|
Posted
17 August 2010
Fracture
Waste
In
West Virginia, under the current General
Permit, wastes from fracturing a well can be land applied.
This waste comes in two forms -- unused fracturing chemicals
dumped into the pit and fracture flowback discharged from
the well into the pit.
According
to the General Permit unused fracture chemicals cannot be
dumped into a pit but it's hard to tell if the operators'
crews know this. The state's Discharge Monitoring Report (DMR)
shows the decision tree for determining under which pit category
pit waste falls and indicates that chemicals and flowback
can be in a pit:
Only
category 1 pits do not have fracture flowback or chemicals.
Of the small number of DMRs we've examined, all have been
for category 2 or 4 pits.
The
EPA's
exemption of oil and gas wastes does allow the land application
of drill waste, flowback, and even chemicals, but the exemption
does not allow the addition of unused chemicals to production
waste that is covered by the exemption (drill waste and flowback)
if the chemicals exhibit certain hazardous characteristics
and if the pit waste then assumes those characteristics. These
hazardous characteristics are reactivity, corrosivity, ignitability
and toxicity. Or, if the chemicals are listed in 40CFR261,
subpart D, then the waste is no longer exempt.
Almost
nothing is known about the chemicals used for fracturing in
West Virginia. The Office of Oil and Gas website publishes
an incomplete list
of chemicals. The list is incomplete in that it does not
show all the chemicals used in a typical fracture job (the
biocide is missing, for instance), nor does it show the proprietary
chemicals which manufacturers won't disclose. For the Material
Safety Data Sheets (MSDSs) I've seen, these proprietary, unnamed
chemicals, can form 10% to 60% of a product.
Proprietary
chemicals may be innocuous or they may be toxic. They may
be those listed in 40CFR261, which makes disposal costly because
the waste is no longer exempt.
These
unknown proprietary chemicals must be assumed to fall in a
worst case scenario -- are hazardous in one way (by their
characteristic) or another (are listed).
The
Office of Oil and Gas has allowed this waste to be land applied
without knowing what makes up this waste -- the products or
chemicals used. But even if the Office had full disclosure
from the operators, it would not be getting full disclosure
from the manufacturers.
It's
our belief that fracture flowback should not be land applied
and that fracture chemicals should not be dumped into drill
waste pits. Unused fracture chemicals should be disposed of
otherwise and properly.
The
MSDS evidence is, as I mentioned above, sparse. Three products
known to have been used in West Virginia create particular
concern. These Halliburton products (though Halliburton is
not the only company making fracturing and drilling products)
are: BC-140
(a cross linker); BE-3S
Bactericide; and SP
Breaker (a post-fracture gel breaker). Clicking on the
product names will produce the applicable MSDS Adobe Acrobat
document. We
have a page on our website that explains the purpose of some
of these chemicals.
These
products weren't used in exceptionally large quantities. Their
hazards are noted on the MSDS sheets (sections 2, 3, 5, 7,
10, 11, 12 and 15) and include ecological, human health, storage
and regulatory issues. Only the SP Breaker exhibits a hazardous
characteristic (two in the MSDS version when the product was
used -- ignitability and reactivity). Waste should, if exposed
to this product, according to the EPA exemption, be tested
to determine if it is still exempt.
A
quick addendum: The
Office of Oil and Gas has just decided that fracture flowback
from Marcellus wells cannot be land applied.
Comments
Posted
14 July 2010
Junior
Book Goats
Blondie
and Grey are fully weaned and are eating up a storm, probably
twice as much each day as the big guys Bobo and Kitty Boy.
Their area of exploration is slowly encompassing the whole
house and they are interacting well with the big guys. Kitty
Boy is utterly entranced with the idea of new playmates and
he can't wait for them to get bigger (we have to watch him
so that things don't get too rough). He's taken to bringing
toys up from the addition to show the kittens and to let them
play with and he's been giving demonstrations on how to play
best with a ball.
Blondie
and Grey love our book piles and exploring the book shelves
(they can only reach the lowest shelves for now). They are
junior book goats!
More
soon!
Comments
Posted
29 June 2010
New
Content on Website
I've
just added two new pages to the website devoted to Grey and
Blondie, two kittens abandoned by a feral mother, and being
hand-raised by us. We have lots ore photos and when there's
time we'll be adding more pages. The
first page devoted to the kittens is in the Cats section of
the website.
The
kittens started eating solid food today! More soon.
Comments
Posted
24 June 2010
Mycotrophic
Plants
We
have at least two varieties of plants that don't depend on
chlorophyll in our woods. These are called mycotrophic plants
(because they are symbiotic with a type of fungus) and the
Forest
Service has a section on their wildflower website about them.
