“Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia,” Prepared by: Marshall University Center for Environmental, Geotechnical and Applied Sciences; and Glenville State College. Submitted to: WV Department of Environmental Protection: July 1, 2015
Report Review by William J. Hughes, Wetzel County Solid Waste Authority, New Martinsville, WV, July 10, 2015
Introduction: (All page numbers are referenced to the PDF version of the 195 page report to the WV-DEP)
Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College, which is supported by over 2300 pages of semi-raw data and graphs and charts and tables, requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide an independent perspective and to aid reflection on how sections of this report might be interpreted.
The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the WV Legislature told the WV Department of Environmental Protection (WV-DEP) to do. Second, then the WV-DEP added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. And finally, the most constricting factor was the large body of existing data within the possession of the WV-DEP which was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.
And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing, natural gas industry which is supported by most of the people in the political administration. Therefore we must be cautious here. The presence and influence of political and economic factors must be considered also. And for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.
Simplified Summary Statements — (All page numbers are referenced to the PDF version of the 195 page report to the WV-DEP)
- Marcellus shale cuttings are radioactive: 17/195; 139/195; 142/195; 154/195
- We do not know if there is a long term problem: 19/195; 96/195
- About 30 million tons of waste expected in next few decades: 176/195
- Landfill liners leak: 20/195
- Owning and operating their own landfill would be expensive and risky for the gas companies: 186/195; it appears that citizens might have to bear the environmental and financial risks related to new landfills.
- Gas well drill cuttings are toxic to plants: 97/195
- Landfill leachate is toxic to plants and invertebrates: 97/195
- If all systems at landfills work as designed, leachate might not affect ground water: 41/195
- Other landfills also have radioactive waste: 14-15/195
- We have no idea if this will get worse: 154/195
- This has not been done before: 78/195
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Three categories of comments will be included here on various aspects of the total 195 pages of the Marshall University Report recently provided to the WV Department of Environmental Protection: Good — Positive aspects, good suggestions, or important observations; General – General comments; Flawed – Problems, flaws, limitations, etc.
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Comment ONE —Water Quality: EPA test protocols and data sets.
General – It is obvious that a very smart and well trained set of researchers put a lot of long, detailed thought into analyzing all the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all the existing years’ worth of leachate chemical and radiological information.
Good — There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some “non-detect” values and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and drew some conclusions.
Flawed – However, the most glaring flaw and the greatest limitation is the nature of the very data set provided to the researchers from the WV-DEP. It is to the commendable credit of the WV-DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill. That way we could keep track of where the drill cuttings are when there are future problems.
To the best of my knowledge, until the black shale industry required it, regulatory agencies (in other states also) have never knowingly deposited large quantities of industrial waste products which were known for decades by geologists and radiochemists to be radioactive, into generic municipal waste landfills. We just have not done it. We knew better. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.
Now we are a little better informed. We are slow, but learning. But three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem we chose the wrong test protocol to use when having all the leachate samples tested. We stipulated the commonly used and familiar clean drinking water test procedure. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately most of the chemistry test results should still be accurate and useful .
At first, three years ago, this was understandable and possibly not an intentional error. But now, it is widely known by hydrogeologists and radiochemists, at least at the PhD level, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high Total Dissolved Solids (TDS). Method 900.0 is designed for low solid samples like drinking water supplies. There is general consensus on this now. And almost a year ago authoritative studies containing this information was provided directly to the WV-DEP.
Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. But it is clearly known now that the protocols that were used for all samples all along when testing for Gross Alpha, Gross Beta and Radium 226 and Radium 228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on quite a few of some very important topics. These topics of concern include: surface water quality; potential ground water contamination; exposure levels at landfills; and public health implications; as well as policy and regulations considerations.
Leachate test samples over all the years were processed using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Laboratories certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. They use them regularly, and they have been widely used for years. They are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations including flowback and produced water or brines and leachate. Using the incorrect lab process for sample preparation and testing will guarantee that the results will continue to be incorrect.
It seems that the best suggestion so far to test liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium detector with at least a 21 day (30 days are better) hold period. The sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties which might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. The Radon 222 must not be allowed to escape. The proper test instrument, recently calibrated and also designed for the specific sample is crucial to get useable test results from which conclusions can be drawn and policy enacted.
So far, in no place in the final 195 page report have I seen any discussion of exactly which EPA test protocol was used and why was it used. It has also not yet been seen in the 2,300 plus pages of supportive statistical and analytical results either. The fact that the wrong protocol was used three years ago is very understandable. However this conventional EPA 900 series was still being used on the additional very recent, (done in fall of 2014) new samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol. It might have been justifiable to also use the clean drinking water procedures along with the 901.1M (gamma spec) process, for comparison.
It is understandable that for the new data to be consistent with the very large existing data set that a case could be made for sticking with the incorrect protocol. But there should have been a detailed discussion of what and why any test method was being used. That type of discussion is usually one of the first topics investigated and explained. Having that type of discussion and justification would be appropriate to the basic science method and accepted research process. And that omission is a serious flaw.
The section of the report on “potential environmental impacts to water quality” seems to demonstrate that if you do not want to find out something, that there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some of the Marshall University folks did not seem to have the option to stray into important fundamental scientific aspects and for the most part, just had to work with the stale data sets given them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results.
Note: Comments Two thru Six will appear tomorrow.
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