The following are the most frequently asked questions, or “FAQs” regarding the extreme extraction industry methods of high pressure, high volume horizontal hydrofracking (fracking), and mountain top removal (MTR), along with the dangers that their waste byproducts pose to the health and safety of the general public. More info about the many health dangers that Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) pose may be found by clicking on this link.
If you have any additional questions, and/or facts that you believe should be placed on this page, please drop me an email and I’ll do my best to include your suggestion.
permalink = mountainparty.com/faqs.
- Question: Why should anyone be concerned about extreme extraction industry waste? Answer: The volumes and especially toxic waste streams from hydrofracking and mountaintop removal have, by far, the most potential to seriously degrade the health, safety and welfare of communities. That’s because they each are rapidly developing industries, so the waste they each produce is the least regulated of all of West Virginia’s industries due to the state’s inability (or unwillingness) to keep up with technology. Due to their powerful lobbying efforts, extreme extraction industries are the least closely regulated of any of West Virginia’s large industrial operations. For more details, check out the Mountain Party Resolution at the following link: http://www.mountainpartywv.com/?p=758
- Question: Will halting extreme extraction industry waste from being dumped, released, or injected within West Virginia’s borders actually stop coal, oil, or gas from being produced in the Mountain State? ANSWER: Not likely. While there are viable alternative methods for less destructive methods of extraction and subsequent field preparation of fossil fuels, it is highly unlikely that the industry will ever adopt them without being forced. The implementation of safe and proper regulation of extraction industries most always requires the creation of more jobs, which increases the cost of production. Any “unnecessary” change resulting in increased cost will always be shunned by corporate boards. So the ultimate responsibility for halting the sacrifice of the water, soil, and air has always been up to local citizens to inform and protect themselves.
- Question: Is all frack waste dangerously radioactive? ANSWER: It might as well be. According to a rigorous and authoritative peer reviewed study by a team of US Geological Survey research scientists conducted back in 2011, flowback samples from a statistically significant number of horizontally hydrofracked wells across the Marcellus established the median amount of radium in waste fluid flowback at 2,460 picoCuries per Liter ”pCi/L”. By comparison, the Maximum Contaminant Limit for combined radium in drinking water is 5 pCi/L. In other words, modern frack waste contains radium typically 492 times the safe amount to drink. It is also notable that the direct discharge remediation action level set forth by the U.S. Nuclear Regulatory Commission (NRC), 10 CFR Part 20 -Appendix B, Table 2, for total Radium (Ra-226 + Ra-228) content in Liquid Industrial Effluent, is 60 pCi/L. Mark Engle, a member of the USGS team of scientists that established the median at 2,460 pCi/L back in 2011, has observed that it is not unusual for Marcellus brine to register at 300 times the NRC limit for industrial wastewater discharge.
- Question: Just because flowback from the Marcellus is generally radioactive, it does not necessarily prove that waste being injected in West Virginia is “hot”. And if it truly is radioactive, wouldn’t there be documentation of it? ANSWER: Because WV State regulators choose to bypass existing regulations that require safe and proper regulatory oversight of TENORM, there isn’t much data here in WV. At least none that is readily available to the public. However, among the permit application documents submitted by Danny Webb Construction “DWC” there are sample test results revealing a radium content at 3,327 pCi/L in the injectate sample, which is far higher than the median established by the USGS back in 2011. There were no other sample result documentation of radioactivity because DEP never required. The reason the one test showed such an elevated level is most likely because after the water and chemical mixture prepared by the fracker is forced horizontally through the radioactive Marcellus shale for up to 2 miles, the mixture is commonly recycled numerous times in West Virginia. Recycling increases radioactivity in the brine during each stage. After it has picked up so many contaminants that can no longer be effectively filtered on site, it is then trucked off to be disposed in one of the many Class II wells scattered throughout West Virginia.
