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Conclusions
What
we do have is the Office of Oil and Gas' verbal statement
that the spill consisted of fracture flowback from a Marcellus
well. We know that an operator and well received a Notice
of Violation.
What
we don't know is when the spill actually occurred. Material
on the banks of the creek and on stones by the creek made
marks that showed that the water level had dropped since the
spill took place.
We
also don't know the source of the spill, but it is assumed
it was a breached pit.
Pits
in this state and the waste they hold are regulated by the
Office of Oil and Gas. A General
Water Pollution Control Permit has requirements for immediate
reporting if there is a spill or accidental discharge from
a pit.
Regulations
that come into effect with a spill include 35CSR1.3 which
requires notification within 24-hours of a "reportable
discharge." Reportable discharges include those covered
by section 311(b) of the Clean Water Act. 40CFR110.3 pertains
to oil discharges "in such quantities as may be harmful"
pursuant to section 311(b)(4) of the Act. These include discharges
that "cause a film or sheen or discoloration of the surface
of the water." The spill at Buckeye Creek seems to be
both a clear violation of the Clean Water Act and also the
reporting requirements of 35CSR1.3. If the spill was caused
by a breached pit, that would be covered by 35CSR4.16.4.
A
photograph of the well site taken on 26 September shows some
issues:
The
circle at A is a pump located on the bank above the creek.
It appears to have been used for dewatering the creek (filling
the large impoundment nearby). The state has no regulation
with a limitation for the minimum distance a pit can be to
surface water. In this case, the pit is constructed next to
a creek with crumbling banks and a continually changing course.
The
circle at B shows a collapsing corner. There doesn't appear
to be a tear in the liner yet. The state has no guidance for
the construction and maintenance of a pit and this pit's construction
shows several flaws, including levee walls that are too vertical
(which leads to collapse). We've seen photographs of other
pits in this state where the edges of the pit liner lie unanchored
on the top of the narrow levee bank. The pit liner needs to
be anchored properly and the levee bank needs to be at least
2 feet wide. These construction requirements are crucial when
a pit is this large.
The
circle at C shows the only area where another pit could have
been placed from studying the photographs of this site. If
a pit had been here, it's been reclaimed. Drainage from this
area would go directly to Buckeye Creek.
And,
finally, the circle at D shows a large condensate storage
tank without proper secondary containment (required by state
and federal regulations). Photographs taken on 2 September
show the secondary containment dike in place. Large red objects
placed around the tank, barely visible in this photograph,
might be absorbent pads. While the spill has been called a
fracture flowback spill, it has many of the characteristics
of a condensate spill (the high TPH).
At
this point there are more questions than answers until the
site is properly examined.
The
Spill at Buckeye Creek
Background |
Photos, part 1| Photos, part 2|
Photos, part 3| Photos, part 4
Timeline | Laboratory
Tests | Conclusions
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