From: Lockhart, John V [mailto:John.V.Lockhart@wv.gov] 

Sent: Tuesday, June 03, 2014 9:34 AM

To: Biddle, Lisa

Subject: FW: West Virginia Oil and Gas Wastewater Management

Lisa,

The triangle on the figure is most likely the City of Weston WV0028088 – they accept CBM wastewater 

from Schlumberger Oil Field Services.

John

From: Lockhart, John V 

Sent: Tuesday, June 03, 2014 9:22 AM

To: 'Biddle.Lisa@epa.gov'

Subject: RE: West Virginia Oil and Gas Wastewater Management

Lisa,

Matt told me to follow up with you...

There is no prohibition on accepting Shale wastewater in WV. The POTWs have chosen not to accept 

Shale wastewater due to the many requirements that will be imposed in the accepting facilities permit if 

they do start accepting (see attachment). Currently I know of no POTW in WV accepting Shale water. 

We do have 2 CWTs (WV0116408 – Fairmont Brine; WV0116441 – Reserve Environmental) that have at 

one time and will soon be accepting Shale wastewater and I think there are a few mobile treatment 

units floating around the State but they do not require a permit (i.e. recycle only). My guess is that 

neither of these are operating at the moment. Fairmont Brine is close for I was up there a couple weeks 

ago and they are almost finished retrofitting. Reserve was not constructed a few months ago when I last 

checked their status.

Wheeling experienced ammonia violations which was attributable to the high chlorides levels accepted 

from the Shale wastewater. They chose to discontinue acceptance of the wastewater from Liquid Assets. 

Liquid Assets has since proposed to build a recycle system (now Reserve Environmental) and hold their 

own individual storm water only permit. Unclear if they have started accepting wastewater yet.

Clarksburg at one time was accepting Shale wastewater but if I recall had chlorides issues and decided it 

was not worth continued acceptance.

I learned a couple weeks ago that the City of Fairmont may be considering acceptance of treated 

wastewater from Fairmont Brine in the near future. The agency’s pretreatment coordinator is currently 

going over what the requirements would be for that activity.

The general problem with the wastewater is if untreated (straight from the site) it is high strength for 

many parameters that are generally not treatable (or treatability is limited) by conventional POTW 

treatment processes. Also there is a question of whether radiation would be present (alpha, beta, 

radium) in harmful amounts at the headworks which would cause concern for worker exposure or 
sludge contamination. WV has never been able to get a good answer on the TENORM question. Basically 

we have defaulted to “cannot accept” TENORM containing materials without prior approval from DHHR 

or NRC. The most recent permits also have IH scans for radiologicals based on EPA’s water treatment 

plant guidance. If a POTW would start accepting this would probably be a requirement until the agency 

can confirm the presence/absence of radiologicals in harmful amounts.

The 3 cities you list have their own Pretreatment Programs so I can’t say for 100% sure they are not 

accepting; however, the agency notified the delegated cities that if they were to start accepting they 

would have to notify us (see attachment).

As for the triangle on Figure 9 I don’t think is Clarksburg – it looks in the area of City of Buckhannon and 

may be CBM wastewater not Shale for they received the letter indicating the requirements the agency 

would impose too (I have attached a draft copy/example of the letter sent). Hard to tell from that figure 

though.

Note acceptance of Shale wastewater was circa 2009 timeframe. The issue has been pretty dead for a 

few years know I think most generators are shipping the wastewater out of WV for treatment due to the 

agency’s conservative stance.

Call me with questions,

John V Lockhart, P.E.

West Virginia Department of Environmental Protection

Division of Water and Waste Management

601 57th Street SE

Charleston, WV 25304

304.926.0499 x1028 phone

304.926.0496 fax

john.v.lockhart@wv.gov

www.dep.wv.gov

From: Biddle, Lisa [mailto:Biddle.Lisa@epa.gov] 

Sent: Wednesday, May 28, 2014 5:21 PM

To: Sweeney, Matthew L

Cc: McFadden, Angela; Sarah Yates (sarah.yates@erg.com)

Subject: RE: West Virginia Oil and Gas Wastewater Management

Hi Matt,

I am following up to the voice message I just left you. I wanted to circle back with you on this and see if 

you’ve had a chance to check into whether or not you have POTWs accepting shale gas/oil wastewater

from well operators. In particular, if you have any specific information on the Wheeling POTW and/or 

the Clarksburg POTW, which may have taken these wastewaters in the past, that would be helpful 

(especially verifying whether or not they are currently accepting shale gas or oil wastewaters). My email 

below asks about some other facilities that are also of interest too. But if your time is limited, if you 

could at least provide the info on Wheeling and Clarksburg POTWs that would be a good start. 

Thanks for your time,
Lisa

_____________________

Lisa A. Biddle

U.S. EPA, Office of Water

ph: (202) 566 0350

Biddle.Lisa@epa.gov

From: Biddle, Lisa 

Sent: Wednesday, April 09, 2014 8:45 AM

To: Sweeney, Matthew L

Cc: Sarah Hays; McFadden, Angela

Subject: RE: West Virginia Oil and Gas Wastewater Management

Thank you for the message Matt. We are not focused on CBM wastewater, so you do not need to go to 

lengths to summarize information about facilities that do not take shale gas/oil wastewater and only 

take CBM. Is that documented somewhere in a rule or agreement (that they will only take CBM 

wastewater out of the oil and gas wastewaters that could be generated and accepted at a POTW)? 

