A Third Spill by Cabot Oil and Gas!

Wow! A third spill is reported in Dimock, Pa, all at the same site by the same company….and all within the span of a week. Talk about not having your act together!

by Abrahm Lustgarten, ProPublica – September 23, 2009

Pennsylvania environment officials have charged Cabot Oil and Gas with five violations after nearly 8,000 gallons of hydraulic fracturing solution spilled [1] from a pipe system in two separate incidents near the town of Dimock last week. The department reported that a third, smaller spill, occurred at the site Tuesday morning.

According to the state, Cabot failed to prevent a fracturing fluid discharge, failed to keep that discharge from escaping into the environment and from entering a creek, and inappropriately dammed that creek after the spill, among other violations. The company could face fines topping $130,000.

“I was concerned with two releases,” said Bob Yowell, director of the north central regional office of the DEP. “A third release, although it was relatively small, gives us great concern that something unusual is happening at this particular well. This isn’t a normal situation.”

The spills began on Wednesday, Sept. 16 at 2 p.m. when a pipe coupling failed on the system that mixes the fracturing ingredients, sending as much as 2,100 gallons of fluid into the environment. At 8 p.m. that same day another pipe coupling broke in the same system, and 5,880 additional gallons of fracturing fluid were discharged, according to both state and Cabot accounts. On Tuesday morning, Sept. 22, another hose ruptured under pressure, releasing 420 more gallons of the same mixture, though only 10 gallons of that last spill escaped from the company’s spill catch system.

According to Ken Komoroski, a Cabot Oil and Gas spokesman, the fracturing procedure was being conducted by two contractors: Halliburton, one of biggest oil services companies in the world, and Baker Tanks, a petroleum storage tank company.

“Our policy is zero spills, zero unpermitted releases, and those goals were not met so there needs to be evaluations of what can be done to prevent them in the future,” Komoroski told ProPublica. “The spills were less than .5 percent gel, and at 99.5 percent water, this material is not hazardous or dangerous nor does it present any environmental risk.”

Pennsylvania officials allowed Cabot to continue fracturing the well while they conducted their investigation. According to the DEP’s Yowell, halting the fracturing may have presented additional problems, though he could not specify what those risks were. Cabot voluntarily halted the fracturing on Tuesday, after the third spill occurred.

The investigation into the spill is ongoing. According to a DEP press release and the notice letter sent to Cabot, a nearby wetland has been flushed and further remediation may be required, including excavation of soil surrounding the site.

ProPublica reported the spills Monday [1], stating that the fluids had seeped into Stevens creek and killed fish there, an assertion repeated in the DEP’s press release on Tuesday. Follow-up interviews with the state’s Department of Fish and Boat Commission, however, show that a small number of minnows were harmed and that the damage to the creek appeared minimal. However, water samples from the creek are still being evaluated, according to the DEP’s Yowell.

According to a Material Safety Data Sheet provided to the state by Halliburton, the substance spilled was a lubricating gel used in hydraulic fracturing that poses a substantial threat to human health and was described in the Halliburton document as a “potential carcinogen” that has caused skin cancer in animals.

Cabot’s Komoroski points out that the document refers to the gel’s concentrated form, and that the mixture spilled in Dimock was mostly water. He also disputes the information on the Halliburton form that warns the product is a “potential carcinogen.” The disclosure, required by law on the MSDS form, was an effort to be extremely conservative and account for the possibility that a derivative from the refining process could be part of the gel mixture, Komoroski said. He could not say what that derivative was, except that it is a hydrocarbon.

Halliburton did not respond to questions about the details of its MSDS disclosure for the product, called LGC-35 CBM.

