral mining industries (B. Heaton and J. Lambley,2000). Scales in drilling and process equipment may become enrichedin radionuclides producing technologically enhanced naturally occurringradioactive materials (TENORM). Exposure to TENORM in drillingequipment may exceed OSHA and other regulatory authority standardsfor the protection of both human and ecological health. The occurrenceof TENORM concentrated through anthropogenic processes in soils atoil and gas wells and facilities represents one of the most challengingissues facing the Canadian and US oil and gas industry today (Saint-Fortet al., 2007). The risk of contamination of surface water and ground waterby TENORM accompanies the risk of soil contamination, as TENORMgenerated may runoff of drilling equipment during rain events or if onthe soil surface into surface water sources and/or enter groundwater bytransport through the unsaturated zone.

In a review article in Environmental Science and Technology (ES&T),authors Karbo, Wilhelm and Campbell (EPA Region III leads and Office ofRadiation and Indoor Air) stated:

New York’s Department of Environmental Conservation (NYDEC) reportedthat thirteen samples of wastewater from Marcellus Shale gas extractioncontained levels of radium-226 (226Ra) as high as 267 times the safedisposal limit and thousands of times the limit safe for people to drink.The New York Department of Health (NYDOH) analyzed three MarcellusShale production brine samples and found elevated gross alpha, grossbeta, and 226Ra in the production brine. Devonian-age shales containnaturally occurring radioactive material (NORM), such as uranium (U)and thorium (Th) and their daughter products, 226Ra and 228Ra. TheMarcellus Shale is considered to have elevated levels of NORMs. NORMsthat have been concentrated or exposed to the accessible environmentas a result of human activities, such as mineral extraction, are defined bythe EPA as technologically enhanced NORM (TENORM). TENORM maybe concentrated because of (1) temperature and pressure changes duringoil and gas production, (2) 226Ra and 228Ra in produced waters reactingwith barium sulfate (BaSO4) to form a scale in well tubulars and surfaceequipment, (3) 226Ra and 228Ra occurring in sludge that accumulates inpits and tanks, and (4) NORM occurring as radon (Rn) gas in the naturalgas stream.

If this flowback-produced water with elevated TENORM is disposed ofin sewage treatment facilities or other ineffective wastewater disposalprocesses – then the TENORM level in surface water (the receiving streamor river) will be largely determined by dilution offered by fluid flows withinthe waste plant and dilution offered by the water flows themselves in theriver or stream.

So, it is entirely possible that Marcellus Shale flowback and produced fluids(yes I hesitate to call it water because it is contaminated fluid – with manyidentified toxic contaminants; if this were coming from other industries itwould be a hazardous liquid waste) will have elevated levels of TENORM and many other contaminants (see explanation in Appendix 1 below) butlevels of TENORM in the surface water it is going into will not exceedbackground levels, seen in the stream or river system, once it is completelymixed in the stream or river.

But here is the devil in the details as Matt said in his article.Recreationalists fish and boat around these outfalls (this is documentedby CHEC in the Allegheny River Stewardship Project and the PittsburghFish Consumption Project), and we have no idea of the levels of TENORM(or other contaminants) in receiving water near the outfalls before fullriver mixing occurs. Additionally we have no idea of the level of long term bioaccumulation of TENORM (and other contaminants) in fish and otheraquatic resources that may frequent or live in areas where this material isdisposed of in.

Concentrations of TENORM and the many other contaminants in the effluent from treatment of oil and gas flowback fluids will vary in receivingstreams and rivers according to the flow of water in the receiving streamor river and their concentrations in the flowback fluids. Therefore, levels ofTENORM in receiving streams and rivers will reach a peak (everything elsebeing equal) during times of low flow – such as a drought or long periodswithout rain or snowmelt – and peak levels will be higher in the surface waternear the outfall then downstream in the river after it is mixed completelywith water flow from the stream or river. The PA DEP river water samplesfor radium were not taken during periods of low flow but during the fallseason when rain was more plentiful. Furthermore, they were not taken near outfallsof plants accepting oil and gas waste fluids for treatment, before completemixing occurs—therefore, peak levels in these areas were not captured bytheir sampling plan.

Additionally, levels of TENORM (and other contaminants) from sewagetreatment plants and inefficient brine treatment plants will be higher inlow volume streams (such as 10 Mile Creek in Greene and WashingtonCounties and Blacklick Creek in Indiana County) than in large volume riversystems like the Monongahela River. We simply don’t know what levels ofTENORM are like at peak levels in low volume streams during periods oflow flow or in areas just downstream of effluent outfalls before completemixing takes place.

CHEC has data showing that levels of bromides, barium and strontiumexiting the McKeesport POTW (a sewage treatment plant) vary over a day’s sampling; they aredependent on when the slug of produced-flowback brine is introduced intothe system and the slug’s rate of entry into the treatment system. At theMcKeesport POTW, it is customary that the slug of oil and gas waste fluidis introduced into the treatment system at 7pm. One sees that the levels ofthese contaminants in outfall effluent raises sharply over a short period oftime and then falls back to baseline (See CHEC figures 1, 2 and 3), whenthe slug is through the system. Any TENORM, in the oil and gas waste fluidbeing treated, not taken out by the treatment system will reasonably followthe same pattern. That is it will come and go quickly and we have no ideaof peak levels of TENORM or any other contaminants in the stream or rivernear the treatment plant outfall.

