Study Causes DEP to Train Inspectors

Gas well technology is changing rapidly

Morgantown Dominion Post
21 July 2013
By David Beard
One of the three legislatively mandated Department of Environmental Protection (DEP) gas well reports generated little fanfare when it was released.  

It was a WVU study of centralized large pits and impoundments at gas well pads. The study, released in March, found a number of compliance and construction problems at existing pits built before the 2011 Natural Gas Horizontal Well Control Act, which led to corrective actions at the sites and in DEP Office of Oil and Gas (OOG) procedures, such as training well inspectors.  

Overall, the report said, “OOG 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 OOG concurs with WVU that ‘future construction, if done in accordance with the WVDEP guidelines, should pose minimal risk.’ ”  

Based on the water and impoundment studies, WVU offered a number of recommendations. DEP told The Dominion Post, “Most of WVU’s recommendations were already being done by OOG via statute and guidelines. Since then, new Rule 35 CSR 8 also picks up many of the items in their recommendations.  

As a result of the study, DEP took a number of corrective actions. It revisited the study sites to observe and address specific problems.  

OOG initiated in-house training for field and office workers, and developed a standardized inspection checklist. Training will be provided to keep up with changing technology and expanding activity.

The report  

The WVU West Virginia Water Research Institute conducted the study for the DEP. It looked at water and waste stream handling, and at pits and impoundments.  

The study didn’t address the “potential for human exposure via fluid movement from the fracturing zone upwards toward drinking water supplies.”  

The water and waste portion of the study observed that flowback water (water that retur ns through the wellhead to the surface after fracking) exceeded drinking water standards for barium, chloride, iron manganese, total dissolved solids (TDS) and radium 226.  

Much of the flowback also exceeded standards for other toxins. Six parameters were exceeded in the fracking fluid itself, but the results suggest that many of the toxins are brought back up from the Marcellus formation.  

For the pits and impoundments portion, WVU studied 15 sites. Researchers found several recurring problems: Insufficient soil compaction, surface soil erosion, slope movement, buried woody debris (weakening the pit wall), seepage and wet zones, liner deficiencies and unsupported pipes (potential breakage and spills).  

WVU also submitted questionnaires to OOG inspectors and to company site representatives. It found that inspectors had no formal training in pits and impoundments, and no standardized inspection method. Inspection frequency varied widely.  

In an attachment to the report, OOG’s Dave Belcher, assistant chief for enforcement, observed that pits and impoundments didn’t start proliferating until 2007. “Presently, 160 large impoundments and pits are on file and registered; few are closed and reclaimed, yet new applications are routinely submitted.”  

New inspectors are getting hired, he said, which will help spur more regular site visits. “The OOG recognizes a continuous need for in-house training programs provided for its field staff. Workshops for industry must continue.”