{"id":382,"date":"2009-04-28T10:52:57","date_gmt":"2009-04-28T14:52:57","guid":{"rendered":"http:\/\/sootypaws.net\/blog\/?p=382"},"modified":"2022-04-15T10:54:16","modified_gmt":"2022-04-15T14:54:16","slug":"pits","status":"publish","type":"post","link":"http:\/\/sootypaws.net\/blog\/2009\/04\/pits\/","title":{"rendered":"Pits"},"content":{"rendered":"\n

At a drilling site pits are used to store water, contain\ndrilling fluids and cuttings or to hold other liquid substances such as brine\nor oil. Sites we’ve examined have all had at least one pit, that for drilling\nfluids and cuttings. These pits may also have held used fracture fluids\n(flowback). The only sites that probably didn’t have a pit were those dating\nfrom the 1940s.
\n
\nUnless an examination is made of a number of Discharge Monitoring Reports filed\nwith the state we have no way of knowing what percentage of pits may possibly\nhave held flowback (category 1 pits do not contain flowback). Because of that\nwe have to assume all pits contain some flowback.
\n
\nRegulation of pits and what they can hold is distributed over three platforms\nin West Virginia: code of state regulations<\/a> (35 CSR 4.16.4), Erosion and Sedimentation\nControl Field Manual<\/a> (II.B.2 and III.A) and General Water Pollution\nControl Permit<\/a> (G2, G10 and G15). This is typical\nfor this state where regulatory control is dispersed and lacks any form of\nquantification. For example, freeboard is required by the code of state\nregulations (35 CSR 4.16.4c), but no amount of required freeboard is given,\nsuch as 2 feet. Other absences include no limitation of placement in respect to\nground or surface water. A driller, in essence, can put a pit anywhere, even\nwhere common sense would dictate differently.
\n
\nWe’ve created a webpage that has the three\nregulatory platforms’ texts together in one spot<\/a>.
\n
\nProblems with the state’s regulations occur in these areas: no limitation of\npit location in respect to ground water; no limitation of placement of pit on\nsite (fill area) or near surface water; no specifications for proper liner and\ninstallation\/welding; no technique for proper encapsulation of solid waste and\ncover requirements; and finally, no placement of permanent marker and filing a\ndeed notice to comply with Federal Housing Administration requirements for\nfuture builders and homeowners. Except for possibly the last item, the state’s\npolicies do not protect the environment or the health and welfare of its\ncitizens.
\n
\nGround Water<\/strong>
\nWhile the state’s regulations make offhand requirements to protect the state’s\nwaters, there is no minimum distance between the bottom of the pit and ground\nwater. The Argonne National Laboratory recommends a minimum of 5 feet between\nthe bottom of the pit and seasonal high water level. British Columbia requires\na minimum of 1 meter. New Mexico in its recently updated regulations requires\nthe distance be at least 50 feet. We believe the state should adopt the Argonne\nNational Laboratory’s recommendation at a minimum. The distance should be much\nmore in sandy soils.
\n
\nPit Location<\/strong>
\nThe pit needs to be placed in firm soil. Sandy soils are not appropriate\nwithout amendment of some sort according to the Railroad Commission of Texas.\nFill soils are inappropriate and pits in fill soils need special written permission\nin British Columbia. Placing a pit on the edge of the pad by the fill slope is\nnot recommended by the Erosion and Sedimentation Control Field Manual but we\nbelieve this is quite common. With pits increasing dramatically in size, the\nstate needs to regulate or somehow control the use of fill soils.
\n
\nThe pit needs to have the site constructed so that rain or other water is\ndirected away from the pit (with berm and\/or ditch). The General Water\nPollution Control Permit actually sanctions the directing of stormwater into\nthe pit (G15). Overflow of the pit because of improper stormwater drainage\ncauses contamination of soils, ground and surface water. The freeboard needs to\nbe a stated amount (New Mexico and Arkansas require 2 feet freeboard).
