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Seventeen damage cases for Alaska were prepared by EPA. A review of the Alaskan damage cases indicates that they mainly concentrate on outdated practices, incorrectly indicate that the outdated practices are similar to current production operations in Prudhoe Bay, grossly misinterpret quantitative data, display extreme bias in numerous speculative statements, and improperly cite references in a fashion that misleads the reader. Because the majority of the damage cases involved suspected environmental damage due to reserve pit operations, it is important to note that the Alaska Department of Environmental Conservation (ADEC) has proposed amendments to the Alaska Solid Waste Regulations that will require that Alaska Water Quality Standards be met at a distance of 50 feet from the boundary of the reserve pits that contain drilling wastes. These amendments, which are expected to be promulgated by July, 1987, should further ease any concerns for potential environmental damage resulting from the use of reserve pits.
North Slope Below are comments on the North Slope Damage cases, Detailed analysis of each damage case can be found in Attachment 8. National Petroleum Reserve, Alaska (NPRA) Sites: AK 11 - AK17 Oil and gas exploration In the NPRA, located west of Prudhoe Bay on the North Slope of Alaska, spanned a period from 1944 to 1981. Final cleanup and restoration work was performed under contract to the U. S. Geological Survey (USGS) in 1984. o v The most erraneous speculations are statements made in the damage cases directly comparing actions at the old, unattended NPRA exploration sites to current construction and operating practices in Prudhoe Bay. The implication in the damage cases are that all reserve pits are left unattended and often breach or overflow during breakup. Current exploration site practice Is to use pits that are excavated Into the permafrost for drilling fluid disposal which are covered with 2-4 feet of soil upon completion of drilling activities. The Prudhoe Bay production facilities use, and have used for years, reserve pits built during the summer months with compacted gravel, rather than in the winter with frozen, uncompactable sand, gravel, and topsoil as was the case at the NPRA sites. Prudhoe Bay pits are inspected daily to guard against overtopping of pit fluids during breakup and various fluid management techniques are employed to reduce water levels within the pits.
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The water chemistry data used in the damage cases to illustrate high levels of heavy metals and hydrocarbons around the explor^ ation sites were grossly misinterpreted. Data in the reference cited (USGS, 1986) were given in a dry weight basis (milligrams per kilograms) and the author of the damage case interchanged it with parts per million on a wet weight basis. The values stated in the damage case are overstated by as much as 1,000 times. The damage cases speculate that the sites may remain barren of vegetation for over 30 years. A review of the cited USGS reference indicated to the contrary. Areas where vegetation was killed began to repopulate naturally within 3 - 5 years of the incident and the area of impact was generally less than 1.5 acres. Misleading statements such a "vegetation kills extend out to 300 feet from the reserve pit" impair the credibility of the damage cases. The reference cited in the USGS report reads "these kills extend 200 - 300 feet, varying it in width from a few inches to as much as five feet".
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Prudhoe Bay Studies; AK 06 - AK 08 o The three studies conducted by the Fish and Wildlife Service attempt to establish that releases of various constituents from reserve pits in Prudhoe Bay have caused invertebrate diversity to decline in adjacent ponds. Furthermore, the studies speculate that the decline in Invertebrates could cause an impact on waterfowl populations in the area. The studies were flawed on several technical points. For example, nutrient levels were not measured, thus the ability of the ponds to sustain invertebrate populations is not substantiated. In another example, FWS statistics highlighted that reserve pit water was different . chemically and biologically from the control ponds. The proper comparison should have been limited to ponds adjacent to the reserve pits versus the control ponds. Lastly, in studying the responses of experimental Daphnia populations in pits and ponds, FWS acknowledged that there were alternative explanations for the findings, including natural temperature and niftrient differences. The FWS reference cited for Case Number AK 06 indicates an October 1986 date for the report. The October 1986 report has not been released by FWS for public access and therefore, it is inappropriate to use it as a damage case reference. An August 1985 draft of the referenced report was made available for review and received significant criticism for its lack of technical soundness.
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Strokensen Point Site; AK 09 o The study referenced in this damage case (USFWS, 1977) was one conducted to assess waterfowl populations in the wetlands around Storkensen Point, Alaska. Within the study area, an oil spill was discovered near an old exploration site that damaged vegetation
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and water quality In a small tundra pond. No quantitative data regarding the spill site is given, yet the USFWS author speculates on potential oil spill damage to waterfowl and wetlands caused by oil and gas production in general. Oil spills in Prudhoe Bay are cleaned up immediately upon discovery. Most spills are confined to the gravel work pads with very few even impacting tundra vegetation or water quality. North Slope Salvage, Inc. (NSSI): AK 10 o The NSSI site, in Deadhorse, Alaska, represents a past practice that was properly identified and expeditiously cleaned up to the satisfaction of EPA and the Alaska Department of Environmental Conservation (ADEC). Kenai Below are comments on the Kenai Peninsula Damage Cases, Detailed analysis of each damage case can be found in Attachment 8. The use of unlined reserve pits to dispose of muds and cuttings on the Kenai Peninsula was common practice from the mid-1950's until the early 1980*s. Although the state promulgated Solid Waste Disposal Regulations In 1972, it was ADEC policy not to require Solid Waste Disposal Permits for reserve pits from 1972 to 1981. During this time the permitting procedures of the state and federal agencies provided for the use of unlined pits as follows: o o state lands - utilized AOGCC APD's as well as approval of plan of operations from ADNR. federal lands - utilized BLM NTL's & APD Procedures. In addition, in the Kenai National Wildlife Refuge USF&WS surface, use approvals were obtained; all wetlands - utilized the Corps of Engineers Section 10 process and associated State 401 Certification;
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While utilizing the above permitting process, no incidence of environmental damage or other indication of inadequate waste disposal or violation of state or federal regulations were recorded. The agency statement on page 7 5 , second paragraph, is incorrect. Depending on permits issued by USGS (BLM), Corps of Engineers, USF&WS, AOGCC, ADNR and the City of Kenai, a number of disposal options were available to the industry for disposal of drilling wastes: o o Solids - in situ, landspreading; Liquids - annular injection, UIC Class II injection, evaporation; and
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Solids o r Liquids - permitted commercial waste disposal facility (Sterling Special Waste Site).
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The conclusion that illegal disposal activities occurred based o n t h e amount o f m a t e r i a l received a t t h e Sterling Special W a s t e Site i s also incorrect. A s stated above, the disposal options legally available t o industry were n o t limited t o disposal a t t h e Sterling Facility. F u r t h e r , the volumes o f w a s t e generation per w e l l indicated i n t h e second paragraph are significantly overstated. On page 7 6 , first full paragraph, which states "...but there i s n o w n o legal site i n Alaska t o which drillers c a n ship their muds." i n incorrect. As stated a b o v e , n o w , a s w e l l a s i n t h e p a s t , there a r e permitted disposal facilities other than t h e Sterling Special Waste Site f o r drilling a n d production wastes, e.g., Swanson River, Trading Bay, Beluga River sites a n d current state a n d federal processes provide means t o obtain permits f o r reserve pits. The o n e case i n which i t i s claimed that substantial economic a n d health damage resulted from disposal o f w a s t e s does n o t meet the Agency's required "test o f proof" c r i t e r i a . There have been n o administrative r u l i n g s ; n o court d e c i s i o n s ; a n d technical tests w h i c h m i g h t satisfy the test o f scientific investigation d o n o t reveal contamination levels i n excess o f applicable state o r federal standards. T h e suggestion made b y the agency that contamination exists a s determined b y ADEC laboratory reports i s questionable i n that ADEC results a r e reported t o show n o organics present in t h e residential w e l l s above detectable l i m i t s . A l l teats for heavy metals i n t h e residential wells showed n o suspect metals t o b e present. T h e r e i s n o direct evidence that the State o f h e a l t h o f the nearby residents h a s been affected b y activities a t the gravel p i t o n Poppy L a n e . In regard t o property v a l u e s , they c a n b e affected b y rumor a n d innuendo a s well a s b y fact.
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Beginning i n 1 9 8 1 , the ADEC decided that i n order t o dispose o f drilling wastes o n location, a n operator must obtain a State Solid Waste Disposal Permit under solid waste regulations promulgated i n 1972 principally f o r municipal waste disposal. This change i n permitting procedure applied t o state, federal a n d private lands w i t h i n the S t a t e . T h e r e f o r e , i n Southcentral Alaska from 1981 t o present, a l l new wells requiring n e w reserve pits obtained a Solid Waste Disposal Permit through ADEC, f o r example, Wolf Lake N o s . 1 a n d 2 , Funny River N o . 1 , a n d development w e l l s at Beluga River. Beginning i n 1 9 8 3 , ADEC began development o f revisions t o t h e existing regulations t o clarify t h e permitting procedure a n d requirements. These new amendments will take effect i n June, 1987. Contained within the n e w amendments a r e construction requirements, which i n a l l cases would require lined pits, monitoring requirements, closure a n d post-closure requirements, and remedial action requirements i n the event o f design f a i l u r e .
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ATTACHMENT 8
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API Detailed Corrections to EPA Damage Case Summaries (with supporting documentation)
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Description of Deration
Production Area Appalachian Basin Production Type Injection well Production Category Description of Operation The area in question is located the athe GrffffthevlBe 08 field on Beat Fork, h 1976 PennzoS was conducting a pilot project for secondary water-flood oil recovery. The W.S. May , an old oil well drilled in 1008 was being used aa a brine disposal wall in the field. Native brine contains about 70,000ppm chlorides. Information is not available as to casing size, length or condition, therefor* Ponnzotl had no way of Knowing whero the brine waa being deposited. The W. S. May 02 was used as a brine disposal *o9 during May, June, July and August ef 1978. The Mtdkxff water weft owned by Billy Dingesa is located 2000 ft from (he W. S. May 02. The well was drilled in 1065. In Septermbar 1078, the well had a five fold increase in chlorides up to 1800ppm. and presence of hydrocarbons was detected. Production (basin, mgian,ete.) (oil, gat, injection wet, etc.) (exploration, development, production, of other)
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Description of Waste and Damage