What is the solution to all this? Are we to sample continuously – at alltreatment plant outfalls, in river and stream segments between treatmentplant outfalls and water intakes, at all water intakes and in all finisheddrinking water (and I might add in private well water systems that may pullin contaminants from nearby streams and rivers) across the entire areaMarcellus Shale waste fluids are being disposed of? (This would includePennsylvania, New York, Ohio, and West Virginia). This is exactly whatis necessary to be done to assure protection of drinking water supplies,recreationalists, and the health of aquatic resources if we continue to allowoil and gas flowback water to be disposed of in sewage treatment andinefficient brine treatment plants.

NO – this would be cost prohibitive and impractical to do on the scale thatis necessary to protect public health and aquatic resources. We must usethe precautionary principal here and insist that sewage treatment plants notaccept oil and gas wastewater, period. Batches of oil and gas wastewaterneed to be tested continuously for levels of TENORM and all other possiblecontaminants so that a determination can be made of where the fluids canbe adequately and safely disposed of. Fluids that are determined to behazardous and/or toxic should be transported only by certified haulers andloads need to be properly manifested so there is an accurate accounting ofthe volumes of waste and where it is being sent for ultimate treatment. Thetechnical capabilities and acceptance of brine fluids, of and by, oil and gaswaste fluid treatment facilities must be matched exactly to the realities oflevels of contaminants in the brine fluids.

The intent of the Resource Conservation and Recovery Act (RCRA) wasto ensure that there is a “cradle to grave” system to document, handleand dispose of all hazardous and toxic waste from all industries and evenmunicipal authorities in a safe and effective manner. RCRA is basically anextension of the environmental public health precautionary principal – andif implemented and enforced thoughtfully and comprehensively preventsthe formation of new Superfund sites and will assure that the publicand environmental receptors are protected from contaminants in oil andgas waste fluids- be they called flowback or produced water, or brine oranything else.

Figure 1, Time-plot of Barium concentration in effluent from the McKeesportPOTW, sampled beginning 10/19/2010. Hour 1 begins at 19:00 (7:00 PM).A sample was taken on the hour, every hour, for a period of 24 hours. (To zoom in, click on the image.)

Figure 2, Time-plot of Strontium concentration in effluent from the McKeesport POTW, sampled beginning 10/19/2010. Hour 1 begins at 19:00 (7:00 PM). A sample was taken on the hour, every hour, for a period of 24 hours. (To zoom in, click on the image.)

Figure 3
, Time-plot of bromides concentration in effluent from the McKeesport POTW, sampled beginning 10/19/2010. Hour 1 begins at 19:00 (7:00 PM). A sample was taken on the hour, every hour, for a period of 24 hours. (To zoom in, click on the image.)

Appendix 1, Background Information

Hydraulic fracturing (HF) of shale gas deposits uses considerable masses of chemicals, for a variety of purposes to open and keep open pathways through which natural gas, oil and other production gases and liquids can flow to the well head. HF, also known as slick-water fracturing, introduces large volumes of amended water at high pressure into the gas bearing shale where it is in close contact with formation materials that are enriched in organic compounds, heavy metals and other elements, salts and radionuclides. Typically, about 1 million gallons and from 3-5 million gallons of amended water are needed to fracture a vertical well and horizontal well, respectively (Hayes, T; 2009, Vidic, R.; 2011). Fluids recovered from these wells can represent from 25% to 100% of the injected amended water solution (Vidic R., 2011) and are called “flowback” or “produced” water depending on the time period of their return.

Flowback and produced water contain high levels of total dissolved solids, chloride, heavy metals and elements as well as enriched levels of organic chemicals, bromide and radionuclides – in addition to the frac chemicals used to make the water slick-water. Levels of contaminants in flowback water generally increase with increasing time in contact with formation materials. There is abundant evidence that fluids recovered from this operation have high levels of total dissolved solids, barium and strontium, chlorides and bromides

While there is at present considerable scientific inquiry and even controversy regarding the potential of vertical or horizontal fracturing of shale gas reservoirs to contaminate shallow or confined groundwater aquifers (thus exposing municipal or private well water users to chemicals used in the hydrofracturing process and/or toxic elements, organic compounds, and radionuclides that exist in the formation materials); disposal of oil and gas wastewater/ Marcellus shale brine water in sewage treatment plants or inefficient brine wastewater treatment facilities is a direct exposure threat to public health through ingestion, inhalation and dermal absorption exposure pathways.

