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What
Happened at Fernow
When
we learned about the landspraying debacle at Fernow Experimental
Forest George made a few phone calls in February. Some of
what we'll describe is from those calls and from documents
released by PEER (on
their website or to Ken
Ward, Jr., a West Virginia Gazette reporter).
The
well was reportedly drilled using only compressed air and
water with no additives. Air drilling frequently also uses
a sodium chloride based foaming agent (here's
a MSDS sheet for one company's product) but that supposedly
wasn't the case at the Berry Energy well.
After
drilling, the well was fractured and as part of the completion
process a tallow plug was used to hold the fracturing fluids
in the formation. (We believe the well was drilled using underbalanced
techniques and was without a conventional blowout preventer,
thus the plug.) When Berry drilled through the plug they lost
control of the well and fracturing fluid flowback sprayed
out of the well and killed surrounding foliage.
There
are one to maybe two dozen trees, mostly smaller ones, immediately
adjacent to the well pit on the lower west side, and a few
above the well pad, where the foliage is brown, and indeed
on the lower west side, there is little to no ground vegetation.
At a casual glance it appears that the area was burned, but
there's not really any charring to support that. (From
documents released by PEER to Ken Ward, Jr.)
A
Forest Service document attributes the leaf wilting and vegetation
death to the high pH tallow, but we believe the cause was
extremely low pH and high chlorides (both from the hydrochloric
acid used for fracturing).
Berry
treated the pit waste, but used inadequate
activated carbon, and landsprayed 100,000 gallons according
the DMR. Actually, what happened was they landsprayed about
80,000 gallons on about half an acre until the Forest Service
was able to get them to stop. Berry then landsprayed the balance
of the waste on another part of the Forest.
 In
the smaller area that received 80% of the waste, landspraying
resulted in immediate wilting and death, including understory
trees. We were told the pit fluids killed "even the greenbriar."
In the second, later area, red oaks emerging from acorns and
other plants showed damage. The landspraying occurred during
a typical wet June/July. This was before the long drought-like
period of no rain that came later.
We
believe a contributing cause of vegetation death was high
chlorides, an incredibly large amount of salt (over two tons)
dumped on a small area.
Chlorides
cause "salt shock." Wilting results because "a
high concentration of salts produces high osmotic pressure"
(Howat)
. Plants can't get either water or nutrients. Each species
reacts to high salinity differently, but even a species with
salt tolerance, unexpectedly exposed to high levels, will
be affected adversely. In addition, sensitivity to salt may
be highest during certain phases of lifecycle, such as germination.
Plants
that do survive in soils with high levels of chlorides show
specific characteristics: "a smaller stature, with darker,
more bluish foliage and occasionally brown leaf tips, leaf
mottling, leaf curling and/or chlorosis. A high chlorophyll
content and thicker cuticle produces the bluish color"
(Howat)
.
Forest
Service tests of pit fluids are at variance with Berry's results
shown on the DMR. Forest Service researchers were surprised
by the differences in constituent concentrations they encountered
when testing pit waste. They had found a low concentration
of chlorides (4,880 mg/l on June 19) but tested a much higher
concentration than Berry's
DMR results during discharge (13,500 to 14,250 mg/l on
June 20). The high concentration of chlorides was still within
the state's requirements (if permission from an inspector
was given), but if the Forest Service's discharge testing
was a good indication of the actual overall concentration
of chlorides in the fluids, that means more than double the
chloride load than Berry's DMR indicated.
Another
concern is two Forest Service tests showing the fluids' pH
above 10, the state's maximum for landspraying. One test found
a pH of 10.51, the other just before discharge found 11.65.
A substance is automatically considered hazardous if its pH
is 12.5 or higher.
The
discharge of an extremely caustic liquid onto the forest could
be a contributing cause of plant mortality, just as we believe
the extremely low pH fracture flowback was a contributing
cause during the earlier incident.
We
believe the extremely high pH came from treating the pit fluids
with caustic soda (NaOH) instead of lime. Caustic soda has
a pH of about 13-14 and performs similarly to lime in the
hydroxide treatment required by the state, except that the
quantity of salts (and sodium) produced is much higher.
In
these chapters we've focused on chlorides, sodium, and to
a lesser degree pH. This doesn't mean that dangerous chemicals
used during fracturing aren't an issue, they are. But we don't
believe that exotic chemicals were the cause of vegetation
dieback.
Here's
a quote from a monograph by T.
T. Kozlowski:
Salinization
transforms fertile and productive land to barren land, and
often leads to loss of habitat and reduction of biodiversity.
Salinity limits vegetative and reproductive growth of plants
by inducing severe physiological dysfunctions and causing
widespread direct and indirect harmful effects, even at low
salt concentrations. (page 12)
In
another month or two we'll try some experiments to see if
we can reproduce what happened at Fernow Experimental Forest.
We'll use the proposed drill site here, our sacrifice area.
We'll mark out 1 foot by 1 foot plots and "water"
them with table salt added to plain rainwater. We'll use varying
levels of salt and total fluid and we'll report on what we
find out.
This
spring Forest Service researchers will begin to be able to
determine how extensive the landspraying and fracture flowback
damage will turn out to be.
Our
research has shown that the landspraying debacle at Fernow
Experimental Forest was both predictable and preventable.
If the state's program had consideration for chloride load
it would have been obvious to the Office of Oil and Gas that
the land application area in the permit for B800 was grossly
undersized. It would also have been obvious to the operator
who the state, because of its inattention, places at a disadvantage.
Because the problem was predictable it was also preventable.
Go
to the last chapter, which has Recommendations
and the sources we used.
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