Pathway of Contamination (yea/no) Groundwater]
Damage Source Saltwater disposal well - gravity wall

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Anal Extent Waste Stream Brine
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Waste Analysis Water analysis was done on Midkrtf well and on numerous surrounding water wells. Analysis shows high chloride levels in the Midkitf well, correlated with dates of operation of W. S. May 02 as sari water disposal well. Pumping tests were also done.
(descnoe nature of available analysis, eHe key numbers I available)
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Waste Volume Approximately 28.000 fcs. of total salt Released
(barrels, gallons, etc.)
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After the W. S. May 92 began functioning as a saltwater disposal wafl, chloride levels kn tha Mldkitf wall were raised by five Umas tha background level Hydrocarbons were also present in tha water. Tha W. S. May 82 was shut down in August 1978, and after reaching a high of 1800ppm in Saptambar 1878, tha chloride lavals in the Midkitf wall began to decline. Last sample showed 275ppm In Fab. 1982. Chloride pluma had (lowed past tha water wall but was still contained in tha groundwaater. Hydrocarbons are still prasant in ths Midkitf water wall.
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'Nona Does WEst Virginia have regulations pertaining to saltwater disposal wells using gravity ? Ooes t h U , laitwatet'disposai weB have a class designationT^ 1
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Raport on probable course of contamination of a water waH near Yewkey. Unooin County, W. V., by William K. Jonas. Water analysis of Injection water and numerous water walla in area, "Groundwater and Meteoric Flusnmg of Contaminated Aquifers in West Virginia', by Benton W. Wltmoth.
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Damage Cases
FfrMS IWV02 yae I SUM WV Nearest Cfy or Town Emmons County/Parish Kanawha
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Description of Operation
Production Ana Appalachian basin Production Type OU/gaa Production Category Development Description of Operation (basin, repnaetej fog # , Injection wet, */ (exploration, development, production, or othor)
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Cabot Oil and Gaa drilled, fractured and eomplatad an unspecified number of production wag In late 1981. JtOntt, These weUa wadriflfldJnjl!oajgwinity to aeveraJjtomestic water wells. Aa a result of this activity. the.wefr^'P'^ wafrtar a\/ral rirtna^M-r>ffliwaHmnrjiT^ domestic purposes. Four (amJKefsueci Cabot Oil The case was tattled out of court tor an undisdooed amount.-
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Pathway of Contamination (yetmo) Groundwater lYes I Surf. Waterl' " I Soil I (reserve, holding or emergency pi: tank, well, battery: tpill: injection well; slowdown, etc.) (mud, brine, produced water, workever fluid. free fluid, etc.) (describe nature of available analysis, cite key numbers I available)
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Waste Stream -Grilling mud, owns, freeing fluid. (Not-speaifie
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Damsg* The wD of (our famBlas war* corttaminatadb^^nS^wiiravity. As araauit,real ostata vaJuet (orthe Dtsetiption proparties hald by tha families wara raducad an waa- agricultural productivity (rem their land.
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Oocumamation ComplaintflladIn tha circuit court of Kanawha County. W. V. CIvO action SCA-02-5183. (Had Dae 3,1882. \.jch^ ^ - f ~ - U * I > M R . t o 6 < * * ~ - w fcaclcUj&cew <iJ-<ut-jL 4/ii J^3
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Production Typo 0 8 Production Category Production
Description of Operation On October 1.1980. a storage tank on a production site owned by L&O Gaa Co. was drained Into a small creek near the home of Mr. Robert Jones. Mr. Jones had asked repeatedly that this lank containing brine not be discharged into the creek as a Bfishdownstream ware killed every time the tank was emptied into creek. Althe time of this particular discharge, all aquatic Ufa downstream from the discharge was deadîncluding aH crayfish, worms and minnows. Upstream from the discharge, aquatic fife was abundant Around 300 fish ware killed as
this was a very small stream.
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Doscriptton of Waste and Damaga

Pathway ol Contamination (yea/no) Groundwater
Damage Source Discharge of brine Into surface stream.
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Arasl Extent Waste Stream Brine.
(reserve, holding or emergency pit: tank, wet. battery; spill: injection we8; btowdown. etc.) (mud, brine, produced water, workover fluid, tree fluid, etc) (desenbe nature of available analysis, cite key numbers t available)
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Waste Analysis NA - Stream below discharge tasted very saky.*
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eras n n > cr o Anal Extent 300-400 feet Oareof October 1 , 1 M d <nw; freAMsemayD* ongoing, recently reported, ate.) (comment as neede
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=r % Damage A 2tt)-300fishware k i l t e d h a s m a l l s t r e a m w h e n a h o l d i n g tank on a p r o d u c t i o n s i t e o w n e d b y L S D . G a s Co. w a CD CD " p3j =J CO Description d i s c h a r g e d i n t o the stream. The tank c o n t a i n e d b r i n e a n d o B . The s t r e a m was p o l l u t e d w i t h c h l o r i d e s ( r e m t h e r + CD brine and had e**pil sheen. The stream had a strong ' g a s ' odor. 0 u. fa* t * l ^ r t e j l fisk .Ki'll ' * & " * ike. cks&r.ch sl\'JBtoW|H' o L t r*,-+ * COr\djjC&' a rvxopVan \4v. Couni, TV>j_
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CompBanea - W f i W t r f - d t e a n a f B O af brine and oil Into a u r f s i e i i i abeam. ' ' Issues
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Nearest Cty or Town Irelan County/Pariah Lewis II Lagta/ l IStientificAschnica l I ^ (basin, region,elc.) (oH gas, injection wt>l, et (exploration, developmen production, or other) Qmnolmye
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Inthewinterof 1984-1985. U n i o n D r i l l i n g had drilled well #2138. The c o n t e n t s o f the reserve p i t were to oe transported t o s i t e 82137 on the same lease. ( F o r d i s p o s a l I n a n o t h e r pit.) Six t o e i g h t vacuum t r u c k l o a d s o f the fluid were illegally discharged on some adjacent land. ^Several head-ef cattle were grazing in < * * e w end-*1 _,,.drank ame-ef-th-dieohwged-(lM<a\ T 3 w e e arfutt-aowa a n s H w a - e a j K > 8 - d l e d asa-CBeMtt-ofdriwhtog the reserve pa^"* P ^JfaM*. The WV Department o f Natural R e s o u r c e s were i n f o r m e d o f the s i t u a t i o n b y an a n o n y m o u s complainant /^ A t the time that tha c o m p l a i n t was filed, the Department was c o n s i d e r i n g legal action. '.,TWo * U t t ecus > > o L ' ' "WD cVatoeA w e r e Jf^wnd. <***- act "ti)* wall sHe <*"^f owe. Cow <***S -tounoL, toA ftppwinyicVtlu I V ' rvv'lc tfLauirkSTâuvt t r a m " W w . > * J i S T O . W X & N R , W M L k*SA irVi*rJL U , a * OâXurvwHiS Co*pWisrdb J U ^ ^ ?"* h * * - A n , t 4nw.. tî^rNa.olr.illiVo p r t ^ A x i - \ U w * u e r \ rvi evndUrNC* o+ t U + a l l f i a o J ^ m . Us + tU+ a l l f i a o J ^ m . Us b e e * . e a t o U - s k i * , C&riiyt request (rf tt,e i S P c W "& p''.*+- s were. 4&CA"CJL ?f. " Description of Waste and Damage Pathway ot Contamination (yet/no) Groundwate Sun". Wat
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Damage Source Reserve pit Amal Extent Waste Stream D r i U i n WcWilr1
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(describe nature of available analysis, dte key numbers If available)
Waste Volume Six to eight vacuum truckloads! U*wA>tr} Released
rt tkt
Cows **A
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(barrels, gallon
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Description of Oporatton Production Ana Appalachian Basin
Production Typa Oil/gas Production Category Production
(oM, gas, injection wet, ete.) (exploration, development, production, or other)
Descriptionof Operation On or about May 14,1980, fracturing fluid* from a production arte owned by Energy UnDmited ware discharged I n t o tha Right F o r k o f B u t t Creak. Tha fracturing fluids had bean contained i n a reserve p i t on the site. Tha p i t had been freshly bulldozed following the discharge. Over 500 fish were lulled, as p H levels were aa low aa 4.0 i n tha stream directly below the discharge.
Description of w a s t a and Damaqa Pathway or Contamination (yes/no) Ground Water
Damage Soiree Fracturing f l u i d discharge f r o m reserve pa. Anal Extant Wasta Stream Fracturing fluid add.
Surf. Wate
E\ ]
Sol! (ntorva. holding or emergency pH; tank well, battery: spiB; injection w a f f ; bbwdown, ate.) (mud.brino. produced water, workover llukl, treefluid,etc.; (descrbe natun of available analysis, cite key numbers I available)
Wasta Analysis p H analysis dona on p i t contents and stream below discharge. p H i n both p i t and stream was 4.0.
Waste Volume H A Released
3/4/S7&
wawaw
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4 / e a / Erterrt Osteal Release Duration
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n > c: o Fish k f f l e x t e n d e d over one m i l e downstream. May 14.1080. - (acres) ( release may be ongoing, recently reported, etc.; (commant as neode
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Damage Description
HumanHoati
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Over 500 f i s h were k i l l e d when h i g h l y a c i d i c f r a c t u r i n gfluidswere d i s c h a r g e d i n t o the R i g h t F o r k o f B u l l C r e e k . Rsh killed included 4 4 1 Bah Rahes, 05 Darters, 13 Suckers, and 3 Sunfmh. Acid levels in the stream were as l o w a s p H o f 4.0. u n c f r j f ^ \joiu.<*. t K t dlaoxL -ftSK, a t 4 ZohlS axj* i4 j
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Violations
State Regs. |
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dd&ma \ 5 .- c , . U- ielecîer-sr-. r ^ sAertC o* "+Uc* "T
CompBanc* 'Issues
VMM discharge o f acidic f r a c t u r i n g fluids i n t o surface vwVJo. C e A . t i j*sW. OAnv, 10 - Sh " V^ ' wWeV. - 1 1 a. Uv. Ct&t, - >SV% V % Zo - S A 6> WU A
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Documentation
WV DNR Inter-office memo documenting Energy Unlimited pollution of Right Fork o f Bull Creek. Complaint f o r d o c u m e n t i n g complaint. Rah kill report. M a y 14,1950. F i s h kill evaluation report Wva. CodU ^ I c - S A - l ^ oJu tto. .
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Description of Oparafton
Production Ana Production Typa Production Category Description of Operation Cabot O P and Gas operates a production u n i t on tha p r o p e r t y o f Inics Pearl M o r r i s . Due to construction and maintainance o f tha production unit, tha property o f Mrs. Morris has incurred significant damage due to erosion. No provision waa made for rain runoff (rom the weB road or from tha she Uses'. Mrs. Morris filed suit in civil oourt and won a settlement o f $ 1 0 0 i n c a s h and $ 2 0 0 0 w o r t h o f construction repairs to tha p r o p e r t y , to Indudo saeding and mulching of well site and embankments of well road, construction of a cross drain 8 8 bottom o f weB road to collect r u n - o f f and a d r a i n pipe to c a r r y water to drainage ditch along m a i n road, 4 0 t e n s o f stone laid on well read to inhibit erosion during rain storms, and a cross ditch constructed at top of well road to collect run-otf from well site. TV*. C<H*<* W W M M . *
Co-A<Je> PftO^vMlt CbvM&
Appalachian Basin Oll/gao Production
(basin, ragian,eec) (oH gas. Injection wet, ate.) (exploration, development, production, or other)
f:
Dascrlptlon of Waste and Damaga

