Gas Well Study

At a drilling site pits are used to store water, contain drilling fluids and cuttings or to hold other liquid substances such as brine or oil. Sites we’ve examined have all had at least one pit, that for drilling fluids and cuttings. These pits may also have held used fracture fluids (flowback). The only sites that probably didn’t have a pit were those dating from the 1940s.

Unless an examination is made of a number of Discharge Monitoring Reports filed with the state we have no way of knowing what percentage of pits may possibly have held flowback (category 1 pits do not contain flowback). Because of that we have to assume all pits contain some flowback.

Regulation of pits and what they can hold is distributed over three platforms in West Virginia: code of state regulations (35 CSR 4.16.4), Erosion and Sedimentation Control Field Manual (II.B.2 and III.A) and General Water Pollution Control Permit (G2, G10 and G15). This is typical for this state where regulatory control is dispersed and lacks any form of quantification. For example, freeboard is required by the code of state regulations (35 CSR 4.16.4c), but no amount of required freeboard is given, such as 2 feet. Other absences include no limitation of placement in respect to ground or surface water. A driller, in essence, can put a pit anywhere, even where common sense would dictate differently.

We’ve created a webpage that has the three regulatory platforms’ texts together in one spot.

Problems with the state’s regulations occur in these areas: no limitation of pit location in respect to ground water; no limitation of placement of pit on site (fill area) or near surface water; no specifications for proper liner and installation/welding; no technique for proper encapsulation of solid waste and cover requirements; and finally, no placement of permanent marker and filing a deed notice to comply with Federal Housing Administration requirements for future builders and homeowners. Except for possibly the last item, the state’s policies do not protect the environment or the health and welfare of its citizens.

Ground Water
While the state’s regulations make offhand requirements to protect the state’s waters, there is no minimum distance between the bottom of the pit and ground water. The Argonne National Laboratory recommends a minimum of 5 feet between the bottom of the pit and seasonal high water level. British Columbia requires a minimum of 1 meter. New Mexico in its recently updated regulations requires the distance be at least 50 feet. We believe the state should adopt the Argonne National Laboratory’s recommendation at a minimum. The distance should be much more in sandy soils.

Pit Location
The pit needs to be placed in firm soil. Sandy soils are not appropriate without amendment of some sort according to the Railroad Commission of Texas. Fill soils are inappropriate and pits in fill soils need special written permission in British Columbia. Placing a pit on the edge of the pad by the fill slope is not recommended by the Erosion and Sedimentation Control Field Manual but we believe this is quite common. With pits increasing dramatically in size, the state needs to regulate or somehow control the use of fill soils.

The pit needs to have the site constructed so that rain or other water is directed away from the pit (with berm and/or ditch). The General Water Pollution Control Permit actually sanctions the directing of stormwater into the pit (G15). Overflow of the pit because of improper stormwater drainage causes contamination of soils, ground and surface water. The freeboard needs to be a stated amount (New Mexico and Arkansas require 2 feet freeboard).

The location of a pit near a body of surface water should be regulated. New Mexico requires a distance of 300 feet from a river (other setbacks are regulated in New Mexico, such as 500 feet from a domestic water source). In Texas, water wells within 1 mile of a pit need to be recorded in the permit, as does the depth of the shallowest freshwater for those wells. Arkansas has similar requirements in its permit for landspraying.

Pit Liners
Pit liners are optional for this state but I believe are commonly used. Liners should always be required. The state has no specifications for liners which are available in a variety of materials and thicknesses. The state also has no requirements for locations of seams (up and down slopes, not laterally, for instance) or installation (type and depth of anchor trench). We believe that New Mexico’s regulations could easily be adapted.

Burial and Cover
Before burial, the solids at the bottom of the pit are encapsulated (though West Virginia doesn’t require encapsulation; open liners and contents can be buried shallowly). Basically, encapsulation means the pit liner’s edges are folded over the solids preventing their escape. Cover over the burial cell is important since enough depth is required to prevent plant roots from disturbing the liner’s integrity. The Argonne National Laboratory recommends at least 3 feet of cover. We believe that more is required where the reclaimed surface will eventually revert to forest. Soil cover needs to be graded so that the surface doesn’t allow the ponding of water. We believe the Argonne National Laboratory’s recommendations should be incorporated in the state’s regulations.

Permanent Marker
There needs to be a way to record the exact location of each pit in the state. In New Mexico this is done through a deed notice associated with the surface owner’s property deed. New Mexico also requires a permanent marker much like that required in this state for plugged wells — a steel monument 3 feet above the ground’s surface. British Columbia requires a separate pit permit and registration for each pit and the pit number(s) posted at the drill site (Arkansas has similar requirements). New Mexico’s regulations were written so as to not disadvantage surface owners at the present or in the future because of Federal Housing Administration requirements. This state needs to do the same.

In a future post we’ll present our recommendations for pits adapted from our comments for Raymond City #17.

Sources:

Argonne National Laboratory. Fact Sheet – Onsite Burial (Pits, Landfills). Drilling Waste Management, web page accessed 20 September 2008.

Arkansas. 2008. Authorization to Construct, Operate and Close the Pits Associated with Oil and Gas Well Exploration. Arkansas Department of Environmental Quality, Permit No. 00000-WG-P.

British Columbia Oil and Gas Commission. n.d. British Columbia Oil and Gas Handbook, Chapter 10, Drilling Waste Management. n.p.: British Columbia Oil and Gas Commission.

Department of Housing and Urban Development. 1999. Changes to Handbook 4150.2, Valuation Analysis for Single Family One- to Four-Unit Dwellings. n.p.: Department of Housing and Urban Development. Chapter 2: Site Analysis, 2.2.E.

