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Waste Pits    

This is an examination of the chemicals used in drilling and found in waste, and their management.

Pits
   Pit Liners
   Pits
   Current state regulations
   Recommendations for change

Drilling Waste Management
  
What Happened at Fernow
  
The Spill at Buckeye Creek

The Gas Well Study

Reclamation

The Old Well


 

West Virginia Regulations for Drill Waste Pits

West Virginia's regulations appear in three platforms: Code of State Regulations, Erosion and Sedimentation Control Field Manual and General Water Pollution Control Permit. We've taken the relevant parts from each platform and present them here.

Code of State Regulations (35 CSR 4.16.4)
16.4. Pits - All field constructed pits which are used to contain wastewater shall meet the following minimum requirements:

16.4.a. Any pit shall be constructed and maintained so as to prevent seepage, leakage or overflows, and to maintain its integrity.

16.4.b. Provisions shall be made for diverting surface water from the pits.

16.4.c. When an operator is unable to maintain adequate freeboard to prevent overflow from any pit, the district inspector shall be notified by the well operator and an additional pit (or alternative overflow facility) shall be constructed under the supervision of the chief, which shall also meet the requirements specified in this subsection (16.4).

16.4.d. If existing soil is not suitable to prevent seepage or leakage, other materials which are impervious shall be used as a liner for a pit. Any such liner shall be installed in such a manner as to protect the structural integrity of both pit and liner.

16.4.e. Dikes associated with pits shall be constructed of compacted material and maintained with a slope that will preserve the structural integrity of such dike.

16.4.f. Any unlined dike constructed of existing soil shall be free of trees and other organic matter, large rocks, or any other material which could be reasonably expected to adversely affect the structural integrity of such dike.

16.4.g. Reclamation of the pits shall not cause an overflow and/or discharge of materials to waters of the state.

16.4.h. All drilling pits and alternative overflow prevention facilities shall be constructed, maintained, and reclaimed so as not to be left in such condition as to constitute a hazard or to prevent use of the surface for agricultural purposes after the expiration of the six (6) month or extended period for reclamation prescribed by W. Va. Code '22-6-30.


Erosion and Sedimentation Control Field Manual
II.B.2. Pit Construction
a. Site Selection: The pit should be constructed in an area with adequate room, so it can handle the projected drilling & frac fluids, plus allowing for adequate freeboard during heavy rainfall. Avoid excessive steep areas, wet seepage areas, swamps, and excessive rocky areas, when possible.

b. The pit shall be constructed and maintained so as to prevent seepage, leakage, and overflows.

c. Pits should be constructed blow ground level, when possible. Any aboveground pit walls, as in the case with pits constructed in the lower slope areas of the wellsite, shall be compacted, with a side slope being maintained that will preserve the structural integrity.

d. Avoid placing any brush, trees, tree limbs, roots, or large rocks in the pit walls.

e. Surface water must be diverted from the pit.

f. If the existing soil is not suitable for the pit to be "impervious", suitable soil may be brought in or other impervious materials should be used, such as:
(1) Gel & pit sealant
(2) Plastic pit liners (hay or straw bedding may be needed)
(3) Clay

g. Pits constructed on location, should be constructed in solid ground, preferably on the cut or highwall side, not in the fill area. Adequate room should be allowed between the base of any highwalls and the pit, for the construction of a surface water drainage ditch.

(Figure II-12 Air Pit Construction and Figure II-13 Mud Pit Construction have not been reproduced here. Figure II-13 seems to show 2 feet freeboard.)

III.A. Wellsite Reclamation
1. Pit water treatment & disposal (as per "General Water Pollution Control Permit")

2. Pit backfilling: Filling with dirt and recontouring. No brush, trees, tree tops, or stumps are to be buried in the pits.


General Water Pollution Control Permit
G. Other Requirements
1. The discharge of treated and untreated pit wastewater or sludge, caused by any reason such as, but not necessarily limited to, leaking, overflowing or an unstable, breached or unreclaimed pit, into waters of the State is prohibited except as allowed by this permit.

2. A temporary fence or suitable barrier shall be constructed surrounding the pit(s), as needed, to prevent vandalism or inadvertent livestock intrusion.

10. Minimum requirements for field constructed pits which are used to contain wastewater include:

(a) Constructed and maintained to prevent seepage, leakage or overflows and to maintain its integrity;

(b) Construction or provisions for diverting surface water from the pits;

(c) Approval from district inspector for construction of an additional pit (or alternative overflow facility) meeting the requirements specified herein in order to attain adequate freeboard.

(d) Constructed or lined such that the pit is impervious. Liners shall be installed in such a manner as to protect the structural integrity of both pit and liner.

(e) Constructed dikes shall be of compacted material and maintained with a slope that will preserve the structural integrity of the dike.

(f) Be free of trees and other organic matter, large rocks, or any other material which could be reasonably expected to adversely affect the structural integrity of the dike.

(g) Reclamation so as not to cause an overflow and/or discharge of materials to the waters of the State.

(h) Prepare site-specific plans or generic plans for pit construction as may be required by the Chief on a company-by-company or site-by-site basis as a special condition of this permit.

15. If the provisions of Section G.7-10 of this permit are being adhered to at the individual site, the storm water runoff from the disturbed site may be directed into the pit.

[Note: In the 1980s when the General Water Pollution Control Permit was created there was a broad awareness of the scope and scale of pit failures. The Office of Water determined that pit failures or breaches occurred at about a third of all drill sites and for this reason the General Water Pollution Control Permit includes material about pits and construction.]

 

 

   

The Gas Well
The Old Well | Reclamation| Gas Well Study
Drilling Waste Management | What Happened at Fernow | The Spill at Buckeye Creek