Pathway of Contamination (yesmo) Ground Water Damage Source Erosion from well site and wed road Anal Extent
:
Surf. Wate
ri \**Fn
(nserve. holding or emergency pit: tank. weB, battery; spill; injection weB; bbwdown. etc) (mud, brine, produced water, workoverthud. frac fluid, etc) (describe natun of available . analysis, cite key numbers J available)
Waste Stream NA
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Waste Analysis N A
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Waste volume NA Released
(barrels, gallons, ate)
3/4/87&
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At* or* Ongoing Rebasa

Duration Ongoing
(rahasemayba ongoing, ncwmly reported, arc.; (comment as n*adea; Faun* I I A n lYes I HumanHatHh I "~l
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Dtmsg* Significant damage from erosion of Cbot Oil and Gas production she on property of (nice Pearl Morris. Description > .V
rt
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Violations Stat* Rags,
CompEanea *tawo-Na-raquiremewta fat1 construction cfwBroada<iniifpredt>atonilaa'lwWwi Viîwici * -
(0-No UYas) at time ofoamaga
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Cbeumanfatton ORDER for settlement of ctvB suit 084-2478. (Dad in United Stataa District Court. Southern District of Wast Virginia. July 31.1886. Charleston Division. 0k \*uGJL o . &*~JL~O, -c&*-ck.
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Pmduction Area Appalachian Basin PtvducdonType O H Production Category Production (basin, ngion.ate.) (e4 gas. faction we*. .) (exploration, development production, or otter)
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Description oi Operation The Devon Corporation operates an o production unit on tha property of Mr. Fronch Curmmflham. on August H 21 1970 anXnptoyaa cfthe company drained two (aat from holding tank U the production alto. The tank contained oil. drilling datargani and safcwatar^MrCunnlnflham had askad the employ*" nottodischarge the a ô^rXrlSadSW; bulirSTeo^fweYiglSrediAa a re.ul of tha discharge. 100-150 mwrww. were killed. This case was referredtorprosecution. Mcte4oltow*p^kwvimf-v^ <3* o. **+BX. .
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Surf. WaferjTeT] &*[7"~| (rasarva. holding or Damage Source Discharge from holding tank on oil production unit emergency pi; tank, wall, battary: spill; Area! injection well; Extant btawdown, etc) (mud, brine. Waste Stream OH. drilling datergant((oam is used for drilling lubrication In WV. Often oorrtein* produced water, detergent), salt weter(brine). workoverlktid, irac fluid, ate.) Wasta Analysis NA (detcnbe nature of available analysis, da key numbers I available)
Pathway o/Contamwatbff
frae/noj
, Ground Waterf
1 m
}$.
(barrels, gallons, etc)
3/4/874
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n c > Dateof 5ugut 2 1 , 1 0 7 0 1 (nbasemaybe ongoing, recently feponed, etc} (comment as needea, fiMia o
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Duration
Last than an hour <y&*io;
i 1 2, S" 2. II. CD Q_
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Affected Biota
43
Damage Description
100-150 minnow* wara killad whan a holding tank wa discharged onto a maadow Tha tank containad oil, dnlir" 3 datargant and aaitwalar or brine .
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flora
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Violations State Regs. I Compliance
11 (0-Ato r>Vas;time of damage
^WiWtri-dmecjard-o^-BtBta-fwJaa concafwiog cttcnaiq-oro<tpfoductMw' waster diacha^^ôtfpwiductterHwastgf
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Documentation WV DNR complaint form, Scot 24,1878. WV DNR Inter-offlea mamorandum describing Devon Corp. diicharga eaaa^ta^9^|-7, ^ *|l*|^ *r>fa . ^ I t t t a UWOLCC)UI * 1 0 - ^ A " ^
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WV
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Production Ana Production Typo Production Category Appalachian Basin Oil/gas Development (baaht, ngbn,etc)
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(oH gas, injection wei, ate.) (exploration, development, production, or other)
Description of Operation ??j^Sk>JUt~ In early 1986 Tower Drilling land applied the contents of/reserve pa to an area 100ft. by 150ft. All vegetation sVfefcSeA. *e#Tn area where pit osntenu ware directly applied anoeaii?trea8 adjacent ot land application area were dying. Complaint was made by Bob Starcher of Mt Zion, West Virginia. MQ cU(Lw3feA> te^cO******* -e** rvLoîUA. eAuvA* "** C**OB. op A c * - ^ e t eUjjyv^ " b * * ^ * * * & 8 * < J ^
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Description of Wasta and Damage

Pathway of Contamination (yaa/no)
Ground Water
Damage Source Land application of reserve pit fluids. (Drying Anal Extant
en
Surf. Mfeftfj
"J Sof|Ye
'[
(reserve, holding or emergency pit: tank, wet. battery; spill: injection well: bbwdown, etc) (mud, brine, produced water, workover fluid, free fluid, etc) (describe nature of available analysis, cite key numbers If available)
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Waste Stream
Drilling <aud.
EBAJU
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Wasta Analysis Analysis was done orâected-tr?Dlssolved Oxygen.7.0mg/1. specific conductance43,000umhos/cm, and ehbrid18,0O0pom.
4V
(barrels, gallons, etc)
3/4/B7&
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Area! Extent 100ft by I50ftpiu some urrouodlog Bra* duotobashing. Oafao/ May-Juna 1986 Rabat* ... .. Duration Savaral hours Affected Biota (yaa/no) Fauna I I Fbta |Ye ] Hunan Health I l
(ton) ( rottasa may br ongoing, recently reported, arc. J (oommant at neeaeai
; n c o <n oz > to
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Damage VegatWiorpttited In er aawhere drillingfluidswars land fanned. Land farmed drBPng fluid eomairwd vary high Daschption chloride Isvels, and*w?nas 18,000ppm chloride. Tree* in surrounding was beginning to die m IT Joa.j.hmg it^* hiehjcfatoodagA' prt CartVeJwS
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Mo/af/ons Star* Rag*.
Compliance Nona - ft is legaltoland farm drillingfluidin VW with ehtorida levels aa high as 2S,000ppm! DNR is trying to cut * * Issues partniled level in half to 12,000pph. -.
(0>rVo UVes; 0 tima of damage
3
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Oocumantarion WVDNR oomplaimtorm6rt 31/88. Analyticalreporton ofraraJyai7af kfll area. ft~^r-a- _,
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Dmcrtplton of Operation Production Arts Appalachian Batin Production Type 09 Production Category Production Description of Operation ( n 1983, Alias Energy d r f l l a d an o3 w a n on tha property o f Charles Abbott, labeled tha A b b o t t 01. The wel craatad a aariaa o f problams immediately upon completion. I t blew out, leaked o B i n t o naarby springs,and tho oparator allowad o i l to stand I n thraa saparata pita. Tho w a l l waa than racasad and tha o i l f l o w into tha spring ttopped. I n Jury o f 1984. o i l started f l o w i n g again f r o m tha spring below tho production aits. A complaint was mado, but follow-up documentation a not availabel. Suck. cVr-, .1-nTaft-m-, a ^BoJ>v-o <oV^d. v * * C j z a a i , o - X J . u ^ teAMM o w 3**fiH \^r\r t o S U A Vit?,_i (buin, ngiouetc)
(oU gas, injection weS, tie (exploration, development production, or other)
Description of Wasta and Damaga Pathway of Contamination (yes/no) Groundwate