The plants we have are Indian Pipe (monotropa uniflora)
and Cancer Root (conopholis americana). Cancer Root
is almost finished flowering and Indian Pipe is just beginning.
 |
|
This
is a large cluster of Indian Pipe that has just emerged
so there are specks of soil on the normally all-white
plants. Another name for this is Corpse Plant. |
| |
|
|
 |
|
Cancer
Root pops up in late spring, generally in clusters, standing
about 6 inches tall. The yellowish "berries"
make this plant easy to identify. |
| |
|
|
 |
|
The
plant is short-lived and begins to turn brown and wither.
We've seen plants torn up that have been munched by something
so at least one critter finds them edible. |
More
soon!
Comments
Posted
24 June 2010
RUSLE2
West
Virginia's Office of Oil and Gas is in the process of revising
and updating its 1992 Erosion
and Sediment Control Field Manual which covers Best
Management Practices (BMPs) for access road and well site
construction. The revision is much needed and we hope industry
follows it better than it did the old manual.
The
BMPs are necessary for important reasons. The EPA gave the
oil and gas industry an exemption from Clean Water Act rules
covering stormwater discharges. Why the industry needs this
exemption when every other construction industry (except mining)
is covered by these regulations is beyond us. The EPA was
forced to abandon part of this exemption in a strongly worded
Ninth
Circuit Court's decision against the EPA. The EPA has
a page
devoted to the NPDES requirements of oil and gas.
These
regulations are important because the issue isn't just sediment
poisoning streams and lakes, but also because of contaminated
runoff from well sites. What types of contamination? Heavy
metals, organics and other chemicals used in drilling and
fracturing or produced by the equipment on the site. This
is why bulk chemical storage on well sites during drilling
and fracturing is a huge issue. There should be no possibility
of chemicals contacting the ground or water during storage
or by accidental spills.
Two
publications that give an idea of these impacts are related
to natural gas drilling within the city limits of Denton,
Texas. Kenneth Banks and David Watchal carried out a study
sponsored by the EPA which examined the effects of drilling:
Demonstrating the Impacts of Oil and Gas Exploration on
Water Quality and How to Minimize These Impacts Through Targeted
Monitoring Activities and Local Ordinances. David
Watchal's doctoral dissertation, Characterizing
Storm Water Runoff from Natural Gas Well Sites in Denton County,
Texas, is made up of 4 papers on the issue. The first
paper discusses chemicals found in stormwater runoff from
gas well pads.
Industry,
in an attempt to forestall regulation, has recently created
a handbook, Reasonable and Prudent Practices for Stabilization
(RAPPS) of Oil and Gas Construction Sites or RAPPS (download
link is on this American Petroleum Institute web page).
I had been familiar with the 2004 version but was unaware
until recently of the expanded and updated version released
by the API and other industry associations in 2009.
The
newest RAPPS depends heavily on the research by Watchal and
Banks and especially on Watchal's work with RUSLE2 modeling
program. The RAPPS manual creators used RUSLE2 (in a special
construction version not available yet publicly which has
sediment control devices not available in the standard RUSLE2
program) to create specific BMPs for management and control
of sediment at oil and gas sites.
RUSLE2
was created by the USDA Natural Resource Conservation Service
(NRCS), the USDA's Agricultural Research Service, and the
University of Tennessee. The version I've been using I downloaded
(it's free to the public) from the USDA
ARS website. Database specifics for West Virginia soils
and climate were downloaded from the NRCS
website for RUSLE2.
The
program allows me to model soil loss based on a suite of activities.
Because of a the size of a well site and the soils here, the
losses are measured in many tons per acre per year. Techniques
to control and manage the soil loss are able to be modeled,
such as silt fences or straw mulch, to gauge the best method
to control sedimentation.
Wachal's
dissertation demonstrates how modeling can be used and, with
few changes, this is what the creators of the new RAPPS manual
did. Watchal's work was based on the construction of gas well
pads in Denton where construction on sites with more than
a 10%
grade is not allowed by city regulation. Sites with low
grades are also within the optimal range for RUSLE2. Sites
with a more extreme grade create situations which RUSLE2 isn't
able to model or the techniques/controls aren't available
(at least on the public version I've been using). The RAPPS
manual is best suited for these low grade slope situations.
RUSLE2
isn't hard to learn, but the program isn't intuitive, and
user manuals are opaque. Training is usually hands-on in several-day
seminars which I'm not able to take advantage of. It takes
time to learn the soil science terminology and I'm thankful
that RUSLE2 does all the math.