Groups Announce Legal Action to Stop Sewage Plants from Dumping Gas Drilling Wastewater in PA Rivers


Groups Announce Legal Action to Stop Sewage Plants from
Dumping Gas Drilling Wastewater in Pennsylvania Rivers

— McKeesport and Franklin Twp. plants targeted —

(Pittsburgh) – Clean Water Action and Three Rivers Waterkeeper served legal noticestoday on two sewer authorities that have been discharging Marcellus Shale gas drillingwastewater into the Monongahela River watershed south of Pittsburgh. The noticesdetail violations of the federal Clean Water Act by the facilities, primarily for dischargingwastewater without a permit. Both EPA and the Pennsylvania DEP were notified as wellof the legal action. This is the first time a legal action has been filed to stop the currentdischarge of Marcellus drilling wastewater.

The two sewer authorities targeted are the Municipal Authority of the City of McKeesport inAllegheny County and the Franklin Township Sewer Authority, located in Greene County.McKeesport discharges up to 100,000 gallons per day of Marcellus drilling wastewater intothe Monongahela River. Franklin Twp. discharges up to 50,000 gallons per day into TenMile Creek, a tributary of the Monongahela River. The Monongahela supplies drinkingwater for nearly a half million people, including a portion of the City of Pittsburgh.

“We cannot wait any longer to rely on the state and EPA to act,” stated Myron Arnowitt,PA State Director for Clean Water Action. “These sewage plants have been illegallydischarging gas drilling wastewater into our rivers since 2008 without a permit as requiredby the Clean Water Act. They should immediately stop accepting gas drilling wastewaterand if they want to accept it, they should apply for a permit to do so,” Arnowitt stated.

“Our rivers have made a miraculous recovery over the past few decades, thanks – in largepart – to laws that protect the public’s right to clean rivers and safe drinking water. Theselaws are public health laws and their strict enforcement has a direct, positive effect on thehealth of our rivers, our communities, and our citizens,” stated Ned Mulcahy, ExecutiveDirector for Three Rivers Waterkeeper. “We demand that these facilities stop acceptingtruck after truck of this wastewater and that the DEP and EPA take all necessary actionsto ensure that our rivers, our drinking water, and our communities are protected from thehealth hazards posed by improper treatment and illegal discharges,” Mulcahy stated.

Pennsylvania DEP has previously issued consent orders with both facilities that purportto allow the sewage plants to accept and discharge Marcellus wastewater. Arnowittstated, “DEP’s consent orders are private deals that are negotiated without public input.

The public is not notified and there are no public hearings as there would be if they appliedfor a Clean Water Act permit to discharge appropriately treated Marcellus wastewater. Ifthis wastewater is as safe as the gas industry says it is, lets have a public process so wecan see what the impact really is,” stated Arnowitt.

Water samples recently taken by University of Pittsburgh researchers downstream ofarea wastewater plants have shown elevated levels of numerous contaminants found inMarcellus wastewater including: total dissolved solids, chlorides, bromides, barium, andstrontium.

Although DEP had previously issued in 2010 strict wastewater treatment standards formost oil and gas wastewater sources, the new rule grandfathered all existing plants thatare currently discharging Marcellus wastewater. No plants in Pennsylvania that arecurrently discharging Marcellus wastewater are capable of removing contaminants to thelevel required by the 2010 wastewater rule.

EPA Region III Administrator Shawn Garvin sent a letter this week to Acting DEPSecretary Krancer concerning Marcellus wastewater discharge permits. The letter readin part, “These permits do not now include critical provisions necessary for effectiveprocessing and treatment of wastewaters from drilling operations.”

The legal action that is being filed today is the first step in what is referred to as a citizensuit under the Clean Water Act. When government agencies fail to address violations ofthe Clean Water Act this federal law allows any citizen to sue for enforcement of the law.The filing today is the legally required “Notice of Intent” informing all parties of the Clean Water Act violations at issue.

The legal filing from Clean Water Action and Three Rivers Waterkeeper can bedownloaded here.

Clean Water Action has more than 120,000 members statewide in Pennsylvania and isthe nation’s largest grassroots group focused on water, energy and environmental health.Clean Water Action’s 1 million members, participate in Clean Water Action’s programs forclean, safe and affordable water, prevention of health-threatening pollution, and creation ofenvironmentally-safe jobs and businesses. Clean Water Action’s nonpartisan campaignsempower people to make democracy work.

The mission of Three Rivers Waterkeeper is to ensure that communities throughoutSouthwestern Pennsylvania have safe water to drink, clean rivers to enjoy, and themeans necessary to defend their right to both. To accomplish this mission, Three RiversWaterkeeper will engage in education and outreach, work with communities and theirleaders, partner with government actors and NGOs, patrol the rivers, monitor water quality,and hold polluters accountable under the law.

Myron Arnowitt, Clean Water Action, 412-592-1283
Ned Mulcahy, Three Rivers Waterkeeper, 412-589-4720

Two Tales of Radioactivity

There’s a disagreement brewing about whether or not there are radioactive materials in the Marcellus Shale wastewater. On February 26, 2011, Ian Urbina’s New York Times article reported:

Of more than 179 wells producing wastewater with high levels of radiation, at least 116 reported levels of radium or other radioactive materials 100 times as high as the levels set by federal drinking-water standards. At least 15 wells produced wastewater carrying more than 1,000 times the amount of radioactive elements considered acceptable.