M
Damage Source Leaking casing on oil wall. Araa/ Extent Waste Stream O U
ED
S u n * . MfeforfTaa rmfTaa * * ! 1
(reserve, holding o emergency ok; tan weft battery; spM; injection weB; bbmrdotm, etc) (mud, brine, produced water, workovw fkiid. frac fluid, etc) (describe nature of available analysis, cite key numbers I available)
Wasta Analysis NA
Q 39
1
:t": : i t '- ''
I', -
(barrels, gallon etc.)
3/4/87&
*ss
mmssmmoa
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DgMof Summer. 1084 Duration NA Atfctd Biota (yea/ho) Fauna ffcni [Y5i j Human Health I (/teat* may t ongoing, ntcantty reported, etc) (comment MM needed
40
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Oarnap* Contamination of fraah w i m y r i n q hy infl.n. ^ ^ ^ ^ fmmtwWnfl arming of urorfmiinn unii )Q fern awTP" Description o-vo^ v>*s^jttoL/s/wCw^Jt Oo-u-rutiL* . *"" j
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Vtofrtfen* State flee*. r~""T3| (OmNolmYu)attimmofdsmMg* CompSanea Nona? UnwiUingnM on part of operator to ramaoy prebtom. Itsutt . . . -fit *~*<J>Â op o-JL - ^ o fl^^_ o-o , . . -lt-b*ja. * . . . . o ^ i f c u * ,
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Ooeumenfarion Complaint form from WV DNR M/B/B5. DMft. <, ^-3A-i<\, C^v^-^^c^JT^ Ho c ^ j u a
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County/Pariah II Laps/ I
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Description of Oparaikm Production Ana Production Typo Production Category Description of Operation On September t, 1983, M R L Inc. (also known aa Hoffman O H and Q u ) , began drilling a production wed. A pit was dug to be used f o r drilling fluids. On the same day, the W V Department o f Natural Resources inspected tha she and noticed that the pit to be used for drilling fluids wasfillingup with groundwater indicating that fluid to be placed in the pit would be allowed to migrate Into the groundwater and a stream 0 feet away H the pit was not lined with an impermeable liner. The operator staled that the drfiling mud would seal tha pfi. On September 13, s k i l l o f over 400 fish was documented by DNR field officers immediately adjacent to the M R L drilling s t o . Stream samples and photographs ware taken. Appalachian Basin Oil/gas Development (basin, ngon,Btc) etc)
3 c+ =r = m
(oil, gas, injection wet,
(exploration, development, production, or other)

Pathway of Contamination (yes/no) Ground Watar I Yes I Surf. Wafer I Yes I Soil (rasarva, holding or omargancy pit: tank, watt, battery; spill: injection well: bhwdown, etc) (mud. brine, produced water, workover fluid, Irac fluid, etc.) (describe nature of available analysis, cite key numbers available)
Damage Source Untined, leaking reserve pit . Anal Extant t";v! Waste Stnam Drilling fluid
Wasta Analysis W a t e r samples were taken. L a b analysis not I n file.
[ft*
Waste Volume Released
Approximately 100 gallons
(panels, gallons, etc.)
3/4/87&
Is,. Is
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Anal Extant NA Oaro/ Sept 2-13, WSReieato Duration About tan days Altecttd Biota fyetAv) Fauna |Va I flora Human Health
Macrae; (mhas* may ba onoojnj, recently reponed, etc.) (comment as needed)
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Oamap* 426 fish wara killad as a raauft of ttia migration of drilling fluid* Into tt Riatit Fork at F,,w. r u _ * * . Minnow,. 60 Dartar. and 3 Sudc.ra. Yh. v.rua of J K . i G S ^ ^ ^ S S ? '" Magffly probl.m wa. daarly viaiblo bafora drilling commancad. MRU he. wa htuld u ^ T ^ S l Magistral. Court of Plaa.anta County wh.ra tha company pl.adadguifty t o e h 5 5 l S S ^ T w * . R.sourcoa Board regulation which raquir.sthdrilling pftibaconatruSed i n ^ S ^ S ! S ^ S S , y aaepage. ^h company plaadsd guilty and was fined S2M. ^
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(exploration, development, production, or other)
On August 11,1980, fracturing fluid from the waste pH of the J. A. Read 02 ownad by R. V. Johnson was allowed to escape into the Big Run ot Leading Croak through a hosa strung ovsr thatowerside of tha pit The wall had Just baan fractured using 1000 gallons ot acid and pH in tha stream was lass than 4.0. 500 be. of lima had baan added to the pit to neutralize the acid, but was not an adequate amount. Over 150 fish were killed as a result of exposure to the acid in the stream.
Description of Waste and Damaga

Pathway of Contamination
(yes/no) Groundwater
Damage Source Reserve pit- fracturing fluid. Amal Extent
Surf. Water
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Waste Stream tracing fluid-add
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Waste Analysis pH of stream immediately below discharge from pit was less than 4.0.
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Waste Volume 1000 gallons of add <sw &OV*W*M3CL0_ Released p c . . . V t l O~JL Soe> t>ov.,.Â , r
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Duration aeveraJ hours Mfactad Biota (yWno)
Damage Over 150 minnow* and darters want killed whan (racingfluidw u discharged (rem a rasarva oft H in ih. . . Dascnpvon immediately below the discharge was lass than 4.0.
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CompSanoa VWifu) disiagairi-of-etiiteTwottteftena-preMt^ditcharqe of reserved fluid directly into aurfaca straam Ittun t w o-. o^fl-ato*^ of U N c W fc,- SA- l\ *~fc. 3*-**. O-^JU ' * . ^ M - A . OAjÂjJ^^ ^ J J W d^J^&~-*XA 4b fee*- dJUA^.^
Documentation JSSft" 0 ^ jr em0r*!)?!J.T W N ' 0 N R tocumantino straam pollution by a V. JohnsonOD Company. August 19. i 0
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nun r Y J ? ^ ' " Rewurcas Sampler's Report documenting low pH e< dlscharga from rasarva pit. wv DNH rishKJI Report Information formtorrequest for Warrant, August 11,1980. WAS THIS CASEJAKEN TO C O U R T S . W e . C o * %to-Sr\-\^<*^. Zo -SA-l^cw **
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Production Area Production Typo Production Category Appalachian Basin Gas Ocvalopmant (basin, region.etc.)
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(03, gas, injection ww*. ate.) (exploration, development, production, or other)
Description of Operation In 1982 Kaisar Qas Co. drillad a gas wall on the property of Mr. Jamas Parsons. The wall was fractured using a typical fracturing fluid or gal. Tha residual fracturing fluid migrated Into Mr. Person's water well, drilled to a depth of 416ft (The gas wall is located less than 1000 ft. from the water well.) By 1884, the watar wall was unfit for domestic use and an alternate source of water had to be found.
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Description of Waste and Oamsga

Pathway of Contamination Damage Source gas wed Anal Extent Waste Stream fracturing fluid or gel (yea/ho) Ground Water WiT Surf. Water r\
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(reserve, holding or emergency pit; tank. weB, battery; spill; injection weB; slowdown, etc) (mud, brine, produced water, workover fluid, Irac fluid, etc.) (describe nature of available analysis, cite key numbers I available) '
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Waste Analysis Well watar was analyzed and found to contain high levels of fluoride, sodium, iron, manganese. Tha water had a hydrocarbon odor indicating the presence of gas. Dark and light gelatinous material (fracturing fluid), w a s found along with white fibers.
NA
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Area/Extent NA Oafeof 1982 Rebate Duration Approximately 12 noma '
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Damage Whan f r a c t u r i n g the K a i s s r gas w a d o n Mr. Jamas Parson's p r o p e r t y , fractures wera c r e a t e d a l l o w i n g m i g r a ici+ n o Description o f fracture fluid f r o m the gas wail t o M r . P a r s o n ' s w a t e r well. This fracture fluid, a l o n g w i t h n a t u r a l g a s w a s present in Mr. Parson's water rendering tl unusable. The contamination has sines passed t h r o u g h the water wa but i s still contained in the groundwater.
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Violations State Rega. j
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Compliance No a p p a r a n t c o m p l i a n c e i s s u e s n o l a w s d i c t a t i n g p r o x i m i t y o f oil a n d gas wellstowater wells notnaximum Itauaa pressure dictated for fracturing oil and gas walls. w <*" ff-**'8'* "****- * - * * u * "to Lt. 6 t X 3 f f w M * & * UABLA^ "povâ* > TUma, ^c-fvw*, C f t ' < . * ^ l
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Three lab r e p o r t s c o n t a i n i n g a n a l u s i a o f water wed. Latter f r o m J. Rosertcrance, Environmental Health Services Lab. to P. E. Merrill, Sanitarian, J a c k s o n County. Letter f r o m P. R . M e r r i t t t o J. E. R o s e n c r a n c e requesting analysis. Latter from M. W. Lewis, Office o f Oil a n d Qaa t o Jamas P a r s o n s stating state c a n n o t n a i o in recovering expenses must file dvS suit Water well inspection report complaint. Sample report forms.
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Production Type Gaa Production Category Description of Operation ^r*x

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Production
\^1 8 J ) Allegheny Land and Mineral Company of Watt Virginia operate^ a gas wefl 9A-226 on the property of Ray and C h a r l o t t e W i l l e y . The well it located i n a com f i e l d where cattle are fed i n winter. A d j a c e n t to the w e U is a ttream known as the Beverfin Fork. The weD is located l e u than 1000 feet from the Wiley's residence. Allegheny Land and Mineral alto operates another gas wsQ above the residence known aa the SA-306, located on property owned by the Willeys. Allegheny Land and Mineral haa maintained open reserve pita and a waste ditch running into Beverfin Fork. The ditch has served to dispose of brine, oil, drip gas, detergents, fracturing fluids and ' produced chemicals. Employees of the company told the Willeys that fluids in the pit ware safe for their, livestock to drink. T U . u n U e n S rvV*fcVi*edis aUowedL t U s n - t o l t l s , " f ^ dLmK