Charleston Gazetee WV, Coverage of Dunkard Creek

http://blogs.wvgazette.com/coaltattoo/2009/09/21/more-on-dunkard-creek-fish-kill/

If you have time to check out this link, do so. And make sure you scroll down and read the comments and check out the posted links from those making the comments. All sorts of thoughts and information here. After checking over this site and reading all the comments from the NPR story yesterday, I am rather upset by the number of spills and damage reports that have not made any big news waves. It seems there is all sorts of smaller stuff going on and in general I feel that, as usual, the media is not doing a very good job of covering it. Well, some local papers and online sites are doing a very good job while others seem to pick an choose what information to discuss and pretend the rest of the story is not going on. I’m still waiting for NPR to redeem themselves……

This blog has a good write up on the indeterminate factors of what is killing the life in Dunkard Creek.

http://blogs.wvgazette.com/coaltattoo/2009/09/17/mon-county-fish-kill-could-coal-be-the-culprit/

Conservation board OKs resolution on fish kill

This is an article from the Observe-reporter.com that relates to the accidentlal fracking fluid spills that took place at Dunkard Creek near Waynesboro, PA earlier this week. I could not get the link to work so I’ve posted the whole thing here and hopefully got rid of the HTML code that was pasted in it.
By Bob Niedbala

WAYNESBURG – Greene County Conservation District approved a resolution Tuesday supporting efforts to identify the cause of the Dunkard Creek fish kill and urging re-establishment of the creek as a warm water fishery.

The board also agreed to ask state and federal agencies responsible for enforcing environmental regulations and investigating the kill to attend a public meeting to discuss the situation.

State and federal agencies involved in the investigation have not been able to determine what caused thousands of fish and other aquatic life to die in the creek during the last three weeks.

The board wants to make sure this doesn’t happen again, said Robbie Matesic, county director of development.

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“They were alarmed by the fact we don’t know about activities taking place in the Dunkard Creek watershed that the federal and state agencies do know about,” she said.

One issue discussed by the board was the permit issued by the federal Environmental Protection Agency in 2005 to CNX Gas to operate an injection well at the former Blacksville No. 1 Morris Run Mine Shaft for brine from the company’s coal bed methane wells.

EPA issued an administrative order last month assessing the company a $157,500 penalty for failing to adequately staff and secure the well site, monitor the well’s cumulative volume and report permit non-compliance.

EPA found that between September 2007 and March 2009 at least 100 truckloads of materials were discharged at the site with levels of total dissolved solids “significantly higher” than levels included in the permit application.

Though the well is not being blamed for the fish kill, local officials were unaware of its existence. “We can find no evidence we received any notice of this permit, the violation or the consent order,” Matesic told the board.

Martin Niverth, also with the county department of development, called the EPA consent order “vanilla,” saying it requires the company to do only what it should have been doing from the beginning.

“We must take ownership of our resources,” Niverth said later. This will involve putting in place methods to be aware of such developments and to comment on them before they become reality.

Matesic said the county estimates the economic value of the 38 miles of lost stream, using Pennsylvania Fish and Boat Commission restoration guidelines, is more than $30 million.

The resolution approved by the board cites efforts by the county and the conservation district to address water quality issues in the watershed.

They include spending $460,000 for the development of sewage plans and line extensions, participating in a study to explore the treatment of acid mine discharge sources and cleaning up illegal garbage dumps.

County and the conservation district have worked to take care of problems they are aware of in the watershed, Niverth said. “We’ve worked our butts off and spent money only to have this slap us in the face,” he said.

The resolution notes exploitation of Marcellus shale gas has caused a significant demand on local water resources and water treatment capacity “that responsible permitting, monitoring and enforcement agencies were unprepared to accommodate.”

The resolution further states that any extractive industry should bear the responsibility, regardless of costs, for the full protection and restoration of natural resources after extraction is completed.