Again, thanks for your help on this!

-Lisa

_____________________

Lisa A. Biddle

U.S. EPA, Office of Water

ph: (202) 566 0350

Biddle.Lisa@epa.gov

From: Sweeney, Matthew L [mailto:Matthew.L.Sweeney@wv.gov] 

Sent: Tuesday, April 08, 2014 7:24 PM

To: Biddle, Lisa

Cc: Sarah Hays; McFadden, Angela

Subject: RE: West Virginia Oil and Gas Wastewater Management

Lisa,

Sorry for the delayed response. This will take some time for me to compile updated information. I am 

currently swamped with some permits and appeals. I will try to get back to you this month with some 

updated info. If I am recalling from memory correctly, I do not believe we have any POTWs taking any 

shale wastewater, but there may be a couple taking CBM wastewater. I will need to compile some info 

to verify in order to provide accurate answers to your questions. If you are not interested in POTWs 

taking CBM wastewater, let me know and I will not compile that information in my research.

Thanks,

Matt Sweeney, P.E.

NPDES Individual Permitting Supervisor

WV Department of Environmental Protection

Division of Water and Waste Management

601 57th Street, SE
Charleston, WV 25304

(304) 926-0495

From: Biddle, Lisa [mailto:Biddle.Lisa@epa.gov] 

Sent: Tuesday, March 25, 2014 3:25 PM

To: Sweeney, Matthew L

Cc: Sarah Hays; McFadden, Angela

Subject: West Virginia Oil and Gas Wastewater Management

Hello,

Dana Walker and Angela McFadden in EPA’s Region 3 Office suggested I contact you for some help with 

information we are looking for about oil and gas wastewater management in the state of West Virginia. I 

work in EPA’s Office of Water in a group that writes Effluent Limitations Guidelines and Standards. We 

are working on a pretreatment standard for wastewater that is generated from the unconventional oil 

and gas industry. As part of the regulatory development process we write a Technical Development 

Document which provides background on the industry and details about what we’ve learned pertaining 

to industrial wastewater management, characteristics, and general industry practices. We have been 

compiling data from existing literature, States, research/presentations, site visits, operators, etc., 

pertaining to unconventional oil and gas wastewater characterization and management practices. A 

summary of the rulemaking effort can be found here: 

http://water.epa.gov/scitech/wastetech/guide/oilandgas/unconv.cfm.

It is my impression that, in light of the recent state requirements, shale gas wastewater is no longer 

being disposed of at POTWs in WV. But I wanted to check in with you to make sure my understanding is 

correct. Also, there are some more detailed questions below which I think you may be able to help us tie 

up to tell the background on oil and gas wastewater management in WV accurately.

I have attached a document titled, “Water Resource Reporting and Water Footprint from Marcellus 

Shale Development in West Virginia and Pennsylvania”. This document notes that, between 2010 and 

2012 in WV, about 22% of flowback was disposed of via underground injection and about 1% was 

disposed of via POTWs. Although there is only a small volume of O&G wastewater being disposed of at 

POTWs, we’re still interested in identifying those POTWs. We have the following questions about 

POTWs in WV:

1. In addition to the names of any POTWs that have accepted (or currently are accepting) O&G 

wastewater, we’d like to know the following information:

- Is the POTW currently permitted to accept O&G wastewater? Are there any limitations to 

the type of water the POTW can accept (e.g., not allowed to accept shale gas wastewater)?

- Is the POTW currently accepting O&G wastewater? If so, what is the source of the 

wastewater (e.g., conventional O&G, unconventional (shale gas) O&G, CWT facility)?

- What quantity of O&G wastewater was/is accepted by the POTW? What volume of 

wastewater was/is from conventional O&G wells and what volume was/is from 

unconventional O&G wells?
2. Are you aware of any problems experienced by the POTWs that have accepted O&G 

wastewater as a result of accepting the O&G wastewater? We’ve heard that the Wheeling 

POTW experienced some issues while accepting O&G wastewater from LAD CWT. If there is 

additional information on that which you could provide (e.g., a report about the problems 

experienced by Wheeling), that would be very helpful.

3. To-date, we have identified the following POTWs as having accepted O&G wastewater. Can you 

verify that the information below is correct and can you provide any additional information 

and/or updates, where available?

a. Clarksburg POTW (WV0023302) – Unclear whether or not they are accepting any O&G 

wastewater. Please inform about the status of this POTW, where data are available.

b. Morgantown POTW (unknown permit number) – Accepted conventional oil and gas 

(COG) wastewater directly from a COG operator in 2006. Not currently accepting any 

O&G wastewater.

c. Wheeling POTW (WV0023230) – Accepted unconventional oil and gas (UOG) 

wastewater directly from a UOG operator in 2008 as well as from the “Liquid Assets 

Disposal” CWT. Unclear whether or not they are currently accepting any O&G 

wastewater.

Figure 9 (on page 34 of the pdf) identifies a POTW in the central part of WV. It doesn’t 

appear that this POTW is the Wheeling POTW or Morgantown POTW that we’ve identified, 

but it could possibly be the Clarksburg POTW. Can you verify that it is the Clarksburg POTW, 

or, if not, can you otherwise identify it?

Thanks for any information you can provide. If I can help clarify anything, please let me know and we 

can set up a time to talk.

-Lisa

_____________________

Lisa A. Biddle

U.S. EPA, Office of Water

ph: (202) 566 0350

Biddle.Lisa@epa.gov