Pathway of Contamination (yes/no) Groundwater
Damage Source Reserve pit, waste ditch, g a s weS Area! Extent Waste Stream
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Surf. Wafer
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(reserve, holding or emergency pit: tank, well, battery; spill; injection weft
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Mud, brine, freeing fluid, detergent!, drip gas, operating chemicals and wastes.
(mud, brine, produced water, workover fluid, free fluid, etc) (describe nature Of available analysis, die key numbers i available)
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Waste Analysis Water analysis was done on fluid from a waste holding tank on the production she. Chlorides o f 360,000ppm were found, phenols o f J Z p p m were detected, sodium 59,000ppm, aluminum 2 mg/1, barium 7mg/1. Iron 1S0mg/1. Complete analysis in file.
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(acns) Dttoaf Reietme Duration NA NA ( (reie&semaybe ongoing, recently reported, etc.; (commons as noeded)
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pSi~~j Fbra Affected Biota (yea/no) Fauna Damage The Willey's cattle drank the fluid in the reserve pVb'esaWpfflaooad^^ Description tot.mntaminata4^w&t-afld-deUv4ioq'a'wargalsoprtîtiiKf7wro6wg4n4Mî!Hy-ttroW>totrtfiufdMjpmaJ^'
Src*MKfwa|-e^*<an^8fa4^m4^^ -watar-aupslfr Tha value of the real estate was diminished as a result of these damages to tha land. Vb&nm' 4cwwod43bofBtiy-jqmsasJoJMa^îB^ Tha Willays were awarded a cash settlement in court of a total of <53088-*a 4 3H , p&* wCta***!* <w<^, &&&, , TKss,
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Violations State Regs. I
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_ GompTianca Soma of tha activities of Allegheny, Land and Mineral ware In violation el West Virginia statutes. Some were noi. _ Issue* Unclear as to specifics. ' '
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Description of Operation Production Area Appalachian Bas Production Type Oil/gas Production Category Development Description of Operation {basin, regkxt.etc) (ail, gas, injection v#, ate.J (exploration, davalopma production, or other) ittt
On Wednesday evening, November 9,AMr. Clarence Rinn returned to his residence and found that the water coming from his kitchen tap was chocolate brown in color. After soma investigation, it was discovered that Beacon Resources was drilling an oil well above the residence o( Mr. Rinn. Drilling m u d and cuttings ware (lowing into the creak (rem a ledge 20 (eat abova the Rinn residence. Upon inspection o f the drilling location it was ascertained that surface casing had not yet been sat Drilling mud was escaping into the greundwatar and llowing into the stream. Tha Rinns ware supplied with drinking water b y Atlas Energy, but were advised that they would have to sue to have a new water well drilled.
Description of Waste and Damag* Pathway of Contamination (yea/no) Ground Wa Surf. Wat Sol
Damage Source Drillingrig-drillingmud and cutting Anal Extent Waste Stream Drilling mud
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(reserve, holding o emergency pit; tan well, battery; spill injection well; blowdown. etc.) (mud, brine, produced water, workoverfluid, free fluid, ate.) (describe nature of available analysis, cite key numbers U available)
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Waste Volum NA Released
(barrels, gallon etc.)
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NA I November 9 , 1 9 0 3
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Approximately 2 4 hours (yea/no) Fauna
Affected Biota Damage Description
Contamination of residential water well with drilling mud and cuttings from drilling site above property. Surfaca casing not in place allowing migration of drilling mud and cuttings into surface fresh water aquifer.
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Violation* State flags. I CompBanc* ' Issue* \l ( " O - A t o UYes) at timo at damage
Willingness o f oil and gas operators to follow state regulations concerning p r o t e c t a n t surface fresh water aquifers. '
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Description of Operation On February 23.1983. a complaint was filed by Tom Ancona, a fur trapper, concerning a fish kill on Stillwall Creek. Another complaint was also filod anonymously by an employed of Marietta Royalty Co. A trail of dead fish, frogs and salamanders was followed up to a drilling site operated by Marietta Royalty Co. A syphon hose was found draining the drilling waste pit into a tributary of Stillwell Creak. Acid levels at the pit were a pH of 4, enough to shock and kill aquatic life according to WV District Fisheries Biologist Scott Morrison. Samples and photographs were taken. Above the syphon site no dead aquatic life was found. Marietta Royalty Co. was taken to court, and was fined a total of $1000 and $30 in court costs.
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(yes/no)
Ground Water
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Damage Source Syphon hose draining drilling pit waste into surface stream killing fish, frogs and salamanders. Aroal Extent
Surf. Water
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Waste Stream
Drilling mud and waste.
Waste Analysis Analysis done on pH. pH4.
7ABO gallons (estimated by WVDNR).
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February 1983 NA (y as/no) Fauna Yes" flbra Human Health
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Drilling mud and wasta was discharged into Stillwall Creek through a siphon hosa from a drilling mud pit. Several hundred fish, frogs and salamanders ware killed due to the release which had a pH level of 4.
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Violations Stata Rags, j
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CompEanee - Willful disregard at state regulations eowearning discharge of drilling ait fluids and waste by oil and g a * Issuaa operators,4* rÂjvoJ2-a3b-iv. jvoJ -^**OrfWk*<*cCL. J U * e & - r\B-AiA>C
Documentation
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Complaint Form 86/170/83, WVONR, 2/25/83.WVONR Incidant reporting shaet, Feb. 28,1983. Sketches ol Mariana drilling site. Complaint for Summons or Warrant, March 28,1983. Summons to Appear, March 18.1932 Mariana Royalty Prosecution Report, WV Deportment of Natural Resources. Inter-office memorandum, spill investigation details. Marietta Royalty,
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... . . .,__. _ _ . , . Co. drillod and began H . , i i i j M WBI , adjacent In May 1980,, the Stonsstreet Lands w . M1 ,_^ l w ^ro^,,, Uoperatingaaygas~wcll ad?a to the property ot Harry and Dons Tanner. Provisions were not made to prevent erosion on the new production site, and the Tannors sustained significant damage to their house and property due to Hooding and surface runoH. This flooding and runoff was not a problem prior to the preparation of the new drilling she. The lack of erosion control was in violation of Regulation 23.03 and 23.04 of Chapter 22 Article 4 of the West Virginia Code. TLu**, fltCq^,-. Afrc ^-e*->, ^**iSo^. o^ptc - ^ C M . uâ, <a< tJCa,^. &A. ef
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Pathway of Contamination (yet/no) Ground Water\ J Surf. W a f / | 7 e i I Soil Yes I (reserve, holding or emergency pit; tank, well, battery; spill: injection well; blowdown, etc.) (mud, brine, produced water, workover fluid, frac fluid, etc.) (describe nature of available analysis, cite key numbers i available)
Damage SoureeÛncontrolled erosion and subsequent flooding resulting from improperly prepared drilling site. Area! Extent Waste Stream Rood waters and mud
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Data of Release Duration
Ongoing (yet/no)
Affected Biota
Damage The Tanners' house, yard and outbuildings sustained (bod and mud damage due to uncontrolled erosion Irc.-n Description the adjacent gas drilling site operated by Stonestreet Landa, Co. Tha garden was washed out. The crawl space and cellar ware full oi mud and slime requiring an application of lima and slerilizaion of tha area. The lawn was washed away requiring new topsoil, resaeding and fertilizing. Tho crawl space required dehumiditying to prever: floor and floor joiat mildew. The total dollar value of damages sustained was $1670. J
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I I (0-No 1m Yes) at time of damage
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CompSane* (Unwillingness to follow regulations concerning proper terracing and construction of drilling she, making area -- - Issues t \ v u ' Vulnerable to uncontrolled- erosion and flooding. This case was settled out of court for S5.500.. . .
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Documentation Complaint filed in circuil court of Clay County, West Virginia, Harry Arnold Tanner and doris Lorene Tanner vs. Stonestreet Lands, Co., #81-C-89, Estimate from Samples Building Supph/ on cost to repair damages to house and yard, dated 8-16-81. Answer filed in circuit court of Clay county, #81-0-89. Letter to Ben Snyder, attorney (or Tanners, from Gerald Thus, attorney for Stonestreet Lands, discussing settlement of case out of court lor $5,500. Order filed in circuit court ot Clay county tor case to be settled as agreed, H81-C-89.
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Stare Nearest City or Town
WV GandeeviUe Roane I I 0no -yas
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Production Area Production Typo Production Category Appalachian Basin Oil/gas Development (baain, ngbn.ats.)
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(oil, gas, injection wet, ate) (exploration, development
production, or other)
Description of Operation In January-March 1985, Allegheny and Western Energy Corporation undertook drilling activity on the Whrted Lease, nearGandeoville. Drilling sites were not properly constructed so as to prevent erosion and sedimentation of nearby streams. Lakin Ryan, a resident farmer filed a complaint when he noticed that the drilling activity was causing pollution to RocKlick Run of Trace Fork. The West Virginia DNR submitted the case for prosecution. T h e company was^riginally lined 1 1 0 , 0 0 0 , but p l o f O n i gained the anwmwHtawB-te $ 2 5 0 0 . Was site ever reclaimed? *t)/ .01^^ ("
y
Pathway of Contamination (yes/no) Ground Wateri | Surt. WaterlYes I Soil Yes I (reserve, holding or emergency pit; tank, *" battery; spill; injection well; blowoown, etc.) (mud, brine, produced water, workover fluid, trac fluid, etc.) (describe nature of available analysis, cite key numbers i available)
Damage Source Erosion and sedimentation of straams due to improperly constructed and maintained drilling site. /tnal Extant Waste Stream Mud and sedimentation.
Wasta Analysis NA
NA
3/4/B7&
Anal Extant NA
(acns)
I
Data of January-March 1985. Releasa Duration 3 months. n) fyo&no) Fauna j | fbw | | Human Haatth
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( rakaaa may be ongoing, recently reported, ale.) (comment as needed
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Affected Biota
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OamaM Due lo impropar site preparation and maintainance of oil and gas development well, Rccklick Run ol Trace For* n J a S J w u polluted with mud and sediment from resultant erosion of drlltoto. Three natural drainage areas were obstructed and no alternate path of drainage was provided. The company failed to maintain integrity o a drilling pit allowing for leakage of drilling mud from the site into the nearby stream. Timber and brush cleared for construction of an access road into the drilUite wa put in a stream, thus impeding its flow.
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Violation* Stato flags. | Compfianea iMttaa
H (O-No UYaa) at ttma oi damage
WiHkil diere9e3Aof state regulations regarding proper construction and maintainance of drilling sites so as to^ minimize erosion and stream sedimentation. * -t ' /tH^v>A) ^JU^*JL IM^t fc**ft-
Documentation
Prosecution report. WV DNR documenting sequence of events in case. Six separate compaints for summons : warrant filed with the magistrate court of Roan, county. WV. Plea bargain filed ^ m s g . s t t e u ^ R o a r e lre county WV. detailing plea bargain agreement and a a n l a m e m o i c a a a j t o r j k n e o j i ^ " -^FSSSiSo^m^SSii w V ^ N R i a l l n g T n i n a H ^ h i n y and Western w u to be fined .10.000 for peno^r charges.
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Damage Casos
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Description of Operation Production Area Appalachian Basin Production Type Oil/gas Production Category Description ol Operation In September 1983, Alan Gable Oil Development was drilling In Wirt county when a DNR inspector paid a visit to the location. It was found that the reserve pits were overflowing and it was requested that the pits be pumped down and tha fluid takan to an appropriate site. The operator stated that the liquid wasn't going anywhere and was thus unconcerned about the integrity of ths pit. A pump truck was called for, pumped the pit and left location with the inspector following so as to determine where the pit wastes were baing dumped. The driver pulled over and waited for tha inspector to leave. The next day, a long string of casing was being cemented and the pits were again overflowing with cement, oil and other wastes. Warrants ware than signed for the arrest of the operator. Development (bMi'n, reghn.etc) (oil, gas, injection woB, etc) (exploration, development, production, or other)
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Description of Waste and Damaga Pathway of Contamination (yes/no) Ground Water Surf. WtoarFYes SoJtY (reserve, holding or emergency pit; tank, well, battery; spill; injection well; bbwdown, etc) (mud, brine, produced water, workover fluid, trac fluid, etc) (describe natureof available analysis, cite key numbers 9 available)
Damage Source Leaking and overflowing reserve pits. Area! Extent Waste Stream
.'y.'S
Drilling mud, eamerrt, oil.
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Waste Analysis NA
If
##
Waste Volume NA Released (barrels, gallons, etc.)
3/4/87&
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Dart of ftetease Duration
NA
I
September 1983
(aentt)
( release may be ongoing, recently reported, etc.) (comment at needed!
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Several weeks. (yea/no) Fauna Flora Human Health
'/
Ground under and around the drill tile was contaminated with drilling fluid, oil and camonl
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"".Mi Violation* State flags. I
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Compliance /ssuas
Mnwilliiiynau en uail u( '< and gaa aperatonfradhare'taâtata regulationa concerning conatruction and maintainanca of drilling mud pita in order to Insure that Integrity is maintained and pita do not overflow.
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Oocumamafllon
Proaacutlon Report WV DNR. Octobar 19,1883. Warrant for Arrset, Alan Gable Oil Development. M3-M-185. Complaint for Summons or Warrant, Alan Gable Oil.
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Description of Operation On June 3,1933, W V DNR inspectors noticed a n unusually grey and turbid condition in a small straam. Thay followed tha straam up to a drillsite operatad by L&M Producing Company. T h e reserve p i t was leaking and p i t sludge deposits were noted o n downslope flats from the she. Sludge was up to 0 inches d e e p . Photos a n d samples ware taken. There also existed a previous mud pit site which had not been reclaimed. The company was charged with active discharge of reserve pit.