- Question: Just how many Class II wells are there in WV? ANSWER: According to the EPA’s March 13, 2013 online UIC inventory table, there are 759 Class II injection wells in West Virginia. Although the EPA’s inventory table didn’t reflect how many wells are operating without UIC permits at the time, it has been recently discovered that there likely are at least thirteen Class II wells currently operating across 10 WV counties without permits.
- Question: Just because one sample of injectate from a Danny Webb Construction permit happened to indicate high radioactivity, it doesn’t prove that any other wells in the State have received waste “hot” with radionuclides. And why isn’t there more evidence that frack waste in West Virginia is radioactive? ANSWER: The reason there is so little West Virginia radionuclide data is because State regulators unfortunately have chosen to ignore existing State laws that require the proper characterization, labeling, storage, handling, disposal, and reporting of TENORM from oil and gas industry production. Instead, regulators have adopted a policy of falling back on a number of federal exemptions created back in 2005. However, there is another sample report from another Class II well in Ritchie County that reportedly injected frack waste containing radium measured at a total of 3,335 pCi/L which, like the DWC sample is far higher than the typical amount established by USGS researchers back in 2011. To its shame, the DEP knew about the dangers of radionuclides in frack waste as early as 2009, when it ordered the municipality of Wheeling to stop accepting and processing it, partially because of the high TENORM content.
- Question: Just what is a waste injection well, anyway? ANSWER: The EPA describes an injection well as a device that places fluid underground into porous rock formations, such as sandstone or limestone, or into or just below the shallow soil layer. In WV, it may also include pumping coal slurry waste from coal prep operations into abandoned coal mines. State regulators have long considered injection wells to be the West Virginia’s “best available technology” for disposing liquid and semi-liquid (sludge or slurry) waste from the extraction and production of coal, oil, and gas. This policy is dangerously outdated, considering the known contaminants and high volumes produced by modern extreme extraction methods, not to mention the seven (7!) existing exemptions from regulations the oil and gas industry currently enjoys. There have been over 1,000 documented cases of water contamination next to areas of gas drilling as well as cases of sensory, respiratory, and neurological damage due to ingested contaminated water. The different types of waste injection wells are all under the jurisdiction of the West Virginia Department of Environmental Protection.
Since their use began in the 1930s, brine disposal wells have the industry’s method of choice for dealing with fluid waste from oil and gas drilling and extraction activities. Long before any applicable federal or State regulations existed, it was commonplace to use played out gas and oil wells to dispose of brine generated during oil that had been produced from “conventional” sources. By the 1990s, injection wells were regulated either by the EPA or otherwise by individual states under federal guidelines developed to safely oversee the disposal of waste from traditional, or vertically fracked oil and gas wells into shallow, porous sandstone formations. Which was approximately where the “brine” being deposited had originated. The old brine wells of the 1930’s may be identified today as Class II Underground Injection Control “UIC” wells, but they have never been upgraded to safely sequester today’s contaminants.
The flowback derived by modern fracking methods contaminates huge volumes of water with radioactive material, heavy metals, hydrocarbons and other toxins, including cancer causing endocrine disruptors. In West Virginia, the millions upon millions of gallons of waste is temporarily stored on or near the fracking sites in open pits, recycled numerous times, then eventually disposed of by injection into Class II underground wells.
Considering the known incidence of failure of injection wells over time, and particularly how they fail – by leaking back up the borehole outside the casing – it is extremely dangerous to dispose of waste from the unconventional method of high pressure, high volume horizontal hydrofracking in Class II wells.
- Question: Didn’t the DEP stop issuing permits to inject coal slurry or (coal prep sludge) into abandoned coal mines? Answer: While there is currently a temporary moratorium on the permitting of coal slurry injection, due to its having “allegedly” spoiled the aquifers of a number of small communities across WV’s southern coal patch, it is still being injected some areas thanks to exemptions provided by State lawmakers.