DEP: Aquatic disaster ‘different from any’ in recent years

A chief environmental enforcement official said Tuesday the massive fish kill in Dunkard Creek is “different from any that we’ve had in recent memory.” Michael Zeto of West Virginia’s Department of Environmental Protection Agency said what makes this fish kill so different is there may be more than one source causing the aquatic disaster. “Typically, there is a chemical or physical characteristic that points to a single source. Then, we deal with who is responsible from there. However, this fish kill may have several possibilities that could be contributing to the cause,” Zeto said. West Virginia DEP is investigating the fish kill jointly with the West Virginia Department of Natural Resources, Pennsylvania Department of Environmental Protection, Pennsylvania Fish and Boat Commission, U.S. Environmental Protection Agency and West Virginia University. “We understand the frustration people are feeling, because we feel it, too,” said Scott Mandirola, director of the West Virginia DEP’s Division of Water and Waste Management. “That’s why we have a large number of people working on this and are working with other agencies to try to determine what could be causing it,” he said. Because of heavy mining activity in the area, the industry was an early suspect. In fact, after conferring with West Virginia DEP, Consol Energy, which operates an active mine in Blacksville, W.Va., agreed to shut off its discharge into Dunkard Creek at its Blacksville No. 2 site. However, at the same time Consol was shutting off its pumps, dead fish were found upstream from its outlet, indicating that the outlet at that site is not the sole cause for the dead fish. In addition, inspectors checked mine pools from previous mining activity that are often sources of acid mine drainage. However, the water levels in the area are hundreds of feet below stream elevation at this time because the area has not received much rain in recent weeks. The agencies also have received reports from area residents suspecting tanker trucks of dumping waste water from oil and gas drilling activities into Dunkard Creek. Various agencies continue to investigate those reports. “We have found that those trucks that have been reported are withdrawing water from the stream, rather than dumping waste water,” Zeto said. On Friday, staff members from West Virginia DEP flew over the area in a helicopter to see if there was anything they could see from the air. The staff noted the stream was clouded with a rust color from the Pennsylvania line upstream to a beaver dam in the South Fork of the West Virginia Fork of Dunkard. As a result, additional staff was brought in to take samples along the 25-mile stretch. Investigators also have solicited the assistance of micro-biologists to help determine whether some form of algae or similar growth may be a contributing factor.

Dunkard Creek PA/WV

Here is an article from the Pittsburg Post Gazette about Dunkard Creek, a waterway that traverses Pennsylvania and West Virginia. The article lays out a mystery about the death of this creek and it’s eco-system, one of which they are still trying to figure out.

http://www.post-gazette.com/pg/09263/999458-113.stm

Gas Drilling in the Marcellus Shale and Pennsylvania’s Coldwater Resources Pennsylvania Council of Trout Unlimited

This paper was in my inbox this morning and I thought all of you might like to read it as well.

Gas Drilling in the Marcellus Shale and Pennsylvania’s Coldwater Resources
Pennsylvania Council of Trout Unlimited