Pathway of Contamination (yes/no) Groundwater Suit. Water I Yes
I Soil
I
(reserve, holding or emergency pit; tank, well, battery; spill; injection well; bhwdown, etc.) (mud. brine, produced water, workover fluid, frac fluid, etc.) (describe nature of available analysis, cite key numbers H available)
Damage Sourea Leaking reserve pit. Araal Extent Waste Stream Drilling mud.
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Waste Analysis Analysis was done o n pit fluid and affected stream fluid, but data not in file.
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Araal Extant NA Dare of" June, 1983 ReJaas* Duration NA Atfaciad Biota (ya*/no) Fauna
(ens) ( nlaasa may ba ongoing, racantty reported, ate.) (comment as naaaed>
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Damaga A stream which Is part ot the Bull Creek headwaters was polluted with drilling mod from a leaking reserve oil T*e Dascnpton area around tha driltsite was eontaminatad with drilling pa sludge up to sight Jnchas daep.
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ok***, <r.lM Oocum.nralfen WV DNR prosecution report. Jury 11,1983. VW DNR Indd.nt reporting sheet. June 3. 1983. Complaint tor Summons or Warrant. L&M Producing Company. Summons to appear in magistrate court of Pleasants county WV, June 15,1083. <x~-<jt -tJLfieJ2 ûu3
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Damage Cases
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Description of Oparatlon
Production Area Production Type Production Category Appalachian Basin Oil/gas Development (%*(, region,etc) (oil, gas, injection woE, etc) (exploration, development, production, or other)
Description of Operation O n Decambar 1 2 , 1 9 8 4 during a routine inspection by W V D N R , a drill sits operated by Magnum O U was found to contain an illegal reserve pit from which drilling fluid had been spilled onto the ground around tha pit. Latar, after complaints w e r e filed concerning the same drilling site, ii w a s found that t h a drilling pits had overflowed and were also seeping into a nearby stream. T h e stream was f u O o f drilling foam and detergents from tha pit seepage. The company wanted to landfarm the pit contents but were denied permission from DNR. The pit contents were land applied anyway. D N R brought tha case to tha magistrate court o f Braxton County. Gettlemant is nat fewwf in the f ' l e . f .

Pathway of Contamination (yes/no) Ground Water
Damage Source Overflowing and seeping reserve pits. Anal Extent Waste Stream Drilling foam and detergent
Surf. Water
rn rn
(reserve, holding or emergency pit: tank, well, battery; spill: injection well; bhwdown, etc.) (mud, brine, produced water, workover fluid, free fluid, etc.) (describe nature oi available analysis, cite key numbers i available)
Waste Analysis Water analysis was done on the pit and the affected stream, but data not in file.
NA
(barrels, gallo etc.)
3/4/87&
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Area! Extent NA Defeat Release Duration Sevarai weeks. Flora December 1984. I (acres) ( release may be ongoing, recently reponed, etc.) (comment at needed) Human Health
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Affected Biota (yet/no) Fount Damage Due to seeping and overflow from reserve pit, noarby stream was polluted with drilling team and determ scnotnn MaanumwMinod J2S00. ^ <rgiant. Description Magnum was lined S250O
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Violations State Regt.
CompEanee Qtt-and gas oparatnr nnwillinato comply with state rules and regulatiens concerning construction and ' Issues malmainanc* of reserve pita. > h e n permission to landfarm Wot denied, operator bmdlarmed the pit contents " anyway, -iiiimirimniii thm fT , 1IT p^.p <ffi - fMt8 ^ s , f , 1| ( \nmefa ICTIHI ami-rounding ahallaw atmjndwsituroi.
(0-No UYea) attimeor" damage
I
I
Documentation
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0**' e^~ VWDNRreponotinvesilgation,Jan.16.1985. WV DNR Industrial Waste Facility Inspection Report Dec 12 1884. Summons to appear, magistrate court or Braxton County. 84-M.S67. WV DNR Complaint form. Dec. 20 1984. Interoffice memorandum and telephone sheets discussing cose. WV Oil and Qea Division construction ' and reclamation plan and permit for Magnum Oil. Nov. 14,1984. "Tkju^-
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Damage Cases i
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Region Proof Category 2 Administrative State Nearest City or Town County/Parish WV Munday Wirt
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Production Arva Production Type Production Category Appalachian Basin Ofl Development
0oo 7yes
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(baj/n, ngion.etc.) (oil gat, injection wet, etc)
(exploration, development production, or other)
Description of Operation On December 1 4 , 1 9 8 3 , it was discovered by W V DNR inspectors that two reserve pits on the Scott 05 drilling she operated by Atlas Energy had been breached and the contents had polluted a nearby stream with drilling fluid, oil, oily waste and sift. Several natural runoff areas and streams were affected. The company was contacted so that cleanup efforts could begin, but no effort was forthcoming. Summons to court and warmats for arrest were signed, however the case waa withdrawn by the state Prosecutor without explanation.