Gross Alpha Particles. This map is based on the Pennsylvania wells which were reported to have high levels of radiation by the New York Times on February 26, 2011.  Please click the “i” icon and then one of the wells above for more information.  Please click the gray compass rose and double carat (^) to hide those menus.

On March 7, 2011, the Pennsylvania Department of Environmental Protection (DEP) issued a statement that would appear to contradict the New York Times data.  According to Acting DEP Secretary Michael Krancer, the situation is as follows:

We deal in facts based on sound science. Here are the facts: all samples were at or below background levels of radioactivity; and all samples showed levels below the federal drinking water standard for Radium 226 and 228.

Can Both Claims Be True?

Of the apparent discrepancy, the Marcellus Drilling News had this blunt proclamation:

It seems that The New York Times’ contention that Pennsylvania is poisoning waterways with radioactivity from Marcellus Shale wastewater was fiction and not science, as is now proven by test results from the Department of Environmental Protection (DEP).

But sound-byte media wars aside, there isn’t necessarily any discrepancy at all. As is usually the case, the devil is in the details.

First of all, it is important to understand that the two organizations are referencing entirely different datasets. More to the point, while the New York Times data is about the produced water itself, the DEP report tested river water. What’s more, in a follow-up article on March 7th, Mr. Urbina wrote:

The Times found that samples taken by the state in the Monongahela River — a source of drinking water for parts of Pittsburgh — came from a point upstream from the two sewage treatment plants on that river. The state has said those plants are still accepting significant quantities of drilling waste.

Because that sampling site is upstream, the discharges from those two plants are not captured by the state’s monitoring plans.

With this perspective, the Marcellus Drilling News’ harsh words come across as misguided. While the DEP statement seems to have been carefully worded to give the illusion of countering the claims raised by Mr. Urbina’s article, in fact, it does no such thing.

CHEC’s Perspective

In Mr. Urbina’s March 7th article, Center for Healthy Environments and Communities (CHEC)(1) Director Conrad Volz, DrPH, MPH said:

As long as we are going to allow oil and gas wastewater to enter these streams, there needs to be monitoring weekly at least for a whole host of contaminants, including radium, barium, strontium.

According to Mr. Urbina’s March 7th Times article, the United States Environmental Protection Agency (EPA) seems to agree with this cautionary approach, requiring tests for radioactivity at water intake plants, as well as a call to check for compliance at the facilities that are handling the wastewater.

This seems like a prudent approach. If the DEP has legitimate issues with the February 26th New York Times data, it was not effectively countered by their March 7th statement. The best way to settle this dispute is through targeted data collection, which in this case means setting up an effective water quality testing strategy.

And isn’t that the sort of work that the Department of Environmental Protection and the Environmental Protection Agency should be doing anyway?

  1. CHEC manages the content for FracTracker, including this site,, and

PA Marcellus Shale Production by Municipality

Average 6 month MS Well Production by Municipality (small)Marcellus Shale production by municipality. The darker red municipalities have higher production, illustrating that gas production in these gas wells comes in “hot spots”, particularly in the northeast and in the southwest.

It is no secret that there is money to be made in the natural gas industry, not only for the industry, but for those leasing their mineral rights as well. Pennsylvania law requires that a royalty of at least one eighth of the wellhead price of gas be paid to the owner of the land’s mineral rights.

And yet, we continue to hear stories, such as the one about Ron Gulla, who leased his land, which was subsequently damaged by drilling operations, all for apparently no money. How can this be? According to Mr. Gulla, it was because his gas was “wet gas” which needs to be processed. The DEP website makes no such distinction. Just to be sure, I called the Harrisburg office of the Bureau of Oil and Gas Management. Their response was that wet or dry, the drilling operators are required to pay at least one eighth of the wellhead price of gas as a royalty fee.

Is it possible that after all the drilling and hydraulic fracturing and dead fish and ruined farm that there was just no gas produced from that well?

First of all, let’s find Mr. Gulla’s former community. We know from the story referenced above that he was from Hickory in Washington County. In terms of this map, that places him in the middle of Mount Pleasant Township, so let’s take a closer look at what’s going on in that area.

Average six month gas production for Mount Pleasant Township in Washington County, PA, by municipality. Production values are from 7-1-10 to 12-31-10. Click the gray compass rose and double carat(^) to hide those menus.

If you click on the “i” button in the blue circle, then the red shape in the middle of the screen, we can learn quite a bit about gas production in Mount Pleasant Township. For example, we know that there were 94 wells in the township, each producing an average of 57.8 million cubic feet of gas in the six month period of July to December 2010, for an estimated minimum royalty check of just over $30,000. That’s a lot of gas and a lot of money. So where was Mr. Gulla’s?

Average six month gas production for Mount Pleasant Township in Washington County, PA, by municipality and by well. Production values are from 7-1-10 to 12-31-10. Click the gray compass rose and double carat(^) to hide those menus.