February 13, 2009
Introduction
A major natural gas boom is underway in Pennsylvania. Energy companies from across the US have come to this region to drill for gas in a geological formation known as the Marcellus Shale. PA Trout Unlimited believes the Marcellus Shale gas boom has the potential to significantly damage Pennsylvania’s coldwater resources and trout fisheries, if not managed properly.
What is the Marcellus Shale?
Marcellus Shale is located in the Appalachian region of the US. It spans approximately 600 miles from the southern tier of New York through Pennsylvania and Ohio, and into West Virginia. Its area is estimated to cover about 54,000 square miles, and it coincides with the location of many of Pennsylvania’s wild trout streams. Marcellus Shale is variable in depth. A majority of the shale is about a mile deep, and in some areas it is as deep as 9,000 feet below the surface. Marcellus Shale is a low-density rock with tight pores that hold natural gas. It is estimated that the Marcellus Formation holds 363 trillion cubic feet (TCF) of recoverable natural gas. In 2006, the US consumed more than 21 TCF of natural gas, and current estimates state that the US now uses approximately 30 TCF of natural gas per year.
How is gas extracted from Marcellus Shale?
Natural gas has long been produced from shallow shale formations. However, recent advances in deep well drilling combined with horizontal drilling, and advances in hydrofracturing (fracking), have made gas extraction from deep shale formations economically feasible.
Depending on the geology, gas companies use both vertical and horizontal wells to capture the gas. Wells can be drilled vertically for several thousand feet. Then the drilling can be angled, creating an arc to the horizontal, and drilling can be continued horizontally through the shale formation for several thousands of feet. Multiple wells may be drilled from the same well pad site, radiating out horizontally from a central vertical well. Well pad sites can vary in size from 3 acres up to 30 acres, or more.
Fracking is a technique used to release natural gas from the tight pores of the shale. A mixture of water, chemicals and proppant (usually sand) is pumped down the well and into the shale at high pressures. The pressure creates fractures in the shale and the proppant holds open the fractures to allow gas flow from the shale and into the well. Chemicals used in fracking may include friction reducers, biocides, surfactants and scale inhibitors.
Fracking requires large quantities of water. Horizontal projects typically use between 1 and 3 million gallons of water for the initial fracking. It is important to note that wells drilled in Marcellus Shale may have to be hydrofractured several times over the course of their lifetimes to keep the gas flowing.
The millions of gallons of water must be piped or transported by truck to the well site prior to a fracture treatment. The flowback water (waste water) from the fracking operation must also be trucked out to a disposal facility. A large percentage (20% to 40%) of the injected fluid remains underground for some time. Fracking and treatment fluids do not come back all at one time. At first, the flowback is primarily treatment/fracking fluids, but this is diluted by formation water. As time goes on, the percentage of treatment/fracking fluids decrease and the percentage of formation water increases. Flowback of fracking fluids and water can continue over a period of years.
Presently there are 63,000 registered wells in Pennsylvania, including those currently producing natural gas, and those which have been drilled and capped for future production. The vast majority of these are vertical wells that have been developed using fracking with water and sand, similar to the fracking techniques used within the Marcellus Shales.
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Brines from vertical wells have been treated at several treatment plants throughout Pennsylvania that are dedicated to brine disposal. Other methods of disposal include use as dust suppression on dirt roads, use by the Pennsylvania Department of Transportation (PennDOT) for road treatment for ice and snow, and dilution through sewage treatment plants. While abuses have occurred, especially on the over-application of brines for dust suppression, major environmental impacts have been addressed and enforcement actions taken. Unfortunately, these brine treatment facilities are not currently equipped to effectively deal with some of the production fluids used in the Marcellus gas extraction process.
What permits are required?
• Well Drilling Permit and Addendum – The operator must obtain a drilling permit, pursuant to the Oil and Gas Act, as well as an application addendum outlining a water management plan for that operation, pursuant to Title 25 PA Code 78.11-33.
• Earth Disturbance Permit (ESCGP-1) – The operator must obtain a permit from the PA Department of Environmental Protection (PA DEP) for implementation of erosion and sediment controls, including stormwater management, if the site disturbance area is greater than 5 acres. A plan for erosion and sedimentation control is required if under 5 acres. Sites in excess of 5 acres must obtain a general sediment and erosion control permit under Chapter 102.
• Preparedness, Prevention and Contingency (PPC) Plan – The operator is required to prepare and implement a PPC Plan and make it available to PA DEP upon request. The plan must address the types of wastes generated, disposal methods and a spill prevention plan. Construction and operation of on-site storage impoundments must also be described.
• Water Withdrawal Permits – PA DEP has required water withdrawal permits for all withdrawals of surface or ground water. For projects located in the Delaware or Susquehanna Basins, a separate Delaware River Basin Commission (DRBC) or Susquehann River Basin Commission (SRBC) water withdrawal permit is required.

Chapter 105 Obstruction and Encroachment Permit – An operator must obtain a permit from PA DEP for construction, excavation, or operation in a wetland, stream, or body of water. A similar requirement is also required under the Oil and Gas Act.