i
(yes/no)
Ground Water
Surf. VMarer(Yes
SoJ[7es (reserve, holding or emergency pit; tank, well, battery; spill; injection well; bbwodwn. etc.) (mud, brine, produced water, woricover fluid, free fluid, etc.) (describe nature of available analysis, cite key numbers i available)
Damage Source Breached reserve pits. Anal Extent Waste Stream Drilling fluid and oity waste.
o
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Waste Analysis NA
NA
3/4/874
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Antel Extant Oafaof Relaase Duration Over on* haJf mil*. Dacembar, 1983. ( raleast may bo ongoing, recently reported, etc.) (commant *$ needed) Fauna | j
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Affected Biota Damaqa Description
Fbn
Human Health
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Streams and natural araaa of runoff war* polluted with drilling fluid and oily wastas whan two reserve pits oparatad by Alia* Energy wara braachad allowing tha contents to flood tha area.
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Vblationa Stata Rags. I CompSanea ls$ua$
Tj (OMo UYas) at tima of damage
Willluljiisragaôf ata rules and regulations regarding oonstruetioQ and raelamation of reserve pto. Why was casa withdrawn by Prosecutor?
m
Documentation WV DNR prosecution raport. Dae. 20.1983. Warrant for arrest, Dae. 15,1983. Complaint for Summons or Warrant. Dae. 15.1983.
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Damaga Casaa
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Description of Oparatton
Production Production Production Area Type Appalachian Basi Gas Development
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Category
Description Operation
of
h att Waco Oiill a n d Gas w warre o oii nag d drrililll a a g g In J a n u a r y 1984, tha C h a p m a n s received n o I c e thatt Waco Oiill a n d Gasarr e o oii nag tt ott o d drrililll aaaa gas well o n t h e i farm. The Chapmans agreed t o t h i s drilling, u tha w o r k p e r m i t stated that c a r e w o u l d to taken to m i n i m i z e damages t o t h e p r o p e r t y a n d topsail w o u l d b i s replaced. Tha well w a s d r i l l e d a f t e r several unauthorized changes wore made to the original worKplanÔn March 18, the well was completed and no topsoil was in evidence. After numerous meetings with Waco and the Department o f Gas and Oil, no settlement could be reached o n damages s u s t a i n e d b y the C h a p m a n ' s farm. Tarry Chapman then s o u g h t legal counsel. I n the meantime, Waoo had proposed to drill four more wells on the Chapman (ami. The Chapmans would n o t agree to more drilling until the first site had been properly reclaimed. UJaCOa, -wo-* l - t r v i - f _ i ft^-j.^
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Pathway ol Contamination Damaga Source Anal Extant Waste Stream (yes/no) Ground Water l | Surf. W
afer
So*
D r i l l i n g b y Waco Oil a n d Gas o n C h a p m a n farm. D r i l l i n g s h e w a s n o t p r o p e r t y r e c l a i m e d (rotarva, holding a n d t o p s o i l was n o t replaced r e s u l t i n g i n erosion and l o s s o f crop production. emergency pit: ta wall. Denary; spill injection wall; blowdown, ate.) Erosion (mud. brine, produced water, workover fluid, frac fluid, etc.)
Waste Analysis
S t u d i e s d o n e on Chapman farm t o q u a n t i f y s o i l a n d c r o p damage d u e t o i m p r o p (describe natur e of available construction and reclamation o f drilling site. analysis, cite key numbers i available)
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Anal Extant DafacV Rabat* Duration
Two term
I
March, 1084 2-3 days (yet/no) Fauna
(acrat) ( release may ba ongoing, recently reported, etc.) (comment as nueaeoi
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Affected Biota Oamag* Description
After drilling and completing a gas well on the property of Terry Chapman, Waco Oil and Gas did not properly reclaim and reslora the surfaca of tha drillsHa. Topsoil was not replaced rssulting in soil snd crop damage documented by two reports done independently by'agronomists. Extensive erosion resulted on the drillsiia. Due to lack of topsoil, tha grass grown on the site would ba of little nutritional value to tha Chapman's cows, ant trees that might grow would have little commercial value.
CD
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Human Health
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Violations Stats Rags. I CompSanca, Issues!
(OmNo 1-Yes) at lima of damage
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Unwillingness of oikjnd gas oparator to follow through ivith agreement concarning reclamation of driilsits. Unwillingnass andjnability of Gas and Oil Division to anforca agreement signed by landowner. This illustrates tha inability of surface landowners to require fulfillment of surfaca agreements signed by oil and gas compame
i-a, "MU.
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---' Documantation
CWa.
s.'eU&A
Report to Banjamin Snyder, attorney for Terry Chapman, from Tarry Chapman documenting chain of events leading to damage of Chapman farm and subsequent lawsuit. Complaint filed in circuit court of Gilmer couniy. WV, Chapman va. Waco oil and gas, 036-C-S. Answer filed in circuit court of Gilmer county, S86-C-6. Lanar from Torry Chapman p Thomas Greene of Waco oil discussing lack of topsoil on driilsits. Report to Terry Chapman from Robert F. Keefer, professional soil scientist, discussing condition of soil and crop loss. Lenar:; Larry Graynolds, district conservationist from Ron Taylor, soil scientist, concerning amount of missing topsoil on Chapman farm. Letter to Tarry Chapman from Victor Laughlin, consulting forester, concerning timber crop loss on Chapman farm. Work permis.
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Description of Operation Production Area Production Type Production Category Southeast Kansas oil production
(basin, region,etc) (oil, gaa, injection well, etc) (exploration, development, production, or other)
Description of Operation Temple Oil Company and Wayside Production Company operate a number of oil production leases in Montgomery County. The leases ware operated using illegal salt water containment ponds, improperly abandoned reserve pits, unapproved emergency salt water pits, improperly abandoned salt water pits. In . addition, operation of the sites was generally very sloppy resulting, in numerous oil and saltwater spills. Documentation of these incidents starts in 1977 when adjacent landowners began to complain about soil pollution, vegetation kills, fish kills and pollution of freshwater streams due to oil and saltwater runoff from these sites. Complaints were received b y . the Conservation Division, Kansas Oepartment O f Health arid the Environment, Montgomery County sheriff and Kansas Fish and Game. A total of 3 9 violations on these leases were documented between 1983-1984. Private landowners filed complaints a s early a s 1981. The leases also contain a large number of abandoned, unplugged wells, posing a threat to ground water. Description of Waste a n d Damage Pathway of Contamination (yes/no) Ground Water \y as Surf. W a r o r l y e s I Sbriflyes (reserve, holding or emergency pit; tank, well, battery; spill; injection well; biowdown, etc.) (mud, brine, produced water, workover fluid, frac fluid, etc.)
Damage Source Brine and oil pallution to freshwater streams, s o H and groundwater due to use o f unlined, unapproved saltwater containment ponds, umproporty abandoned reserve Area! pits and brine disposal pits, and unplugged abandoned wails. Extent
oo
O
Waste Stream
Brine and oil
Waste Analysis Water sampled from a 4 1 / 2 foot test hole between a freshwater pond and creek on the (describe nature Fowler's lease showed ground watar with CI cone, of 65,500 ppm. Water samples of available taken from pits on the owner's leases (the Fowler's and others) showed CI cone analysis, cite ranging from 5,000 to 82,000 ppm. A**lh> key numbers if _ _ , j - available)
P^F^'
NA
3/10/87
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Areal Extent Data of Release Duration NA 1977-1984
(acres)
(release may be ongoing, recently reported, etc.) (comment as needed)
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At loast eight yaars (yas/no) Fauna
= r* 3 3 *+ TT co =r mJ? 3
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Affected Biota
yas
flora
yes
Human Health
(O CO CD
Damage This case study involves violations on multiple leases. The Fowler's lease is the area showing damage to a pond Description and a creek due to intentional dumping of brine into a creek. Both the creek and the pond experienced fish kills after brine was released into these surface water bodies. A test hole was dug between the creek and the pond show the ground water was also contaminated with chlorides of 85,000ppm. Numerous vegetation kills and oil spills are documented on the leases involved. Soil salt pollution was documented by adjacent landowners.
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Violations Star* flags Compliance laauoa
The Kansas Corporation Commission made an administrative order in 1984, fining Temple and Wayside a total of $80,000. Only $25,000 Was collected and the operators could reapply for licenses to operate in Kansas in 36 months. It took the KCC at least five years to bring an end to the blatant disregard for the rules and regulations governing oil and gas operations in Kansas. In five years, significant environmental damage was sustained by the areas near these leases.
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Documentation The State Corporation Commission of the State of Kansas, Court Order describing the evidence and charges agianst the Temple Oil Co. May 17.1984
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Description of Operation: Damage Source:
"A threat to groundwater" does not represent documented damage.
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Groundwater is very deep in the area. Damage was to the unsaturated zone. There was no documentation of damage d ue to unplugged abandoned wells. In fact, this is a depleted reservoir with a static fluid level 300 feet below surface. Waste Analysis: There is no groundwater at 4 1/2 feet. This chloride concentration corresponds to produced water concentrations in this area. This shows no dispersion as would occur in groundwater. Damage was to soil in the unsaturated zone (the groundwater level is very deep in this area) due t o produced water filtering downward from t h e surface. The respondents, the Temples, petitioned the District Court for review of the Commission's assessment of the $80,000 penalty. The Court r e q u i r e d the Temples to post a $25,000 bond. F o r lack of prosecution the Commission made a motion of the court that the petition for seeking judicial review be dismissed. The dismissal was granted and the $25,000 was turned over to the Commission. At that time the Commission reconvened to again get an update to the inspection of the leases to find out if any progress had been made since its initial order. This was in about October of 1985. The Commission found that no progress has been made towards bringing the leases into compliance and therefore, reassessed the outstanding $55,000 penalty. The Commission has since sought judical enforcement of that penalty i n the District Court and a journal entry has been signed and was reviewed by the Commission and is now ready to be filed in District Court. This will give District Court judicial enforment to the outstanding penalty. Additionally, in a separate lawsuit between the landowners, the lessors, and the Temples regarding operation of the leases, t h e landowners were successful in a lawsuit and the leases have reverted back to the landowners. Those leases are now being released or leased again to new operators. The new operators are prevented from operating without Commission authority. This is pursuant to the Commission's orginal order entered in May of 1984. That order prevented any operator from coming in and operating the subject leases without notice and hearing before the Commission. The Commission entered that provision of the order to
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prevent the respondents, the Temples, from reincorporating under another name and starting up operations again. They did attempt to do this once or twice and through hearing, they were denied further operation of the leases.
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This was a KCC order, not a court order. It assessed a penalty, revoked the operators license and prohibited further operations on the lease without notice and a hearing.
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(oil, gaa, injection well, etc.) (exploration, development, production, or other)
Description of Operation The Associates Oil and G a a Inc. operates a production unit on the Shrag Lease in Harvey County. In May 1986, the Equus Beds Groundwater Management District No. 2 received a n anonymous complaint concerning the illegal operation of the Shrag Lease. Upon inspection, it was found that an unapprovad lined emergency pit was being used for the storage o f brine. Conductivity o f fluid in the p i t was greater than 5 0 , 0 0 0 micro-Mhos., and there was evidence that the pit had contained more fluid than waa currently present There was saltwater leaking from a saltwater holding tank on site, and there waa evidence o f salty r u n o f f from this leak. Samples o f tfle.fluid were taken.

