What Happened at Fernow
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. The presence of hydraulic fracturing fluid and breakdown elements possibly enhanced the negative effects of chloride and pH. We also believe high sodium load will affect the landsprayed areas in the future.
The state's landspraying program allowed 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.
Those were our recommendations before the revised General Water Pollution Control Permit came into effect in 2016. The new permit does have a maximum chloride load. That load is 3500 lbs/acre. We believe that load is too high for waste land applied in a forest environment.
At present the state doesn't have an effective waste management program.
It's worth taking a look, also, at studies and a paper by Fernow Experimental Forest scientists.
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.
What Happened at Fernow
Landspraying
Fernow Experimental Forest
Discharge Monitoring Report
Chloride Load
SAR
Liming the Pit
A Short History of Fracturing
Fracturing Chemicals
What Happened at Fernow
Recommendations & Sources
Gas Well Study is the examination of natural gas wells in West Virginia.
Underground Injection Control Class 2 Wells
These wells are used either for the disposal of oil and gas liquid waste or for the enhanced recovery of oil or natural gas.
Gas Well Study Site Visits
Annual reports, environmental assessments, and individual well information.
YouTube Videos
Select videos from the Gas Well Study YouTube channel.
What Happened at Fernow
An investigation into what caused the vegetation death in the land application area after landspraying hydraulic fracture flowback waste.
The Spill at Buckeye Creek
An investigation into a spill from a Marcellus well site into Buckeye Creek in Doddridge county.
The Details
Plunger Lift Technology on Gas Wells
Fluids Brought to the Surface during Production
Plugging a Well
How To Read a Lab Report
Information the Completion Report Provides
Casing and Cementing