Water Quality Management Permit – An operator must obtain this permit if a centralized impoundment will hold fluids other than fresh water (such as drilling or fracking fluids). The siting, construction, use and closure of temporary pits are regulated under Chapter 78. Permits are only required if the pit is part of a treatment facility. However, permanent impoundments to hold drilling or fracking fluids are rare. In the case of freshwater impoundments, strict adherence to design and safety standards must be met and adequately enforced.
Pennsylvania TU’s position on gas drilling
We understand that natural gas drilling and other energy developments are important to the economy of the Commonwealth and the nation. However, we are adamant that this drilling be done in a manner that does not damage our natural resources. Deep gas well drilling is relatively new to Pennsylvania, and the environmental concerns have not been fully evaluated prior to numerous permits being issued. Adequate permit restrictions and oversight are necessary. We encourage our regulatory agencies to actively ensure that all protections be enforced to protect our water resources as afforded under the Clean Water Act and the Clean Streams Law.
What are our concerns?
1. The removal of millions of gallons of water from streams and aquifers to frack the Marcellus gas producing zones. 2. The potential environmental damage the fracking water will do; both on site and during its disposal.
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3. Drilling activity in Special Protection Watersheds (HQ and EV streams) and Wilderness Trout Designated areas may permanently affect these areas. 4. Bonding is inadequate to deal with plugging/closing of wells and to deal with any long-term environmental implications of orphan/abandoned well sites. 5. Potential increase in sediment and stormwater from the well pad sites. 6. Resource agencies may be inadequately staffed to deal with the increase in permit requests and on site enforcement.
What should happen?
1.
Marcellus Shale drilling and production presents a new series of problems. Namely, the need for millions of gallons of water for fracking, and the need to properly treat and dispose of this water when it returns to the wellhead. Simply put, Pennsylvania must enact criteria and disposal methods not yet employed in the Commonwealth. As an organization concerned with coldwater fisheries and the water quality and quantity needed to support these fisheries, Pennsylvania Trout Unlimited (PATU) insists that PA DEP must meet this new challenge. For example, PA DEP should encourage the use of reverse osmosis units to remove salts and any associated heavy metals from production waters and reuse the resulting water for future fracking.
2.
PATU strongly believes that Marcellus Shale development cannot be permitted within Exceptional Value (EV) watersheds. We do not see how the existing Best Management Practices (BMPs) for sediment and erosion control, given the significant earth disturbances associated with road and pad construction, can comply with the anti-degradation standards required under the Clean Streams Law.
3.
PATU sees an urgent need for PA DEP to change its present bonding requirements for existing vertical wells, and to cover the likely higher plugging costs for Marcellus wells. PA DEP needs to take immediate steps to determine the anticipated costs of closing Marcellus wells. PA DEP needs to consult with surrounding states regarding their existing or proposed bonding rates for this class of wells. PA DEP also needs to work closely with the Interstate Oil and Gas Compact Commission (IOGCC) to assure that bonding rates meet the necessary closing costs for Marcellus wells. Without adequate bonding, Pennsylvania will inherit more abandoned wells that cannot be properly closed, and that risk the spewing of contaminants into our waterways, much as we presently see from pre-Act drilling, and where bonding was inadequate to close the wells.
4.
PATU sees an urgent need for PA DEP to require a severance fee adequate to meet the Department’s costs for permitting, inspections and enforcement, including the logistical needs of the program.
5.
In High Quality-Coldwater Fishery (HQ-CWF) watersheds, PA DEP should, at minimum, require individual permits for gas development. Individual permits assure that the public has an opportunity to review, object to, or request a public meeting on, the proposed drilling operation and its associated discharges prior to the issuance of the permit. These options are not available with the present practice of issuing general permits pursuant to Chapter 102. Appeal rights, under the general permit, are limited to a short window after issuance of the permit. We find this practice unacceptable.
