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West Virginia Landfills to Take Marcellus Drilling Cuttings
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by Beth Little | 2011

This cannot be good for our WV waters and communities!

Drilling cuttings are the bits and pieces of “rock” that are removed from the well bore during drilling for gas. The specific contents can vary depending on the formation that the drilling goes through. For Marcellus drilling, the cuttings contain heavy metals, mineral salts, volatile organic compounds (VOCs) such as petroleum, and naturally occurring radioactive materials (NORM). There are also chemicals used in the drilling mud — shale stabilizers, dispersants/deflocculants, lubricants, spotting fluids, surfactants, defoamers, biocides, detergents, polymers, viscosifiers, pour
point reducers, emulsifiers and corrosion inhibitors — same sort of stuff listed for fracking fluids.

For many years the disposal method for drilling cuttings has been to put them in a pit, settle out the solids from the liquid (drilling brine) which is sprayed on the land, and bury the pit on site. Until recently there wasn’t even a requirement for the pit to be lined, and the gas industry fought against that requirement.

            
Wetzel County is ground zero for Marcellus gas drilling and its impacts on the community. — photos by Jim Sconyers

One of the new regulations that citizens and environmental groups want to see for Marcellus shale drilling is a requirement for removal of the drilling brine and cuttings to hazardous waste facilities. At least we thought they should qualify as hazardous waste, since they can contain arsenic, benzene, lead, and other nasties, not to mention the NORM. Unfortunately, the EPA regulations specifically exclude “drilling fluids, produced waters, and other wastes associated with the exploration, development, or production of crude oil, natural gas” from the definition of hazardous waste. Similar exclusions were created for oil and natural gas development from other federal environmental laws during the Bush administration.

WV code excludes drilling waste from the definition of solid waste, but the WV definition of “hazardous waste” would cover it, if it weren’t preempted by federal law. There are seven Class A  landfills in WV currently taking drilling waste. They are Meadowfill, S&S, Northwestern LF, Short Creek, Greenbrier Co, Sycamore, and Wetzel Co. All they need to do is apply to the DEP for a “special waste permit.” First they are supposed to get siting approval from the local SWA and hold a public hearing. There has to be a leachate analysis twice a month as part of a landfill’s NPDES permit, but it is not clear if they are testing for radioactivity, which could vary with each load.

The Greenbrier landfill was first fined for taking the cuttings without a permit, but then they got permits for the “Disposal of Special Waste” and the “Disposal of Petroleum-Contaminated Materials” and they can now take 7,400 tons of this waste per year. The leachate will go into the Greenbrier River, from which several towns downstream get their drinking water.

The Meadowfill waste facility is seeking a Certificate of Necessity from the WV PSC to build a new cell dedicated for Marcellus drilling waste, which they have already been accepting and mixing with the regular solid waste. They are also seeking a waiver to the Public Notice and public hearing. In their petition they admit that “What this drill mud consists of, and its source, is not clear” and “The addition of the drilling waste is an additional activity that is not explicitly authorized by Meadowfill’s current certificate. This additional activity will have an impact upon the public. What this impact will be cannot be predicted at this time. There is not sufficient data to form an opinion.”

A developer is proposing to build and operate a 120 acre industrial landfill to receive drilling waste about 1 mile south of Bruceton Mills, in the Little Sandy and Big Sandy watersheds of Preston County, which has generated a lot of local opposition. The Big Sandy sub-watershed was the first local area successfully restored from the impacts of abandoned mine drainage (AMD) pollution. A collaboration of partners, agencies, and individuals logged many hours and contributed millions of dollars to bring the Sandy back. A landfill of the proposed size could accommodate over 7 million tons of drilling waste.

There will be more and more of this waste as the Marcellus “play” ramps up, and they will be looking for places to put it.

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