- Question: The DEP has declared underground injection to be the best available technology for the disposal of non-solid wastes within the boundaries of the state of West Virginia. So why aren’t they safe? ANSWER: They are unsafe primarily because administrators at the DEP and the WV Department of Health & Human Resources “DHHR” choose to ignore or otherwise mischaracterize the extremely toxic nature of wastes generated by modern extreme extraction industries. Outdated current State policies are based on “conventional” methods of extraction from “conventional” sources. These policies place the waters of the State in great jeopardy. For example, 47CSR13 – West Virginia’s REQUIREMENTS GOVERNING WATER QUALITY STANDARDS under §47-13-4.2a only permits the injection of waste from “conventional” sources into Class II UIC wells. HOWEVER, The Marcellus Shale has long been considered as an “unconventional” source. Additionally, high-pressure horizontal hydrofracking is universally recognized as an “unconventional” technique. The waste stream from unconventional sources is far more contaminated than from conventional wells, yet neither policies nor regulations have changed.
- Question: Since the waste is being injected so deep, why should the DEP even monitor the type of chemicals going into Class II injection wells? Answer: There are three reasons to monitor what goes into all injection wells: a. To prevent corrosive damage and eventual leakage from compromising the mechanical integrity of the well; b. To maintain a list chemicals adequate to detect leakage; and, c. to maintain a list of possible contamination in the event that a well is discovered to be leaking.
- Question: Does the DEP monitoring adequately protect the waters of the state as mandated by law? Answer: Not even close. The DEP currently requires injectate testing for only 15 constituents and those are based on what is produced from “conventional” wells. Although the DEP most conspicuously excludes required testing for radionuclides and their radioactive emissions, the federal Halliburton Loophole exemption, in combination with the Statewide Dirty Secret Water exemption passed several years ago makes it all but impossible to mitigate the full extent of damage to aquifers and/ or surface waters in the event of an injectate release. There are untold variations of hundreds of different chemicals are commonly used throughout all phases of hydrofracking, including drilling, fracturing, extraction of gas and purification of extracted materials. Extremely limited data is available since manufacturers are allowed to protect their proprietary formulas.
- Question: In addition to the radionuclides and other heavy metals from the Marcellus itself, what sort of threat do the other chemicals pose.
- Answer: Christopher Kassotis, a PhD student at the University of Missouri, Columbia, and author of a health study focused on chemicals commonly used in fracking, found “Among the chemicals that the fracking industry has reported using most often, all 24 that we have tested block the activity of one or more important hormone receptors. The high levels of hormone disruption by endocrine-disrupting chemicals (EDCs) that we measured, have been associated with many poor health outcomes, such as infertility, cancer and birth defects.“
- Question: Are the wells at Lochgelly still leaking? Answer: Most likely, since the source of the frack waste discovered in Wolf Creek just downstream from the Fayette County oil and gas injection site back in 2013, by Duke University researcher Dr. Avner Vengosh was never determined, so nothing could be done to stop it if it was. Plus, the DEP never performed any external mechanical integrity tests on the two wells either before, or after, the new permits were issued. It could be why a release of suspected frack waste adjacent to the operation was observed by local geologist Brandon Richardson on Sept. 27, 2015. It’s more than likely also why the DEP investigator subsequently refused to test the reported contaminant on site, and would not provide Richardson with any violation tracking information so that he could follow up.
- Question: Are the wells at Lochgelly still operating? Answer: Yes. They were reissued permit numbers 2D0190460 and 2D0190508 late August of 2015, and they will not need to be renewed for five years. DEP records indicate that more than 1.5 million barrels of waste have been injected down just one of the two wells at Lochgelly, all under high pressure.
- Question: Who is dumping extreme extraction waste in Fayette County? ANSWER: Danny Webb Construction Inc. (DWC) has 2 wells at Lochgelly, and Consol Energy also operates at least one such well in Fayette County. In addition, according to the 2011 Source Water Assessment and Protection report for Fayette County’s largest public drinking water provider frack waste is also being dumped in abandoned Fayette County coal mines. On Table 4, page 7, there is a “highest priority” concern over the knowledge that frack waste is being dump into abandoned mines. The statement is as follows: “Underground mines in some locations are being used to dispose of mine waste and fracturing water from oil and gas operations. The water system staff has expressed concerns about what types of things may be injected into abandoned underground mines and how that will potentially impact the surface water in the future.”