6.
Drilling projects have the potential to cause multiple impacts on our environment. Permit approvals should consider all of the impacts before issuing a permit, including water needs for drilling, treatment and discharge of backflows and brine, habitat destruction from drill site pads, and erosion from road construction and pipeline construction.
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7.
PATU urges state agencies to prohibit any oil and gas development in Exceptional Value (EV) watersheds, Wilderness Trout Stream watersheds, EV wetlands or areas containing threatened or endangered species. Increased oversight should be applied in High Quality-Coldwater Fishery (HQ-CWF) watersheds.
8.
We insist that water withdrawal permitting by SRBC, DRBC and PA DEP be closely monitored. Namely, flows from the permitted watershed need to be documented at the time of withdrawal to assure that the stream uses are protected. This will require that flow monitoring devices are part of the permit, thus assuring that the Q-7/10* is not violated.
9.
PA DEP is obligated to consider the cumulative impacts these drilling sites will pose in a watershed. In addition, resource agencies should evaluate the overall impacts to groundwater and surface flows and place a cap on permits to prevent Total Maximum Daily Loads (TMDLs) from being reached. While any one project may do minimal damage, the cumulative impacts from multiple projects could cause significant damage.
10.
Surface landowners must consider the cumulative impacts of site development as it pertains to forest fragmentation and its potential impacts on our coldwater resources.
11.
Roads built to and around well pad sites should be required to incorporate Environmentally Sensitive Maintenance principles as outlined by the Center for Dirt and Gravel Roads Program.
12.
Fracking water must be treated at facilities built to meet NPDES permit requirements. Municipal sewage treatment plants are not capable of treating chlorides and toxins present in fracking water.
13.
The public has the right to know what materials the industry is injecting for Marcellus Shale development. It also has the right to know the chemical analysis of the flowback water.
*Q-7/10 is defined as a consecutive 7- day low streamflow during a ten year drought. Water quality modeling is based on this low flow condition to assure that stream uses are maintained.
Whom should I contact with concerns?
If you believe that drilling activities have affected water resources or caused pollution, you should contact your nearest PA DEP Regional office, County Conservation District (CCD), Pennsylvania Game Commission (PGC), or the Pennsylvania Fish and Boat Commission (PFBC). The numbers are as follows:
PA DEP Regional Offices:
Northeast: (866) 255-5158
Northcentral: (570) 327-3636
Northwest: (814) 332-6945
Southeast: (484) 250-5900
Southcentral: (877) 333-1904
Southwest: (412) 442-4000
Toll free, after hours and weekend:
1-800-541-2050 or 1-866-255-5158
Pennsylvania Game Commission Regional Offices:
Northeast: (570) 675-1143
Northcentral; (570) 398-4744
Northwest: (814) 432-3187
Southeast: (610) 926-3136
Southcentral: (814) 643-1831
Southwest: (724) 238-9523
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Pennsylvania Fish and Boat Commission Regional Offices:
Northeast: (570) 477-5717
Northcentral: (814) 359-5250
Northwest: (814) 337-0444
Southeast: (717) 626-0228
Southcentral: (717) 486-7087
Southwest: (814) 445-8974
References:

PA DEP’s Marcellus Shale Page: http://www.dep.state.pa.us/dep/deputate/minres/oilgas/new_forms/marcellus/marcellus.htm

Penn State Cooperative Extension Natural Gas Page: http://naturalgas.extension.psu.edu/

Oil and Gas Accountability Project: http://www.ogap.org

Pennsylvania Land Trust Association Oil and Gas Page: http://conserveland.org/pp/naturalgas

Natural Gas Lease Forum: http://www.pagaslease.com/natural_gas_well_mapper.php

Starting to Gather

Today I  started searching out other folks in my community who have contact information for others who share my concerns with the drilling proposals and regulations that currently exist in  Pennsylvania. I am hoping these contacts are able to provide me with some of the information I am looking for. Water quality and aquatic life preservation are just one of the many concerns voiced to me by people in this area. I am excited about the possibility of connecting with some folks at Penn State who are currently doing research in regards to just that.