If the statewide trend is one of hotspots, at the township level, we are now looking at hotspots within hotspots. While many wells in Mount Pleasant Township produced over 300 million cubic feet of gas in the six month period, many others produced very little. And if Mount Pleasant is a moderately high producer of Marcellus Shale gas, and Chartiers Township to the southeast is a heavyweight, it makes it all the more curious that Cecil Township to the northeast and Smith Township to the northwest have no Marcellus Shale activity at all.

So maybe you have a neighbor who hit the jackpot with the Marcellus Shale gas boom, but does that mean that you will?

Average six month minimum royalty fees by township. Note the large number of municipalities with low or no royalty averages, and the very high dollar amounts in some other communities. Click on the gray compass rose and double carat (^) to hide those menus.

From this map, you can get an idea of what the average six month well royalty check might be for a well in your community. The figures for this map are based on the production values, above, times 0.125 times the average wellhead price of gas in 2010. But as we’ve seen in Mount Pleasant, there are some holes where the gas just doesn’t flow.

After taking this to another level of complexity, the lesson is pretty much the same as before: There is money to be made in the Marcellus Shale gas extraction industry–sometimes. As Mr. Gulla’s story reminds us, there are hardships as well. The DEP issued 9,370 oil and gas violations in a period of less than four years. Things can and sometimes do go wrong, and even when they don’t, around the clock industrial action for months on end in your backyard may be at odds with your bucolic lifestyle, or that of your neighbors.

So if you leased your land, would you cash in? At best, you can look at the numbers and play the odds, but there’s only one way to find out for sure.

The Citizen Surveillance Project and Marcellus Shale Development

By Charles Christen, DrPH, MEd – Director of Operations, Center for Healthy Environments and Communities, University of Pittsburgh Graduate School of Public Health

In August and November of last year, we reported on the start up of the Citizen Surveillance Project targeting surveillance and water monitoring of the industry developing the Marcellus Shale deposit for natural gas. I would like to update you on the progress of this project.

Currently this is a two phase project beginning with attendance at a Visual Assessment training followed by an optional Water Monitoring training. Since the start up of this project three visual assessment trainings have been held: Connellsville, Washington and Greensburg, PA as well as a water monitoring training.

To aid in the visual assessment training, a manual has been developed by the partners forming the core of the Citizen Surveillance project. The manual uses information from the Society of Petroleum Engineers in order to provide a detailed description of the well pad selection, drilling procedures, fracturing and well completion. There are also detailed descriptions of water and air related issues and how to perform surveillance with the senses of sight, smell, sound and touch. A section of the manual is also devoted to safety issues when performing surveillance on industry operations. The manual concludes with instructions for a full visual assessment of an industry site and surrounding area.

The project started as a pilot in the fall of 2009 in Fayette County, with the intention of expanding the project into all areas where Marcellus Shale gas industry develops. This project was developed out of the realization that as the number of wells grew the necessary enforcement officials from the PA Department of Environmental Protection (PA DEP) to provide oversight on the industry would be lacking. The realization of the need for additional “boots” on ground developed into a project to provide education and empowerment to individuals living in and around these gas industry sites. The content for training citizens in surveillance of the industry is provided by the manual for the Visual Assessment training. View the Visual Assessment Manual. You may print and use this manual freely.

If you would like to participate in visual assessment training or water monitoring training you can contact Veronica Coptis, project coordinator for the Citizen Stewardship project. Her contact information is (724) 455-4200 extension 4# and

Project Partners

Communal Fracture: Concerned Citizens of Western Pennsylvania React to the Various Impacts of Marcellus Shale Fracking on their Communities