- Question: Is this waste dangerous? Very. , an investigation by the House Energy and Commerce Committee Democratic staff released by Reps. Henry A. Waxman (D-Calif.), Edward J. Markey (D-Mass.) and Diana DeGette (D-Colo.) found that between 2005 and 2009, 14 leading oil and gas companies used more than 780 million gallons of hydraulic fracturing products containing 750 different chemicals, including carcinogenic and other toxic components such as lead and benzene. In fact, these companies used 29 distinct chemicals that are known or possible human carcinogens, regulated under the Safe Drinking Water Act (SDWA) for their risks to human health, or listed as hazardous air pollutants under the Clean Air Act. source
Furthermore, Radium 226 has a half life of over 1600 years. It travels easily up the food chain, so the primary threat is by ingestion. Once r226 enters the body, 20 percent remains there to bio-accumulate. Radium takes the place of calcium in the bones, where the Alpha radiation affects the soft tissues of the body and the blood.
Although difficult to diagnose, numerous illnesses have been linked to long-term low-level exposures to radium, including thyroid problems, blood diseases, and cancer. The smaller the victim’s physique, the more radiation is known to affect the body.
Because radium is a heavy metal, ingestion is known to adversely affect the autoimmune system. Biomagnification through interaction with other pollutants poses additional serious health complications.
- Question: Are these wells drilled through an abandoned coal mine? Answer: Yes. The Sewell Coal mine is largely uncharted, and from there fluid waste can travel to other mines supplying drinking water or empty into the New River. Well construction records indicate a high likelihood of leakage back up the borehole and into that mine.
- Question: Was frack waste discovered in Wolfe Creek below the wells and above the drinking water intake for Lochgellly, Oak Hill and Fayetteville? Answer: Yes. source
- Question: Did the DEP prohibit a scientific from sampling Lochgelly sludge pits? Answer: No, but the Environmental Quality Board did–while stating 3 times in their order that they did so at the request of the DEP source.
- Question: Did the DEP order highly-radioactive frack sludge to be dredged from settling pits in Lochgelly and then sign it into the Raleigh County Landfill as if it was ordinary fill? ANSWER: Yes. Source
- Question: How much waste will the wells hold before they are full? ANSWER: It really doesn’t matter as long as the operator is allowed to keep pumping hydrochloric acid down the well to burn out a larger cavity. And although there is strong evidence that’s exactly what happened, it is a very dangerous gambit as hydrochloric acid solution will also compromise the cement seal between the casing and geologic layers. This common mechanical integrity failure is greatly exacerbated by an attempt to chemically frack sandstone with a strong hydrochloric solution.
- Question: Since the wells at Lochgelly were converted from producing wells into waste disposal units, how do we know that they aren’t leaking right now? Answer: We don’t. There is nothing in the the drillers logs for well 19-00460 to demonstrate any testing was done after cementing to make sure that the cement was adequate (deficient or missing cement bond log), and there is nothing on file with the DEP showing that formation pressure was ever tested below the casing shoe after drilling through a few feet. The DEP thus makes a huge assumption that cementing for the wells is adequate.
NO MECHANICAL INTEGRITY DEMONSTRATED
According to 47csr13 6.1.a.2.a., “an injection well has mechanical integrity if there is no significant fluid movement into an underground source of drinking water through vertical channels adjacent to the injection well bore.”
Unless the type of cement that was used is properly identified (and it wasn’t), it is useless to speculate on the effects that hydrochloric acid or other strong corrosives known to have been used in those wells have had on either the cement itself, or the cement’s ability to maintain a solid bond to the surrounding geological layers. (for graphic clarification, see attachment 6 & attachment 7 )
more to come re: coal slurry