Review of Report on Leachate from Marcellus Drill Cuttings in West Virginia — Part 2

“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 Part 2 by William J. Hughes, Wetzel County Solid Waste Authority, New Martinsville, WV, July 10, 2015

(All page numbers are referenced to the PDF version of the 195 page report to the WV-DEP)

Comment TWO — Marcellus Shale is Radioactive

Good –  Wetzel County has had active Marcellus black shale exploration and drilling for at least eight years now. And finally we now have a public report that clearly, unambiguously states that Marcellus shale is radioactive. Of course, geologists have known that for many decades. But also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge that fact in public.  They sort of wanted the topic and the waste and its radioactivity to just disappear. So finally now, a formal report is out here in WV, that actually says that the black shale cuttings are radioactive. We have known that, but now we can publicly discuss it and not pretend otherwise. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be just echoing the industry’s intentional deception by declaring that “…it is only dirt and rock…”  So this report represents progress, and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.

Another very important advance is that finally after eight years of drilling we have made progress at starting to try to actually test a sample from the horizontal bore. Two years ago, the WVU WRI study researchers were never given access to any sample taken from the horizontal bore material. This was, of course, what they were supposed to have been allowed to do. But, they were only given access to study material from the vertical section of the well bore. Now, this report describes how we are getting closer to actually testing good samples of the black shale. But it seems that we have only gotten closer. Let us see how close. The devil is in the details.

Page 11/195 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1000 deviated wells (horizontal wells or wells with laterals) have been drilled in the past few years, that number represents a very small fraction of wells. It is less than .3% of the wells drilled. Even if a high quality sample was obtained it might be a challenge to extrapolate the test results. However, it seems that there is a major problem with the samples from the three wells.  And those limitations are also completely ignored in the report. Given the available documentation from the WV-DEP, this seems to be a serious flaw or at least a significant oversight.

Comment THREE—-Samples from Vertical vs Horizontal Well Bores

Flawed –  The problem is that it does NOT seem that the actual samples tested from at least two of the three wells used in the study were, in fact, from the horizontal bore material.  It was just getting closer. The sample from the third well (Wentz 1H) might have come from the horizontal bore, but just barely. I will try to show this  below  using information which was provided by Antero to WV-DEP Office of Oil & Gas. This information is in state records on Antero’s well plats which become part of the well work application and also part of the final permit.

Three wells which were included in the WV-DEP —  Marshall University report are located on Antero Well Pads in Doddridge County, WV. See the chart on report page 11 of 195:
A. The Morton 1H sample seems to be 1,044 feet short of reaching the Marcellus formation.
B. The McGee 2H sample seems to be 394 feet short of actually reaching the Marcellus.
C. The Wentz 1H sample to have just drilled into the Marcellus shale by 219 feet.

Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. The well pads where the samples were taken have between six and ten wells on the pads. The well plats are very detail-filled technical documents provided to the WV-DEP. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats give the depth of the Marcellus and the length of the lateral. The Marshall University report gives the drilling depth when the sample was taken. Using these available records from the WV-DEP it appears that on two of the wells the sample and its test results that were included in the report came from material produced when the experienced drilling operator was not yet into the shale formation.

Then, on the third well, the Wentz 1H, the numbers seem to indicate that they were just barely within the shale layer, by 219 feet.  We need to keep in mind here that the total length of the lateral or horizontal bore in these three wells, as shown on the well plats, ranges in length from 8,000 feet to 10,000 feet. It would seem prudent that if a researcher wanted to get a good sample, that waiting a few days until the drilling operation was at least 3,000 to 4,000 feet into the lateral would have guaranteed that the sample would be more accurate. That would be scientifically required if someone wanted a good sample. Consider that even on the Wentz well, at 219 feet into the shale, that given the intermingling of cuttings, both on the shaker table and separators and in the centrifuge and in the mixing tubs, material from the curved section as drilling approached reaching horizontal, could easily still be mixed with the cuttings from the true horizontal bore which would just be beginning to arrive at the surface. 

Would it not seem prudent, if one wanted a good, representative sample, to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings, returning to the surface, were in fact from the Marcellus the bore?  That would have been eminently defensible and easily accomplished by just waiting for drilling to progress for a few thousand feet further into the lateral bore.

