Gas Well Study

The U.S. Forest Service has just released a technical report titled Effects of development of a natural gas well and associated pipeline on the natural and scientific resources of the Fernow Experimental Forest. It can be downloaded from this page or you can download it directly.

The report deals with the expected and unexpected effects resulting from a natural gas well drilled in the Fernow Experimental Forest in Tucker County, West Virginia in 2008. The site is on karst, a problematic location for a well, and is located close to a cave where endangered Indiana Bats overwinter and in an area with other endangered species.

This well is a vertical well into formations below the Marcellus and shows some of the limitations of West Virginia’s regulatory program. We have serious issues with erosion and sediment control at sites. The state requires the use of a 1993 Erosion and Sediment Control Field Manual which is sorely in need of revision. We’ve found that operators after almost 20 years still don’t understand the requirements of the manual. The report documents sediment control overwhelmed on the site, including sediment going into a sinkhole (sinkholes and caverns are features in karst limestone formations).

While drilling out a fracture plug the operator lost control of the well and flowback sprayed onto the pad and into the surrounding woods, killing vegetation. The state has a history of spills, blowouts and other events not being reported to the regulatory agency and that appears to have happened this time also. PEER obtained some documents related to the well by FOIA request and a scientist stated that the area the spray hit had a burned appearance.

This state allows the land application of liquid drill waste and fracture flowback using a permit created in the 1980s (it’s currently being revised, at long last). In this case the liquid waste killed vegetation and trees and that is documented by Forest Service scientists. The state also allows solid waste to be buried on site. At this well, the waste is leaching to the surface through the action of several seeps where it was buried. As far as I know (the report doesn’t explicitly state this) the state has had no response to either the death of vegetation nor the leaching of waste.

We have a section on our website dealing with the Fernow land application debacle. We’ll be updating it and including material from this report. We’ve been able to reproduce, on a small scale, some of the effects seen on vegetation at Fernow using chloride solutions. We have not been able to reproduce the high soil concentration of chloride found by scientists after the application was done in 2008, nor have we been able to reproduce the effects on a broad spectrum of species. It’s entirely possible that other factors were involved in the death of even large trees, but the land application permit requires analysis of only a few constituents, such as iron, aluminum, chloride, etc. No heavy metals, and there is no load factor for chloride.

Articles are appearing in various venues on the web based on this Forest Service report. A good one is on the ProPublica site.

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.