By Nate Natale

The 141 acre farm in rural Washington County was a fixer-upper. 
The challenge of clearing the 80 overgrown acres on this property suited Ron Gulla just fine. So did the prospect of renovating the farm’s pond, tenant house and barn- all of which he did.
Gulla loves to work, he also loves to hunt and fish. “When I was hungry, I used to catch fish right out of my pond,” said Gulla. His property was perfect for all of these pursuits. 
That was until his 2.5 acre pond turned black, killing everything in it- including the fish. 
That was until a dream piece of property turned into a nightmare. 
In 2002, like so many in Hickory, Pa., Gulla signed a lease to allow natural gas drilling on his property. In discussing what has happened since, Gulla speaks with an anger and a passion that is impossible to dismiss. 
His story is one of the many in Washington County that is fraught with regret. “There are days that I am so mad, I have tears streaming down my face,” said Gulla.
Gulla was one of the last to sign in Hickory, even though his gut told him it was the wrong decision. “People will say, ‘it’s your fault’ and yes, but it wasn’t for the money…it was for the free gas,” said Gulla. 
Promised 300,000 cubic square feet of gas per year, Gulla said he never saw any of it. 
“Shale gas is wet, you can’t burn it. It has to be processed. They knew all along, we were never going to see that gas,” said Gulla. 
He also said that he was never informed that there would be unconventional horizontal drilling on his property.
Gulla said that the lies and deceit he experienced permeates the industry. “If you sign your mineral rights away, you’re signing your land away,” said Gulla. 
Gulla no longer lives on the farm he said was destroyed by natural gas company Range Resources. It is now owned by the Texas based company, whose Marcellus Division is located in Canonsburg, Pa. 
“They treated my farm like a landfill,” said Gulla. He also said that Range Resources never owned up to destroying his land or his pond.
Range Resources did not respond to a request for comment on this story. 
“I know what I know about this industry, I’ve seen the skull and cross bones come onto my property- the black water in my pond, the frack pits. They are destroying the ecosystem,” Gulla said. 
The Urban Perspective 
Community activists Loretta and Ken Weir, of Pittsburgh, speak with the same passion as Ron Gulla. 
After spending their Sunday afternoon at a meeting of the Marcellus Shale Protest organization, the Weirs shared a perspective from an area where drilling is not allowed. 
In November 2010, The City of Pittsburgh passed the “Pittsburgh’s Community Protection from Natural Gas Extraction Ordinance”, banning drilling within city limits. 
The ordinance alone does not protect the city from pollutants and this is one reason why many residents are still concerned. 
“The ordinance is just the beginning- Pittsburgh sits in a bowl, we have to keep moving out- the water sources are all connected,” said Mr. Weir. 
Quoting the Pennsylvania Constitution, Article I, Section 27,  “The people have a right to clean air, pure water…”, Mr. Weir said that people’s rights are being trampled on by the natural gas industry. 
Fourteen waste disposal facilities along the Monongahela River accept and dilute water used in the fracking process, returning it to the river- the source of much of the community’s drinking water. 
The chemical solution used in fracking is proprietary, and due to their exemption- known as the Halliburton Loophole- from the 2005 energy bill, the natural gas companies do not have to share its components. 
It is the presence of these components in the frack water, some of which are returned to the river, that cause concern. 
Due to the Halliburton Loophole, the industry is basically self-reporting. “It’s like the fox watching the henhouse,” said Mr. Weir. 
The Weirs said they are frustrated with the lack of oversight and that more was promised. This appears to to be impossible with the budget cuts that the Pennsylvania Department of Environmental Protection (DEP) is experiencing. 
“The government has failed to protect the people,” said Mr Weir. 
With a lack of trust in the industry and a feeling of dissatisfaction with the government’s efforts, there is a desire to put the topic in front of the people. 
Marcellus Shale Protest is exploring the viability of putting a referendum on the 2012 Allegheny County ballot for a moratorium on hydraulic fracturing. 
To the Suburbs
In Allegheny County, municipalities like Jefferson Hills are contemplating ordinances that restrict or ban hydraulic fracturing. 
In terms of percentage of land under oil and gas lease, Jefferson Hills is ranked tenth in Allegheny County with 18 percent. 
“It looks like a new ordinance will go one of two ways: either ban it completely..or allow it in a very small area zoned for industrial activity,” said Anita Barkin, community activist and public health expert. 
Ordinances may not be enough. According to the Pennsylvania Oil & Gas Act, the DEP administers the oil and gas well permitting process- superseding municipal ordinances. 
However, the courts have not outlined a clear path on what these layers of laws actually mean. At this point, each case is defining the extent of a municipality’s authority to regulate. 
Tight Quarters 
Suburban fracking creates dangerous scenarios unique to these areas. 
“A well blowout or a fire in a densely populated area would make it necessary to evacuate 5,000 people. No one is prepared to do that,” said Conrad (Dan) Volz, director of the Center for Healthy Environments and Communities at the University of Pittsburgh’s Graduate School of Public Health.  
“We’ve found that local departments feel inadequately prepared and in situations where there has been an emergency, they’ve played second fiddle to the company. They are also not equipped to do vital air and water testing during an emergency, they have to wait for the DEP to come from a great distance,” said Volz.
Water is also an issue for Jefferson Hills. The Peters Creek Watershed provides source water for the community’s drinking water and functions as a source of recreation. Fracking would put the watershed in a precarious position. 
As for Jefferson Hills’ drinking water, “Marcellus drilling does have the potential to affect drinking water quality. The Clairton Municipal Authority is accepting frack fluid at its plant. The effluent of this plant enters Peters Creek just prior to it’s confluence with the Mon River. Drinking water for most watershed residents comes from the Mon River downstream in Hays,” said Tim Schumann of the Peters Creek Watershed Association.
Barkin and Schumann said community education is working, but more needs to be done.
“There are still many residents that have grown up with shallow wells (there are over 40 in Jefferson Hills) and do not realize that the impact of Marcellus wells will be quite different,” said Schumann. 
“These are not your grandmother’s wells,” said Volz. 
Trouble Ahead, Trouble Behind
More Violations Than Not
Ron Gulla’s pond was destroyed due to a lack of sediment control. “It was pathetic, a joke,” said Gulla.
Studies show that 28 percent of well violations, recorded by the DEP, are due to improper erosion and sediment plans. 
On average, 76 percent of wells receive violations.
In Ron Gulla’s case, getting the government to notice was the problem. “No one would help me, the DEP, the county, they all pointed fingers,” said Gulla. 
The Great Divide
The natural gas industry has been accused of employing a “divide and conquer” strategy in the communities in which it operates. 
Some citizens are happy to accept financial gain for their mineral rights, while others protest. 
“What about community members who don’t own the leased land, but live next door? They are exposed to noise, light, air pollution…to waste water, but they get no say,” said University of Pittsburgh’s Volz. 
Communities are at risk for divisiveness that comes from some of its members making money, while other members’ health and quality of life are compromised. 
Boom and Bust
Research shows that communities involved with energy boom times also experience behavioral health issues. 
“These communities have been shown to have an increased need for medical, behavioral and social services. Alcoholism and drug addiction increases, as does the divorce rate and even the number of sexual predators in an area,” said Volz.
Communities have also been promised jobs as part of the boom. “We have been tracking unemployment and haven’t seen an influence,” said Volz. 
“Most of the jobs are transient, but even the ones that come from training programs in Pennsylvania, those people won’t stay here. It’s the nature of the field, workers move on  to the next well,” said Volz. 
The Big Picture
Above all, this issue is about money and money talks. 
The natural gas industry is perceived as greedy. The industry has also been accused of preying on the poor, desperate farmers and the elderly.
But, what is happening in Jefferson Hills- an affluent area- points to something else. 
Greed on the part of residents. 
“Where is their conscious? Money and gain, it’s the way we’re programmed. It’s a tough sell, asking people not to take the money, but in the long run it will ruin your property value and your health,” said activist Loretta Weir. 
Long Term?
Pennsylvania Governor Tom Corbett has proposed slashing the state’s education budget, while refusing to tax natural gas. His contention is that the state’s economy will benefit by being the center of the gas boom and any taxation will drive out the industry- despite the fact that the gas cannot leave the state. 
“Forty years ago, there was this great insulator, it was asbestos. Look at what we know now. The shale has been there 300 million years, it’s not going anywhere. Until the industry can extract it in a safe way; what’s the hurry? Why risk it?” said activist Ken Weir. 
“One of the biggest problems is that there is little or no effort to consider or measure or account for or control the cumulative effect that this process will have in the long-term on water quality and quality of life and health of residents for local communities,” said Schumann.
The Road Ahead
How important is this issue? “It’s the issue of our time. We will be wrestling with this for the next 100 years,” said Volz. 
The U.S Energy Information Administration estimates the Marcellus Shale may have enough supply to meet the needs of the U.S. for the next 15 years. 
The next 15 years. 
Is it worth it? Worth the health risks? Worth the damage to the environment? Worth the impact on our quality of life? 
For so many in our consume all society, the cash at stake makes it an easy “yes”.
Ron Gulla disagrees. 
“You can’t put a price on quality of life. I was a multimillionaire before Range Resources came into my life and that was based on the quality of life I had,” Gulla said. 
Air emissions from drilling rig

