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Recommendations
We
believe that vegetation death during the landspraying at Berry
Energy's B800 well in the Fernow Experimental Forest was due
to an extremely high chlorides load and possibly also to an
extremely high pH of the liquids. We also believe high sodium
load will affect the landsprayed areas in the future.
The
state's landspraying program allows operators to deposit high
chloride drill waste without consideration of load. The state's
permitting the landspraying of fracturing chemicals and flowback
encourages the extremely high concentrations of chlorides
found in West Virginia landsprayed waste.
We've
seen analysis of a number of pits of drill waste liquids in
another state where the chlorides concentration ranged between
30 mg/l to 280 mg/l. These were high volume pits containing
between a quarter and a half million gallons. By contrast,
the Berry Energy well's pit held 100,000 gallons with a concentration
of 6,210 mg/l chlorides (by Berry declaration, other testing
showed more than twice that concentration).
West
Virginia's program should incorporate load per acre for salinity
(chlorides or some other measure) and should drastically limit
the upper level of chlorides to 3,000 mg/l maximum concentration.
There's
every reason to believe that the SAR for the landsprayed waste
at Fernow was at an unreasonably high level. We recommend
that a sodium load mechanism is required in the state's permit
to prevent destruction of soil and long term negative impacts
on vegetation.
The
state's waste management program depends on operators' on-site
testing of pit fluids. The wide variance between Berry's and
Forest Service's results from testing of pit liquids shows
several problems with the state's program. We recommend testing
should be done by a state sanctioned laboratory. We also believe
that guidelines for how samples are to be collected are necessary.
In
addition to the testing of pit waste liquids, we also recommend
that laboratory testing of the soil before and after land
application is necessary as a final examination of the operator's
performance.
The
state's program needed to have means to predict and prevent
what happened at the Fernow Experimental Forest. At present
the state doesn't have an effective waste management program.
Sources
This
is a partial listing of some of the sources cited.
EPA.
1994. R.E.D.
Facts, 2,2-dibromo-3-nitrilio-propionamide (DBNPA).
U.S. Environmental Protection Agency, Prevention, Pesticides
and Toxic Substances, EPA-738-F-94-023.
EPA. 2000. Associated
Waste Report: Completion and Workover Wastes. Washington,
DC: U.S. Environmental Protection Agency, Office of Solid
Waste. (This is an important resource and Appendix C provides
a detailed chemical analysis of waste constituents for several
wells.)
EPA.
2004. Evaluation of Impacts to Underground Sources of Drinking
water by Hydraulic Fracturing of Coalbed Methane Resources.
U.S. Environmental Protection Agency, Office of Water, Office
of Ground Water and Drinking Water (4606M), EPA 816-R-04-003.
(Information about gel-type fracturing and chemicals in Chapter
4, but flawed study.) Chapters
or the whole document can be downloaded. Chapter
4 Hydraulic Fracturing Fluids is available.
Howat,
D. R. 2000. Acceptable
Salinity, Sodicity and pH Values for Boreal Forest Reclamation.
Edmonton, Alberta: Alberta Environment, Environmental Sciences
Division, Report # ESD/LM/00-2.
Keister,
Timothy. Marcellus
Gas Well Water Supply and Wastewater Disposal, Treatment,
and Recycle Technology. Apache Junction, AZ: ProChemTech
International, Inc. (Discusses constituents of fracturing
flowback, fracturing additives and treatment.)
Kozlowski,
T. T. 1997. Responses
of Woody Plants to Flooding and Salinity. Tree Physiology
Monograph No. 1. Victoria, Canada: Heron Publishing.
Monk,
George and Schaffnit, Molly. n.d. Drill
Mud Additives. Drilling Waste Management section of
Sootypaws website.
Monk
George and Schaffnit, Molly. n.d. Comments
for the Draft Industry Guidance, Gas Well Drilling/Completion
Large Water Volume Fracture Treatments. (Includes
West Virginia Department of Environmental Protection's Draft
Industry Guidance Gas Well Drilling/Completion Large Water
Volume Fracture Treatments, 13 March 2009.)
Saskatchewan
Energy and Mines. 1999. Saskatchewan
Drilling Waste Management Guidelines. n.p.: Saskatchewan
Energy and Mines, Petroleum Development Branch, GL99-01.
State
Review of Oil and Natural Gas Environmental Regulations, Inc.
2003. West
Virginia Follow-Up and Supplemental Review. n.p.:
State Review of Oil and Natural Gas Environmental Regulations,
Inc.
Sumi,
Lisa. 2005. Our
Drinking Water at Risk: What the EPA and the Oil and Gas Industry
Don't Want Us to Know about Hydraulic Fracturing.
Durango, CO: Oil & Gas Accountability Project. (Excellent
rebuttal to EPA 2004. Table 2 on page 7 provides an estimate
of chemical concentrations of substances appearing on Table
4-1 of EPA 2004.)
West
Virginia Department of Environmental Protection. 2008. Memorandum,
Large Volume Pit/Pond Operators. West Virginia Department
of Environmental Protection.
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