West Virginia's Office of Oil and Gas allows the landspraying of liquid drill waste if it meets certain requirements covered in the West Virginia General Water Pollution Control Permit. The permit as it exists today reached its final form in 1988. Documents we examined at the West Virginia Department of Environmental Protection offices, related to a FOIA request, had to do with the creation and rationale for the permit which underwent several major transformations after the first permit was instituted in the mid-1980s. The state was sued by industry and made changes. The state also stopped allowing discharge of liquid drill waste directly into streams and rivers.
An issue we have with the permit that existed before 2016 was the high level of chlorides (salts) that were allowed to be sprayed out of the pit onto forest or other "nonproductive" land. The state has several categories of pit waste, the lowest chloride level being up to 5,000 mg/l, the highest being 12,500 mg/l (with a waiver allowed for up to 25,000 mg/l). The problem with chlorides is that too great a quantity will kill vegetation and we've heard of sites where landspraying has occurred in this state when even large trees have been killed. Too great a quantity of chlorides can sterilize soil, causing "salt scaring" -- permanent areas with no vegetation at all. Salt scaring is a feature of some older oil fields in other states.
We've been concerned about the levels of chlorides allowed, believing that a maximum of 3,000 mg/l is much more realistic. The problem is that there's another element -- the volume of pit liquids and the area of land that is covered. We believe that chloride load was considered for the permit in the 1980s but was dropped for some reason. Determination of chloride load is required in the 2016 permit.
Here's a simple formula: (volume in barrels) X (chlorides mg/l) X 0.00035 = pounds of chlorides. A barrel is 42 gallons and if we want the weight for 20,000 gallons of waste (476.19 barrels) at 3,000 mg/l it comes out to 500 pounds of chlorides.
To figure the load divide the formula total by the number of acres. Well permit applications we've seen set aside an area of usually less than an acre for landspraying the liquid. Figuring one acre, 20,000 gallons of 3,000 mg/l chlorides is then 500 pounds of chlorides an acre.
Twenty thousand gallons was a figure out of thin air. We've seen a document where the state's average landspraying involves 35,000 gallons. That's 850 pounds of chlorides at 3,000 mg/l.
Oklahoma in the early 1980s determined that the maximum chloride load, per acre, should be 400 pounds. Saskatchewan had a chloride load limit of 400 kg/ha (356 lbs per acre) for landsprayed drill waste. 3,000 mg/l at 20,000 gallons on one acre is already above that. Pits can have 5,000 mg/l chlorides or 10,000 mg/l or up to 25,000 mg/l with a waiver. And while the average landspraying can involve 35,000 gallons we believe that it's not uncommon for wells to have pits with a quarter million gallons or more of waste. Recently the state's Office of Oil and Gas created a memorandum on pits and is working on a draft guidance document for those wells with high volume water usage.
The Berry Energy well had 100,000 gallons (or 2,381 barrels) of waste. If, as according to the company's DMR, the chloride concentration at discharge was 6,210 mg/l, then that means 5,175 pounds of chlorides were landsprayed. For two acres, that is a load of 2,588 pounds (over a ton) per acre.
But, in reality, 80,000 gallons was sprayed on about half an acre, equal to 4,141 pounds of chlorides. That's 0.19 pounds (3 ounces) of salt per square foot. An unreasonable amount by any standard (in Saskatchewan, that drill waste would have had to been spread over at least 11.6 acres). There is reason to doubt some of Berry's test results in their DMR and it is possible that perhaps more than twice as much chlorides was landsprayed in the Forest.
The next chapter discusses the Sodium Adsorption Ratio (SAR). Just as the state had no load for chlorides, it has no program to manage the high sodium concentrations in drill waste.
Go to the SAR chapter.
We have a page about the environmental effects of chloride.
What Happened at Fernow
Fernow Experimental Forest
Discharge Monitoring Report
Liming the Pit
A Short History of Fracturing
What Happened at Fernow
Recommendations & Sources
Gas Well Study is the examination of natural gas wells in West Virginia.
Underground Injection Control Class 2 Wells
These wells are used either for the disposal of oil and gas liquid waste or for the enhanced recovery of oil or natural gas.
Gas Well Study Site Visits
Annual reports, environmental assessments, and individual well information.
Select videos from the Gas Well Study YouTube channel.
What Happened at Fernow
An investigation into what caused the vegetation death in the land application area after landspraying hydraulic fracture flowback waste.
The Spill at Buckeye Creek
An investigation into a spill from a Marcellus well site into Buckeye Creek in Doddridge county.