\n
\nThe location of a pit near a body of surface water should be regulated. New\nMexico requires a distance of 300 feet from a river (other setbacks are\nregulated in New Mexico, such as 500 feet from a domestic water source). In\nTexas, water wells within 1 mile of a pit need to be recorded in the permit, as\ndoes the depth of the shallowest freshwater for those wells. Arkansas has\nsimilar requirements in its permit for landspraying.
\n
\nPit Liners<\/strong>
\nPit liners are optional for this state but I believe are commonly used. Liners\nshould always be required. The state has no specifications for liners which are\navailable in a variety of materials and thicknesses. The state also has no\nrequirements for locations of seams (up and down slopes, not laterally, for\ninstance) or installation (type and depth of anchor trench). We believe that\nNew Mexico’s regulations could easily be adapted.
\n
\nBurial and Cover<\/strong>
\nBefore burial, the solids at the bottom of the pit are encapsulated (though\nWest Virginia doesn’t require encapsulation; open liners and contents can be\nburied shallowly). Basically, encapsulation means the pit liner’s edges are\nfolded over the solids preventing their escape. Cover over the burial cell is\nimportant since enough depth is required to prevent plant roots from disturbing\nthe liner’s integrity. The Argonne National Laboratory recommends at least 3\nfeet of cover. We believe that more is required where the reclaimed surface\nwill eventually revert to forest. Soil cover needs to be graded so that the\nsurface doesn’t allow the ponding of water. We believe the Argonne National\nLaboratory’s recommendations should be incorporated in the state’s regulations.
\n
\nPermanent Marker<\/strong>
\nThere needs to be a way to record the exact location of each pit in the state.\nIn New Mexico this is done through a deed notice associated with the surface\nowner’s property deed. New Mexico also requires a permanent marker much like\nthat required in this state for plugged wells — a steel monument 3 feet above\nthe ground’s surface. British Columbia requires a separate pit permit and\nregistration for each pit and the pit number(s) posted at the drill site\n(Arkansas has similar requirements). New Mexico’s regulations were written so\nas to not disadvantage surface owners at the present or in the future because\nof Federal Housing Administration requirements. This state needs to do the\nsame.
\n
\nIn a future post we’ll present our recommendations for pits adapted from our\ncomments for Raymond City #17.
\n
\nSources:
\n
\nArgonne National Laboratory. Fact Sheet – Onsite Burial (Pits, Landfills)<\/em><\/a>. Drilling Waste Management<\/em>, web page accessed 20\nSeptember 2008.
\n
\nArkansas. 2008. Authorization to\nConstruct, Operate and Close the Pits Associated with Oil and Gas Well\nExploration<\/em><\/a>. Arkansas Department of\nEnvironmental Quality, Permit No. 00000-WG-P.
\n
\nBritish Columbia Oil and Gas Commission. n.d. British Columbia Oil and\nGas Handbook, Chapter 10, Drilling Waste Management<\/em><\/a>. n.p.: British Columbia Oil and Gas Commission.
\n
\nDepartment of Housing and Urban Development. 1999. Changes to Handbook\n4150.2, Valuation Analysis for Single Family One- to Four-Unit Dwellings<\/em><\/a>. n.p.: Department of Housing and Urban Development. Chapter\n2: Site Analysis, 2.2.E.
\n
\nNew Mexico. 2008. New Mexico Code and State\nRules for Oil and Gas<\/em><\/a>. New\nMexico Energy, Minerals and Natural Resources Department, Oil Conservation\nDivision.
\n
\nNew Mexico. Highlights of the\n“Pit Rule” — 19.15.17 NMAC<\/em><\/a>.\nSanta Fe, NM: New Mexico Energy, Minerals and Natural Resources Department, Oil\nConservation Division.
\n
\nRailroad Commission of Texas. Surface Waste Management\nManual, Chapter 4, Pits<\/a>. Railroad\nCommission of Texas website, accessed 8 December 2008.<\/p>\n","protected":false},"excerpt":{"rendered":"

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 […]<\/p>\n

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