The
three major inputs are location by county, soil type, and
slope length and grade. The NRCS has specific county climate
data and soils for download at the NRCS RUSLE2 site. The NRCS
also has downloadable county soil maps and handbooks.
Starting
out, I used a generic Kanawha County (Charleston area) climate
location in an OSM folder in the original RUSLE2 program download
(RUSLE2 is also used by the Office of Surface Mining), and
inputted a generic clay loam soil with a K of 0.35 (one of
the default figures used by the creators of the new RAPPS).
Actually, where we live on the ridge the soil type is Gilpin/Upshur
with a Gilpin horizon (brown clay with a K of 0.32) and Upshur
horizon (red clay with a K of 0.43). The higher the K value,
the more erosive the soil is. As I've been learning the program
I've been using more specific climate and soil data.
Here
is a road segment profile screen shot from the program. The
segment has two grade components (350 feet at 20% grade, and
50 feet at 9% grade) in our area with Upshur soil (K=0.43).
The total sediment for this length is 310 tons per acre per
year from a bare bulldozed surface.
We
believe roads should have a cleared width of between 25 to
30 feet. For this length that makes 0.27 acre in size, or
84 tons of soil lost from graded surface. Well operators like
to "daylight" roads to 50 or 60 feet width, believing
that cutting back all the trees helps keep the road dry (meaning
operators can be sloppy in drainage control). Daylighting
is effective only minimally and not at all when the soil is
cool. A 60 foot cleared road width would mean 164 tons per
year lost for this road section. By being more reasonable
in site clearing practices operators could cut the soil loss
in half. The goal is under 5 tons per acre per year soil loss
and could generally be achieved by use of mulch, gravel road
surface, immediate reseeding, and sediment management devices
like silt fences.
Here
is a worksheet screen shot detail for the same segment. Worksheets
allow multiple management plans to be examined side by side.
For this worksheet the first row is for a bulldozed surface.
The average upslope erosion figure in the right-hand column
is sediment loss and is 310 tons per acre per year. The second
row is a graded surface covered with straw mulch at two tons
per acre and with three silt fences. The sediment loss is
a tenth of what it would be without any controls. The third
row is a graded surface with mulch, temporary and then permanent
seeding with 3 silt fences. The vegetated surface has a profound
effect in limiting soil loss.
This
same segment could also be a hillside where a well pad would
be cut in. If the width of the disturbed surface were 300
feet for the cut, then the disturbed area is 2.75 acres. Roads
because of their length and width and well pads because of
the large area of surface disturbance on hillsides can create
a huge soil loss. Sites we've seen have not had mulch or seeding
until after the well is completed, sometimes more than a year
later. The reports we've heard of huge amounts of sediment
entering ponds, streams and rivers are not at all exaggerated.
More
about RUSLE2 later. I've just received a copy of a special
construction version not available to the public as yet.
Comments
Posted
15 June 2010
Gasland
Terry
Gross on NPR's Fresh Air had extensive interviews with Josh
Fox, the film maker of Gasland, a documentary to be
shown on HBO (June 21st), and with Abrahm Lustgarten, a
reporter for ProPublica, on June 10th. We highly recommend
both interviews and both can be heard on the NPR website.
Josh
Fox described the making of Gasland and what he saw
as he investigated the impacts of natural gas drilling in
Pennsylvania and elsewhere. This
page on the NPR website has a link to hear the interview
plus there are clips from the documentary and background information.
The
interview with Abrahm Lustgarten was equally revealing. His
articles for ProPublica have focused on fracturing and problems
with industry disclosure about the chemicals being used and
their effects on drinking water. In this Fresh Air interview,
Lustgarten talks about the oil and gas industry's exemption
from the requirements of the Safe Drinking Water Act, partially
based on industry's promise not to use diesel fuel for fracturing
any more. Of course, diesel has been used for fracturing since
the 2005 exemption, along with a host of other toxic chemicals.
This
page on the NPR website has a link to hear the interview
plus there's background information.
Comments
Posted
15 June 2010
Kitten
Movie
Grey
and Blondie are well past their third week birthday and the
changes since we saw them first on May 21st are amazing. Their
eyes are open and ears are erect. They are walking (though
a bit unsteadily still) and they've begun bathing themselves
after a session with the bottle. We've begun the process of
weaning them but Grey and Blondie are so excited they tend
to skate across the saucer of food more than eat it.
We've
seen the third kitten; the momma cat had moved it to under
a workbench shelf in the shop. We checked again today and
the kitten is no longer there and we think it's been moved
to the woods.
When
I get a chance I'll create a page on our website with kitten
photos in the Cats
section. Until then, here's
a short movie of Grey made on May 30th (2.2 MB).
Comments
|
