From Pilot Study to Daily Processing

Warren, Ohio’s Documentary to

Hydraulic Fracturing Water Treatment

By Tom Angelo

Director

City of Warren, Ohio

Water Pollution Control Department
In May of 2009, Warren and Patriot Water Treatment LLC began discussions with 

the OEPA to initiate the treatment of brine water from the Marcellus Shale.

Warren was asked to perform an eight (8) week pilot study to 

“clearly identify the amount of brine that Warren can receive 

without causing WWTP or water quality issues.”

This demonstrated that the facility could accept up to 664,000 gallons of 

brine water at 50,000 mg/l TDS before toxic conditions occurred. 

Charged with this task, Warren first had a whole effluent toxicity (WET) test 

accomplished on September 4, 2009 to determine the ceiling of brine water 

acceptance.
An organizational meeting was held January 8, 2010 to set guidelines for the pilot study. 

The guidelines were set as follows:

1. Patriot Water Systems would supply ten 20,000 gallon frac tanks.

2. The tanks would be connected together to create one 100,000 gallon mixing system.

3. Brine water would be re-circulated in the combined tanks to create a homogeneous mix.

4. The initial mix will be tested for the parameters as defined by OEPA.

5. The City will sample influent, effluent, upstream and downstream prior to the discharge 

of brine water to develop a baseline concentration of TDS.

6. The City would conduct a live, 8 week, phased in trial to monitor and record effects on 

treatment processes, accumulation loading and receiving stream TDS.

7. The maximum amount of TDS in the brine water will not exceed 50,000 mg/l.
An organizational meeting was held January 8, 2010 to set guidelines for the pilot study. 

The guidelines were set as follows:

8. Brine water will be phased in as follows (all flows will be over an 8 hour period):

• Week 1 – 5 days at 20,000 gallons 

• Week 2 – 5 days at 40,000 gallons

• Week 3 – 5 days at 60,000 gallons

• Week 4 – 5 days at 80,000 gallons

• Week 5 – 5 days at 100,000 gallons

• Week 6 – 5 days at 100,000 gallons

• Week 7 – 5 days at 100,000 gallons

• Week 8 – 5 days at 100,000 gallons

9. Testing will be accomplished as defined in Addenda 3 
Acute & Chronic Toxicity Volatile Organic Compounds

Base Neutral Organic Compounds Acid Organic Compounds

Pesticides & Total Phenols MBAS

Aluminum Antimony

Silver Barium

Beryllium Boron

Cadmium Chromium

Copper Iron

Nickel Lead 

Selenium Strontium

Zinc Hexavalent Chromium

Low Level Mercury pH

HEM Oil & Grease Total Dissolved Solids

Total Suspended Solids Total Phosphorus

BOD5 COD

TOC Total Nitrogen

Ammonia Nitrogen Nitrate/Nitrite Nitrogen

Total Uranium Total Thorium

Total Alpha Total Beta

Barium Strontium
BASELINE SAMPLING

Initial baseline testing was accomplished on the river and plant flow to determine 

TDS levels prior to start-up of the pilot study. The baseline levels are as follows:

Baseline Level TDS Chloride

Raw 584 143

Final 599 157

Up 336 70

Down 332 60

Liquid Sludge 296

Initial radioactivity sampling:

Collect date 2/17/10

 

Parameter Results Units

Gamma Scan All other nuclides <LLD pCi/L

K-40 2.6E+02 +/- 2.6E+01 pCi/L
TDS is greatest pollutant of concern. Of that, 

Chlorides or salt, is the largest proponent.

Raw TDS average increased to 679 mg/l which is approximately 16% over the baseline 

of 584 mg/l. The average final effluent TDS increased by 47.8% above the baseline.
TDS OVERVIEW

Daily Chloride Loading to the River

This information provides a better model of loading in terms of pounds of chlorides to the 

river. 

BASELINE DAILY CHLORIDE LOADINGS

Upstream Downstream Plant

Avg Avg Avg

Avg Daily Daily Daily

River Flow Load Load Load

MGD lbs/day lbs/day lbs/day

867.27 506,314.39 484,615.20 20,439.42
TDS OVERVIEW

STUDY RESULTS - DAILY CHLORIDE LOADINGS

Upstream Downstream Plant Effluent

Avg Peak Avg Peak Avg Peak

Avg Daily Daily Daily Daily Avg Daily Daily

River Flow Load Load Load Load Plant Flow Load Load

MGD lbs/day lbs/day lbs/day lbs/day MGD lbs/day lbs/day

867.27 852,488.76 1,612,972.97 873,134.10 1,446,612.53 15.61 46,867.46 118,995.12

% Over Baseline 168.37 318.57 180.17 298.51 229.30 582.18

Lbs. Over Baseline 346,174.38 1,106,658.59 388,518.90 961,997.33 26,428.04 98,555.70

This information demonstrates that the river was able to assimilate a peak daily load of 

chloride 318% greater than the baseline loading without any toxicology issues. In total 

pounds applied this means that an additional 1,106,658 pounds of chlorides over 

baseline was assimilated without adverse affects to the river biology. Warren’s highest 

peak daily loading of chloride was only 118,995 pounds.
EPA Questions

What caused the high effluent results on 4/13, 4/14, and 4/15?
Toxicology

Overall the results of the study indicated that if Patriot Water Treatment 

discharges a consistent amount of brine water over an extended period of 

time then there will be no adverse changes in the water quality of Warren 

WWTP or in the Mahoning River downstream of outfall 001.
Pilot Study 

Conclusion

The 8 week Pilot Study demonstrated 

that a controlled discharge of brine 

water into Warren’s WWTP did not 

have adverse water quality impacts to 

the treatment facility or receiving 

stream. 
Concerns

• Allow high levels of heavy metals to enter the 

receiving stream.