The Environmental Impacts of Shale Gas Extraction


This article has been archived and is provided for reference purposes only.

By John Stolz, PhD – Duquesne University, Department of Biological Sciences

The Marcellus Shale represents one of the largest reservoirs of unconventional natural gas in the world.It holds the potential, like other gas and oil reserves, to provide a source of energy and jobs for Maryland. It’s extraction, however, is non-trivial and if done without proper safeguards can result in the degradation of water and air quality, and loss of land use. Over the past year I have had to opportunity to observe ongoing natural gas well activities in Western Pennsylvania, attended public hearings,spoken with disaffected individuals, gas company representatives, and people from other states with gas drilling activities. I would like to share with you some of my observations.Shale gas is called “unconventional” because the gas is trapped in the rock and needs to be extracted.The process, called hydraulic fracturing, involves a mixture of water, sand, and chemicals that are injected into the group at very high pressures (~10,000 psi). Each “frac” may require up to 5 million gallons of water. In Pennsylvania, this water is withdrawn from lakes, streams and rivers.

The large volumes of water are transported to a developing “play” by water trucks and deposited in large impoundments. These impoundments can be several acres in size and hold millions of gallons of water. A typical water truck may hold 4,500 gallons, so it takes several hundreds to thousands of truck trips to fill an impoundment.

The depth of the Marcellus Shale is between 5,000 and 6,000 feet below the surface in Western PA,thus a larger drilling rig is needed. A unique feature of these wells is that they are “horizontal” and may extend outwards several thousand feet in several directions. This is needed as the formation is relatively thin (~150’) in most places. A well pad may have 6 to 12 well heads. Each well produces~1,000 tons of drilling waste (ground up rock and drilling mud) that may contain a variety of salts, heavy metals, and naturally occurring radioactive material (NORM). This drilling waste may be buried on site or, more usually, transported to a land fill.

The well pad itself is 4-6 acres, in order to provide space for the trucks and containers, and impoundments for drilling mud, waste, and fracking. Once the horizontal has been drilled and cased, it is “fracked”. This process involves many vehicles, containers of sand and chemicals, the mixing trucks with fracking chemicals, and the diesel compressors (~200 vehicles). Hence the need for more space than a conventional well. During completion, the well is usually flared.