New Mexico. 2008. New Mexico Code and State Rules for Oil and Gas. New Mexico Energy, Minerals and Natural Resources Department, Oil Conservation Division.

New Mexico. Highlights of the “Pit Rule” — 19.15.17 NMAC. Santa Fe, NM: New Mexico Energy, Minerals and Natural Resources Department, Oil Conservation Division.

Railroad Commission of Texas. Surface Waste Management Manual, Chapter 4, Pits. Railroad Commission of Texas website, accessed 8 December 2008.

In the October 2008 newsletter of the Independent Oil and Gas Association of West Virginia (IOGAWV) there was an article by Greg Kozera (starting on page 9) about the economic benefits of oil and gas. Greg was using the example of a well crew:

“The drilling supervisor was probably in his 50s, two of his crew were in their 20s and the third was 19, according the supervisor. I understood from the supervisor that they got paid fairly well and had good benefits. . . . Where else could three men with high school diploma be so successful so quickly?”

What Greg didn’t write about was the high fatality rate for oil and gas workers — higher than the mining industry’s. In another post I’ll write a little about the Australian Health Watch Study of workers’ health and issues related to exposures to petroleum products. The Australian study is underwritten by the industry there; I know of no similar long term study in this country. That is telling, isn’t it?

Instead, what I’ll present is the tip of the iceberg about worker injury and fatality, for which a good deal is known. The U.S. Department of Labor’s Bureau of Labor Statistics asked the CDC (Centers for Disease Control and Prevention) to investigate the dramatic rise in fatalities a few years ago and the CDC report can be read here. Essentially what was found was a direct link between the number of workers killed and the number of rigs used in drilling and workovers each year. The boom in drilling that began shortly after 2000 and reached a fever pitch a few years later had side effects that industry doesn’t want to talk about. Besides the environmental degradation, workers were being killed.

The National Institute for Occupational Safety and Health (NIOSH) produced a safety manual for oil and gas workers back in the 1980s and to the best of my knowledge it’s never been updated. The IOGAWV has their own, downloadable, safety manual which looks good but I wonder how many workers see something like this, much less are encouraged to study it.

One of the issues for us is to remember that individuals involved in the oil and gas industry are people, that they have pride in what they are doing. We have to be continually aware of that pride, even though we often have issues in how they are doing their jobs or in the outcomes of their efforts.

There’s a good story at the High Country News website, Disposable Workers of the Oil and Gas Fields by Ray Ring, that we recommend. Closer to home is this story from a 1984 accident in West Virginia that is taken from NIOSH’s Fatal Accident Circumstances and Epidemiology (FACE) Project. This is quoted from FACE 8502:

On the day of the accident, at approximately 7:30 a.m., a five-man crew assembled in the office of the field supervisor to receive their instructions for the day. The crew consisted of two service rig hands (hereafter designated “rig hands”) and their supervisor, the service rig operator (hereafter designated “operator”). In addition, the rig supervisor (hereafter designated “supervisor”) and the service rig tool pusher (hereafter designated “tool pusher”) were assigned to the crew so that the supervisor could instruct the tool pusher in the assembly and usage of the packing and down hole tools necessary to complete the job. The crew was informed that they were to “blow the well down” (relieve the internal pressure). If they could get the pressure down to acceptable levels, they were to start putting the tubing down. All members of the crew were familiar with the procedures necessary to blow down the well and insert the tubing. The crew began to work by about 8:30 a.m.

When the well Is “blown down,” gas, water, acid, and occasionally oil are released. These substances are directed into the fracturing tanks through two-inch steel “flow back” lines. Because of the pressure exerted on these lines, they are secured to the tanks with safety chains. When sufficient steel lines are not available to plumb in all of the tanks, a high pressure, double walled, two-inch rubber hose, called a Kelly hose, is used as a flow back line. When the Kelly hose is used, it must be tied down, both to the inside and outside of the tank, to prevent it from whipping around when the well is flowing during blow down.

By approximately 9:30 a.m., the well had blown down sufficiently to begin inserting the tubing, so the operator and one of the rig hands began to disconnect the well from the fracturing tanks. The remaining members of the crew (the supervisor, tool pusher, and one rig hand) were near the service rig, assembling the down hole equipment when they heard the operator yell that the rig hand was in the tank. The operator then entered the tank himself. Despite warnings by the rig supervisor to stay out of the tank, the other rig hand entered the tank, followed by the tool pusher. When the supervisor got to the top of the tank and looked in, he could only see two of the men and they were unresponsive and “dazed looking.” He immediately got off of the tank and opened the valves to release the water in the tank. He then called for help on the truck radio.

When the call was received at the office, the rescue squad was notified, and arrangements were made to have the supervisor of a second crew meet the ambulance and give them directions. In the meantime, the rig hands from the second crew proceeded to the site to provide additional assistance, and other supervisors and employees proceeded to the site as well.

When the two rig hands from the second crew arrived, they helped the supervisor remove two clean-out panels at the bottom of the tank. By this time, most of the liquids had been drained from the bottom of the tank. When the panels were removed, the bodies of the operator and tool pusher were found lying on the bottom, of the tank. One of the rig hands was found standing in the tank, but was unresponsive; the other rig hand, also unresponsive, was found attempting to climb up the internal support bars of the tank, but appeared ready to fall. The two rig hands who had entered the tank and survived the incident reported that within 10 – 15 seconds of entering, they were overcome by the gas. They could not remember anything past that point.

The autopsy reports indicated that the rig operator and the tool pusher died by drowning due to asphyxiation.