• Potential for radiation.

• Contaminate source drinking water and ground 

water.

• Increase TDS Levels in the receiving stream, 

specifically Chlorides or salt.
Daily Processing

Ohio’s whole model for the treatment of low TDS flow back brine 

wastewater was based on the observance of issues that was 

witnessed during 2009 through 2010 by treatment plants that was 

processing brine wastewater in Pennsylvania.
Daily Processing

• Only Flow Back, muddy and brackish brine water will be allowed for treatment. 

No Produced water will be allowed.

• Direct discharge to a municipal wastewater treatment plant will not be allowed. 

Brine water must go to a centralized waste treatment facility (CWF) for 

pretreatment prior to discharging to a municipal wastewater treatment facility 

(POTW). The CWF will remove heavy metals, suspended solids and other 

pollutants to categorical and local limits and adjust pH prior to discharge.

• A limit will be set on the total volume of brine water that can be treated daily. 

This limit will be established based on the ability of the treatment facility to 

assimilate without toxic conditions or water quality conditions occurring.

• A limit of no greater than 50,000 mg/l of TDS in the flow will be allowed to be 

discharged from the CWF into the POTW.

• All brine water will be regularly tested for heavy metals, radiation and volatile 

compounds and will be summarized in a daily operational report.

• Quarterly toxicity testing will be accomplished by the POTW. 
Daily Processing

• October of 2010, OEPA issued a PTI to Patriot Water 

Treatment 

• December 1, 2010, OEPA issued a NPDES modification 

to Warren that would allow for the acceptance and 

treatment of low TDS flow back brine wastewater from 

a CWF. 

• Total acceptance of 100,000 gallons of flow back brine 

per day at a maximum concentration of 50,000 mg/l 

TDS.
Daily Processing

• The overall success of this program 

depended on how TDS would 

impact river quality.

• Warren initiated a self-imposed 

river sampling program that 

monitored TDS levels throughout 

the watershed.

• A total of 8 locations were finally 

part of the sampling regiment.

• Analyze for both Chlorides and 

Sulfides.

• Analyze for Bromide.

Increase TDS levels in receiving stream
Daily Processing

• December 2010, Warren filed an appeal with the 

Environmental Review Appeals Commission (ERAC).

• May of 2011, OEPA issued a letter to the Ohio Department 

of Natural Resources (ODNR) indicating that the permits 

issued to Warren and Patriot were in violation of ORC 

1509.22 and would not renew the modification when 

Warren’s current permit expired on December 31, 2011.

• Legal Battle throughout 2011 & half of 2012.

• OEPA issues a new NPDES to Warren April 1, 2012.

• Section BB; permittee shall stop accepting brine wastewater from oil or 

gas drilling, exploration or production

State Showdown
Daily Processing

• Warren ordered Patriot to cease discharging brine water to 

its Municipal Wastewater Plant effectively shutting down 

Patriot. 

• ERAC hears Warren/Patriot’s appeal (april/may 2012)

• July 3, 2012 ERAC determined that Section II, BB of the 2012 

Warren NPDES was both unlawful and unreasonable.

• ERAC unilaterally modified Warren’s NPDES to remove 

Section II, BB in its entirety.

• Patriot restarts operations in July of 2012 and Warren has 

continued to receive daily discharges since.

State Showdown
Daily Processing

• September 2011,USEPA Region 5 conducted a compliance 

inspection to determine that the Warren WPCC was only 

accepting brine waste water generated from the oil and gas 

industry from one CWT facility (Patriot), and that the POTW 

had not experienced any of the following conditions since 

accepting the brine waste water: 

1. Diminished or inhibited performance of the biological 

treatment processes, 

2. Adverse impacts to the downstream water quality, 

3. Adverse impacts to the quality of the facility’s biosolids.

USEPA Compliance Inspection
Daily Processing

• Both Warren and Patriot were inspected and numerous 

tests were conducted. Overall, approximately 950 pages of 

documents were generated from the report. A summary 

of the key constituents of concern is shown below:

USEPA Compliance Inspection
Daily Processing

• In addition to a complete metals analysis, radiological 

screening was accomplished.

• The report concluded that Warren’s POTW was in compliance 

with the NPDES permit limitations.

USEPA Compliance Inspection
Summary

The waste treatment model used in Warren has almost 2 1⁄2 years of 

operational data that demonstrates that it is a safe and viable 

alternative disposal that compliments other disposal options 

including deep well injection. The model requires both a CWT and a 

POTW. It requires extensive testing by both entities which are 

mandated and voluntary. It only allows for a small percentage of 

hydraulic fracturing wastewater to be accepted. The water that this 

model accepts; low TDS, pit, flowback, muddy and storm waters are 

also the waters that are most problematic for deep well injection.
Benefits

The waste treatment model used in Warren has almost 2 1⁄2 years of 

operational data that demonstrates that it is a safe and viable 

alternative disposal that compliments other disposal options 

including deep well injection. The model requires both a CWT and a 

POTW. It requires extensive testing by both entities which are 

mandated and voluntary. It only allows for a small percentage of 

hydraulic fracturing wastewater to be accepted. The water that this 

model accepts; low TDS, pit, flowback, muddy and storm waters are 

also the waters that are most problematic for deep well injection.