These three videos were shot by Beth Little of the West Virginia Chapter of the Sierra Club. They demonstrate issues with the commercial Underground Injection Control (UIC) class 2 well in Fayette county at Lochgelly operated by Danny Webb Construction.
Commercial UIC class 2 wells inject oil and gas generated liquid waste underground at high pressure into a formerly producing natural gas zone. In the case of the Webb UIC well, this is the Weir formation which is relatively shallow, about 2500 feet below the surface.
West Virginia gained primacy over its UIC program from the EPA in the 1980s. Primacy allows a state program, which meets or exceeds federal standards, to regulate UIC wells. There are federal requirements specific to state programs and there are federal requirements for all programs. These include periodic inspections; proper handling of complaints; monitoring of injection pressures, fluid volumes and flow rates; and site security for commercial UIC 2 wells.
The Webb UIC well (47-019-00460) demonstrates deficiencies in the state's program. It's impossible to track UIC well complaints in the Office of Oil and Gas' file system -- complaints are not placed in UIC well files. Monitoring of injection pressures, fluid volumes and flow rates is haphazard. For the first 5-year permit period, Webb never reported injection pressures, for instance. They have yet, since 2002 when the well received its first permit, to report flow rate. Site security is an important issue, especially for an operator who has received a Notification of Violation for adding used oil in the fluids to be injected.
More information on the Webb well documents gained through FOIA requests.
The stream by the pits
The video showing the stream demonstrates contamination from the injection well facility. The stream is normal in appearance and chemistry above the site and where it runs into a freshwater pond. By the time it reaches the seeps at the base of the pits' bank the water is orange. Further downstream vegetation has captured "gunk" that acts like oil on the water's surface.
A number of lab tests have been conducted on samples from various locations on the stream. Webb's show low iron and chloride. Samples collected by the West Virginia Department of Environmental Protection and others show high iron and chloride and one test showed glycols (used as friction reducers in hydraulic fracturing) and methane.
The 2007 UIC permit required that the operator remove the materials from the pits and backfill. That hasn't been done as this video shows. In order to keep the pits, the operator signed a Consent Order with the Department of Environmental Protection in 2008 that required laboratory testing of samples collected from the pits, the stream by the pits and downstream of the pits. Webb has found it impossible to comply with these requirements and there's no record showing where exactly stream samples were collected.
The 2013 draft permit allows the operator to keep the pits, requiring compliance with the Consent Order.
The open gate to the injection well
The injection well, according to the Webb's monthly reports to the state, operates 24 hours a day. There's a gate on the access road that is usually kept open. The operator has video surveillance of the site but there is no other site security except for a fence around the pits. The video shows the types of traffic that goes through the open gate.
The EPA's Guidance number 77 (dated 1992) for class 2 commercial wells requires a site that is entirely fenced. The Guidance is applicable to states like West Virginia with primacy.
The draft permit requires a fenced site. The operator is currently injecting liquid waste without a permit and without having a fenced site.
An Underground Injection Control Class 2 Well in Putnam County, WV
Three videos about issues at a UIC Class 2 well in Fayette county
Two Problem Wells
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They Don't Do It That Way Any More: Fracturing with Explosives
Drilling Causing Problems in Wetzel County, West Virginia
Gas Well Study Cooking Class: Making Fracking Gel
Natural Gas: Blunders and Numbers
Bad Well Bad Well Bad Well
Natural Gas: Trashing the Surface Owner
Three Natural Gas Wells
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.
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The Spill at Buckeye Creek
An investigation into a spill from a Marcellus well site into Buckeye Creek in Doddridge county.