WVU: Marcellus Drill-Site Pits Have Problems
Existing regulations 'sufficient,' DEP says
Charleston Gazette
15 March 2013
By Ken Ward Jr.
CHARLESTON, W.Va. -- A legislatively mandated study by West
Virginia University has found consistent and potentially
significant problems with the way oil and gas companies build
drilling waste pits and with how state regulators inspect those
impoundments.
WVU engineers reported that field evaluations found insufficient
compaction, soil erosion and seepage at sites where gas-drilling
companies store wastewater from hydraulic fracturing and gas
production activities.
Impoundments inspected as part of the study were found to be built
larger than permitted, with different crest-berm widths and
steeper upstream and downstream slopes than authorized.
While none of the problems "indicated imminent pit or impoundment
failure potential," the WVU report warned, "the problems
identified do constitute a real hazard and present risk if allowed
to progress.
"Overall, these deficiencies reflect a lack of adherence to the
best management practices . . . as well as poor construction
knowledge," the 208-page report said. "These construction
practices combined with a lack of field quality control and
assurances are indicators of the source and frequency of the
problems observed across all evaluated sites."
West Virginia Department of Environmental Protection officials,
though, said the sites designed and constructed to current state
standards scored higher on WVU's inspections than those built
before new Marcellus Shale drilling regulations were enacted.
In a summary of the WVU report, the DEP said it "is able to
conclude that the current regulatory framework is sufficient to
properly regulate the construction, operation, and maintenance of
large capacity pits and impoundments."
The report, required as part of West Virginia's new Marcellus
drilling law, also found that none of the DEP inspectors had any
formal training related to pit and impoundment inspection.
"Consequently, the inspectors only targeted the readily apparent
problems such as slips and slides, while not recognizing, or fully
understanding, the smaller problem indicators," the report said.
The report also said the DEP had no set frequency for site
inspections, and that the actual frequency of inspections --
either by the DEP or the company involved -- varied from once
every three days to once every two months. Inspection frequency by
a professional engineer ranged from weekly to never, the report
said.
"Infrequent inspections may allow problem areas to go unnoticed or
delay corrective action," the report said.
In summarizing the WVU report for lawmakers, DEP officials said
the agency has since provided additional training to inspectors on
the proper design, construction and maintenance of pits and
impoundments.
"Continuous improvement through training has been, and will
continue to be, ongoing at numerous events in order to stay
apprised of the new and constantly changing industrial activities
associated with horizontal well drilling," the DEP said. "In
addition, the OOG developed a standard inspection checklist to
ensure that the inspection of pits and impoundments is
standardized across the Office of Oil and Gas."
During a budget hearing Friday, DEP Office of Oil and Gas Chief
James Martin told lawmakers his agency also has made progress
using additional permit fees on the industry to hire additional
inspectors.
The office now has 49 staff positions, up from 32. Agency
officials have filled 41 of the 49 positions, and the eight
vacancies are evenly split between enforcement and permitting
functions, Martin said.
"We've been, I think, fairly successful," Martin said. "We've
managed to hire folks, and we've gotten good people."
Under the law, passed during a special session in December 2011
and signed by Gov. Earl Ray Tomblin, the DEP was required to
complete a study of oil and gas wastewater impoundments by Jan. 1.
The pits and impoundments report from WVU's Department of Civil
and Environmental Engineering was submitted to the DEP in
mid-December.
In January, DEP Secretary Randy Huffman said work on the
impoundment study was complete, but that its submission to the
Legislature was delayed because of formatting problems. Huffman
also said WVU researchers included some recommendations about the
handling of gas-drilling wastewater that went beyond what they
were actually asked by the DEP to do.
Two other documents from WVU were provided to the DEP in February,
and the DEP released the material publicly last week.
A separate study on noise, light and dust from drilling operations
was to be provided to the Legislature by Dec. 31, 2012, but is
still not finished. A third study, examining possible air
pollution from oil and gas operations, is due July 1.
In their push for more natural gas, drilling operators in West
Virginia's Marcellus Shale region are increasingly using a process
called hydraulic fracturing, which shoots vast amounts of water,
sand and chemicals deep underground to break apart rock and
release the gas. Operators also are using a process that involves
drilling down and then turning horizontally to reach broader
stretches of gas reserves.
Water from these processes, along with any "flowback" that returns
to the surface, is frequently stored in large, centralized pits
and impoundments at or near well locations. Oil and gas operators
frequently re-use this water several times, but eventually the
wastewater has to be disposed of. In West Virginia, that is
typically done by injection into other underground wells.
In a four-page summary of the impoundments review, the DEP
reported that, "based on sample results of both the material held
in the structures and the groundwater below them, the study showed
that no leakage was detected from the examined structures."
The WVU report itself said, "There was no evidence of significant
leakage of flowbacks from the impoundments.
"While the monitoring wells detected no contaminants, it is not
clear that the monitoring interval of 146 days was sufficient to
capture any leakage from the impoundments," the WVU report said.
"A longer sampling period is suggested with, perhaps, aquifer
permeability testing."
Reach Ken Ward Jr. at kw...@wvgazette.com or 304-348-1702.