A completed well pad will typically have several well heads (the “Christmas tree), separators, small compressors, and condensate tanks (to handle the produced water). As long as a well pad is active (the well can be restimulated or used to drill a deeper formation), the footprint is still 4-6 acres. Depending on the number of wells, there may be as few as two condensate tanks or many more. They are sources of volatile organics as they are designed with “blow off” relief valves. Invisible to the naked eye these volatiles can be seen with specially designed infrared cameras.

The amount of produced water may also vary. For Marcellus, the initial flow back has been only about10 to 20% of the amount of fluids that were injected. Over time this “produced water” increases in total dissolved solid (TDS) content. The “brine” can be ten times saltier than seawater, contain high concentrations of bromide, chloride, strontium, and barium, as well as arsenic and uranium. In Pennsylvania, while the condensate tanks have hazard placards indicating the toxicity and flammability of the flow back water, the truck only is labeled “residual waste” and “brine”. Publicly owned wastewater treatment plants (POTWs) are allowed to take up to 1% of their total daily output. In Pennsylvania, there are currently at least 63 POTW’s permitted to take produced water. POTWs are not designed to“treat” produced water but merely dilute the salts.

This has resulted in increases in total dissolved solids(TDS), bromide in particular, in local rivers. The increase in TDS and bromide has caused problems with public drinking water facilities as the disinfectant process (chlorination) creates trihalomethanes (TMH, bromoform and chloroform). As a result many public drinking water facilities in the area have had to convert from chlorination to chloramination to reduce the formation of THMs. However, chloraminated water can cause the leaching of lead from older pipes and fittings. And there will be spills. Over the past 2.5 years, the PA-DEP has cited the industry with over 1,600 violations. Many of these were for improperly constructed impoundments, chemical spills, and surface contamination.

There are other aspects to the industry as well. Methane is a colorless, odorless gas, that needs to be odorized with mercaptan. The product from the Marcellus in Western PA is not dry gas but a combination of other organics as well. Thus the gas needs to be “dried” in refineries. Propane and butane are “cryo” separated in these facilities. These complexes are a source of volatile organic compounds and are frequently flaring off residual organics. They are also flanked by compressor stations that pressurize the gas for the pipeline.

The industry can move very quickly as has been recently demonstrated in Hickory-Houston, PA area,where since 2005 there are now over 80 well pads, impoundments, compressor stations, and other gasfacilities within a five mile radius.

The extraction of unconventional natural gas is heavy industry involving large tracts of land, heavyequipment and vehicles, and an extensive array of pipelines, compressor stations, and processing facilities. The level of surface disturbance is extensive, as has been demonstrated elsewhere (e.g.,Colorado, Wyoming, Texas, Arkansas, Louisiana). Existing industries such as agriculture, tourism, outdoor ventures (e.g., fishing, hunting, and camping), and wineries, will be lost or significantly impacted. In Pennsylvania there have already been loss and contamination of well water, and loss of livestock and quarantined herds after exposure to contaminated water.<

Summary of Environmental Impacts


  • The amount needed for fracking (5 million gallons/frac)
  • Loss of well (aquifer) water through disruption or contamination
  • Gas migration causing methane contaminated water
  • The fate of the produced water (“treated” at POTWs)
  • Degradation of water quality in local streams and rivers
  • Degradation of drinking water quality (need to purchase bottled water)

Land usage

  • Large amount of acreage needed for well pads and impoundments
  • As long as a well can be “restimulated”, the well pad will remain active
  • Leased areas (former private and public lands) become restricted access
  • Public lands and parks no longer “public” as they are off limits due to safety

Exposure to toxic chemicals (spills, aquifer contamination)

  • Fracking fluids
  • Produced water contaminated with organics, salts, heavy metals, and NORMs
  • Failed or improper casings lead to aquifer contamination

Traffic and road degradation

  • Significant increase in trucks and vehicles cause road and bridge deterioration
  • Trucks may exceed weight and height limits


  • Heavy equipment, increased traffic,
  • Low frequency sounds during fracking
  • Compressors and compressor stations

Air pollution

  • Increased vehicle traffic
  • Well flaring
  • Release of VOC’s from well installations (condensate tanks are vented by design)
  • Compressor stations
  • Well blow outs

Property devaluation

  • Mortgages and home equity loans jeopardized by presence of wells
  • Mine subsidence insurance compromised or negated
  • Land owner ultimately responsible for taxes and environmental damage

EMS and emergency procedures

  • Evacuation plans must be in place for populated areas (a single well blow out can affect more than 1 mile radius)
  • EMS, police and fire must be trained to handle emergencies (well and impoundment fires, evacuations)

Increases taxes to cover infrastructure damage, additional public services and security.

John F. Stolz, Ph.D.
Professor, Department of Biological Sciences
Director, Center for Environmental Research and Education
Duquesne University
Pittsburgh, PA 15282