These observations seem to address a very important limitation or possible flaw in this section of the report. It would seem that any informed scientist or geologist would go to great effort to guarantee that the sample actually came from where they said it came from and not just almost or getting close.

There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero provided information on the well plats are incorrect and not intended to be accurate, or that maybe the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.

Comment Four — The Report Gives Some Good Suggestions & Observations
 
Good — There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these are very accurate and should be implemented. For example: since the report clearly restates the fact that drill cuttings are known to contain radioactive compounds and since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the test well samples should be tested for radiological isotopes. Good idea. They are not required to do that now. This should be implemented immediately. Actually, should have and could have been implemented years ago. Pg 17/195 and 21/195.

Good  –The report also recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site waste water treatment plants should also test their effluent for radioactive isotopes. Pg.17/195. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. They will pass thru traditional waste water treatment plants.

It is also very useful that the report does recommend that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and they should now be required to also take into consideration the significantly more challenging chemical and radiological makeup of the shale product wastes.
 
Comment  FIVE  — Economic Considerations on a Gas Industry Supported Mono-fill

The WV Legislature asked that the WV-DEP evaluate the feasibility of the natural gas industry to build,  own or operated their own landfill solely for the disposal of the known radioactive wastes.  This seems to be a very reasonable approach since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of these special waste materials.

The discussion of the economic considerations is extremely complete and detailed.  They are given in Appendix  I.  They take into consideration a very thorough economic feasibility study of such a proposed endeavor. And it seems to have been done by a very talented professional team.
  
However, some of the basic assumptions seem to be a bit askew. For example, in the initial Abstract of the financial analysis, it is stated that two new landfills would be needed because we do not want to have the well operators have to drive any further than they do now. Interesting!  This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects  the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Home builders in rural settings should know they will have to incur expenses for their waste disposal needs. It seems, however, that the gas company might want the communities to provide cheap waste disposal for them.   

More than 15 pages later, the most important aspect is clearly stated that, the most salient benefit of establishing a separate landfill sited specifically to receive (radioactive) drill cuttings would be the preservation of EXISTING disposal capacity of existing landfills for future waste disposal.  (Meaning for my (our) grandchildren) See page 175/195.

Then, comprehensive and sound financial details in the report explain that having the natural gas operators build their own radioactive waste depository landfill, and then to operate it, and set aside closure funds,  would involve a lot of their capital and some risk to them. Pg. 187/195.  It is stated that their money would be better used drilling more wells, which of course would produce more waste. The conclusion then seems to be that, all around, it is  cheaper and less risky for the gas industry to just put all their waste products into our Municipal Solid Waste Landfills, and later our residents, our children and grandchildren can incur the costs and risk to build another landfill for their household garbage when needed.  
 
Comment SIX —- Omissions within the Report

1. Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do also. However, rather than raising a very large red flag and expressing concern over a problem for which no one has looked at the implication, it seems to be that therefore we should not worry about any radioactive waste anywhere because it might be in all landfills. Pg 139/195.

2. Nowhere within the radiological discussion is there any discussion of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure”. The speciation process is sort of a slice it and dice it procedure. It would then show exactly what isotopes are responsible for the activity that is being indicated. It does not seem that it has ever been done on the landfill leachate test samples. The general scanning process cannot do that. The Appendix H, pages 141-142/195, contain detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used and why.

3. A short discussion of the landfill entrance radiation monitors required by the WV-DEP is included on page 146/195.  The recently installed landfill entrance monitors are the goalpost type. Trucks will drive between them when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high energy gamma radiation.  However, what is omitted from page 144 is that the primary form of decay for radium 226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium 226 include both alpha particles and some gamma radiation. It is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings.  However those monitors are still useful since they will detect the high energy gamma radiation from a truck carrying a lot of medical waste. Pg 17/195.

4. On page 144/195 it is stated that the greatest health risk due to the presence of radium 226 is the fact that its daughter product is radon 222. Radium 226 has a half-life of 1600 years. Since radon has a half-life of only 3.8 days, it might seem to be less of a concern. What is not mentioned is that we have essentially an infinite supply of radium 226 going into our landfills now which will essentially be creating radon forever.
 
 See also: www.FrackCheckWV.net