Pathway of Contamination (yea/no) Ground Water \ | Surf. Wtferiyes I S o yes (reserve, holding or emergency pit; tank, well, battery; spill; injection well; bbwdown, etc.) (mud, brine, produced water, wotkovor fluid, frac fluid, etc.) (describe nature of available analysis, cite key numbers if available)
Damage Source Leaking o f saltwater from rusty fitting on brine storage tank. Areal Extent
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Waste Analysis Specific conductance test on water from pit show >S0,000 umhos. Samples from monitoring walls -3/4 of a mile S W of the pit, refistered CLconc. of 1Igajjd 150 mg/l
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Damage Salt pollution of soil duo to leakage from bfino holding tank. Potential for groundwater pollution due to use of Description unapproved, lined emergency pit As emergency pit was lined, it was assumed that the operator meant to use it on a long term basis, in violation of rules regarding the us* of pits.
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Emergency pit was lined indicating the intention to us* it on a long term basis, disregarding rules governing use of pits in Kansas,
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Equis Beds Goundwater Management District #2. 313 Sprue*. Halstead, KS 67056-1925. (318) 835-2224. Latter to Ralph O'Conner, Joint Oil and Gas Regulatory Agency explaining cas*.
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The leak was minor in nature (referred to as a drip). Any damage would have had to be minimal due to the small nature of the leak and the short duration of the incident. Groundwater flow in this area is to the southeast, therefore, the results of this analysis could have no relation to this minor leak. "Potential for groundwater pollution" does not represent documented damage. This is particularly true for a lined pit. Impact on soil was minor due to minor nature of the leak. This was strictly an administrative violation. The operator simply overlooked filing an application. The fact that he lined the pit indicates his appreciation for the sensitive nature of the Equus Beds area. Also, the high level of surveillance in this area insures that violations are caught early and damage is minimized. Field Report dated May 2 1 , 1986, from Ralph 0'Conner (KDHE geologist) as a compliance follow-up indicates the pit is essentially empty (fluid tested revealed contents primarily rainwater) and the valve leak was repaired.
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Description of Operation At tha Gary Laslie farm, considerable saltwater pollution is evident. Natural springs on tha larm have become salty, causing vegetation kills and salt pollution of soil. Located on tha farm is the Leslie #1. a well drilled by Western Drilling. Tha Leslies believe this wall to ba tha sourse of salt pollution of their groundwater, as soma days after plugging, the top plug slipped an unknown distance downhola. After slippage a rock was dropped downholo and a splash was heard soma seconds later. Another possible source it tha abandoned reserve pit used to drill tha Leslie # 1 , as drilling i n this area requires penetration o f tha Hutchinson Salt, member, during which 200 to 400' cubic feet of rock salt is dissolved and discharged into the reserve pit The ground in the'area consists of high infiltration soils which would allow migration of pollutants Into tha groundwater. The Lsslias were not provided relief by tha Kansas Corporation Commission, so they filed suit in civil court, and won thoir case for a total of $11,000.
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Damage Source Salt pollution of groundwater duo to improperly plugged oil well and leaching of reserve (reserve, holding or emergency pit; tank, pit into groundwater. Salty groundwatar came up through natural springs causing well, battery; spill; Area! vegetation kills and salt pollution of soil. injection well; Extent blowdown, etc.) Waste Stream brine (mud, brine, produced water, workover fluid, (rac fluid, etc.) (describe nature of available analysis, cite key numbers if available)
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Damage Groundwater on Gary Leslie (arm severely contaminated with salt. Qroundwatar came to the surface through Description natural springs causing salting of the soil and subsequent vagatation kills.
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Compliant* Issues
The Kansas Corporation Commission raoognizad tha savara salt pollution prablams on tha Gary Laslla larm as documented by tho extensive studies dona on tha subject Yet, no fines wars levied against Western Drilling and no relief was provided to tha Leslies by the Commission in recovering damages. Tha Leslies were forced to persue tha case in civil court, where they were awarded $11,000 in damages from Western Drilling, now Bramwell Petroleum.
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Documentation Gary Leslie Saltwater Pollution Problem, Kfngman Co. Final Report. KCC Conservation Div., Jim Schoof, Chief Engineer. Sept 1986. Contains letters, memos and analysis pertaining to case.
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Case No. KS03 Description of Operation: The pit was closed by the landowner spreading the contents with his own bulldozer. He eventually rebuilt his terraces back with this mixture of pit contents and soil. The KCC made an investigation ( w i t h state funds) of the allegation that the damage w a s due to the improperly plugged oilwell. This included digging the wellhead out, drilling down alongside the surface pipe and eventually drilling t h e well out. No evidence was f o u n d that the well was inadequately plugged. Cement o n the 8 5 / 8 string was good, no high Chloride water was found outside the surface pipe and no movement of f l u i d was observed in the well after it was drilled out. The KCC eventually replugged the well a n d remain satisfied that the well did not contribute to the problem. Further evidence that this scenario is correct is the fact that the landowner's water wells were never affected.
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The natural springs is actually a clay outcropping. The clay barrier is about 40 feet below the surface in the area of the pit, due to the relief i n the area (this is a terrace farming site) the clay barrier outcrops as the land drops off. Groundwater below this clay barrier was not affected as attested by the fact that no impact noted on the landowner's water wells.
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The KCC made a detailed investigation of this case (see damage source comments). This situation occurred due to surface pond management techniques carried out under the KDHE rules during the time of i t s joint authority with the KCC. See the attached comments on surface pond regulation in Kansas that explains how this situation is being rectified by the KCC now that they have sole authority over oil and gas activities.
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gSince July 1 , 1 9 8 6 , all oil and gas activities in the State of Kansas have been regulated by the Kansas Corporation Commission ( K C C ) . Prior to that d a t e , the Kansas Department of Health and Environment (KDHE) and the KCC had joint authority over certain aspects of oil and gas activities (from 1981-1986 as the Joint Oil and Gas Regulatory O f f i c e ) . Although both agencies had rules and regulations, it was the KDHE statute that promulgated the pit and pond r u l e s . During this approximately twenty year period, the KDHE had the technical staff to evaluate compliance and the KCC was primarily involved from an administrative standpoint (see Attachment I-memorandum from Shari Fiest dated February 2 6 , 1987 for background). This joint regulatory approach resulted in confusion on both operators and regulators. However, the placement of all authority under the KCC has resulted in a much more efficient mechanism to address the need for additional environmental protection, promulgate appropriate rules and enforce compliance. An example of this are the new surface pond and spill notification regulations included in the May 1 3 , 1987 KCC notice to operators (Attachment 2 ) . These rules include requirements for permits for all p i t s , emptying of emergency pits within 4 8 h o u r s , notification of spills within 2 4 hours and sets specific administrative penalties appli^ cable to each individual violation. It should be noted t h a t , unlike the previous situation where the KDHE had no authority no shutdown operations, the KCC has this option should the situation warrant this drastic an approach. A l s o , relevant to the evolution of surface ponds regulation in Kansas has been the formation of a Surface Pond Study Committee (see Attachment 3 ) . This committee has representation from the various state Groundwater Management Districts, the Kansas Geological Survey, Industry, the KCC and the K D H E . A s the proposed Surface Pond Policy Statement (Attachment 4 ) indicates, this group is in the process of identifying potential environ^ mental problems related to the use of pits in certain locations in the state and is considering appropriate measures to protect the environment in those sensitive a r e a s .
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MEMORANDUM
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TO: Chairman Lennen Commissioner Wriqht Commissioner Henley A d m i n i s t r a t i v e Assistants B i l l Bryson Shari Feist
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RE: DATE:
Dri 11 Pit
Permits 1987
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February 26,
During the course of our committee meetino s on r e g u l a t i o n s t h i s summer, the committee working on p i t s and ponds p r o m u l a a t e d r e g u l a t i o n s s u b s t a n t i a l l y s i m i l a r t o those which had been i n use by KDHE f o r 20 y e a r s . The KDHE r e g u l a t i o n s were a u t h o r i z e d pursuant t o t h a t p o r t i o n of K . S . A . G5-171d which i s now K.S.A. 1986 Supp. 55-171. When K D H E had - j u r i s d i c t i o n over p i t s and ponds, i t had a rule which had been i n e f f e c t f o r 20 years which s p e c i f i c a l l y exempted d r i l l p i t s and burn p i t s from the s t a t u t o r y requirement th^'t a l l surface ponds be p e r m i t t e d p r i o r t o t h e i r u s e . The p i t s committee p r o m u l g a t e d a v i r t u a l l y i d e n t i c a l r e g u l a t i o n v/hich was rejected by C a r l Anderson of the A t t o r n e y G e n e r a l ' s o f f i c e d u r i n q t h e r e g u l a t i o n ' s review process as b e i n g o u t s i d e the scope of our s t a t u t o r v authority. As a r e s u l t , the Commission i s required to permit a l l surface ponds, i n c l u d i n g d r i l l p i t s , p r i o r to t h e i r u s e . A t t a c h e d is a pond p e r m i t a p p l i c a t i o n which s t a f f has developed for a l l p i t s . When I presented the rules and r e g u l a t i o n s to the J o i n t Committee on Rules and R e g u l a t i o n s , I was questioned p a r t i c u l a r l y about these pond r e q u l a t i o n s . A great deal of concern was expressed about how we intended t o permit d r i l l p i t s and a v o i - i " r u b b e r - s t a m p i n g " them w i t h minimal s t a f f review. I i n d i c a t e d that we hac" a permit a p p l i c a t i o n for a l l p i t s except d r i l l p i t s and had i n t e n d e d t c permit d r i l l p i t s on the d r i l l i n g i n t e n t c a r d . This was not a s a t i s f a c t o r y approach so I have chanqed the a p p l i c a t i o n to i t s c u r r e n t form w h i c h requests s p e c i f i c i n f o r m a t i o n about d r i l l p i t s . A few weeks a f t e r t h i s m e e t i n g I was asked to j o i n R e p r e s e n t a t i v e Sandy Duncan and Judy McConnel l f o r lunch so t h a t we could discuss t h * Commission's plans for implementinq these r e g u l a t i o n s . Rep. Duncan a g a i r expressed c o n c e r n about " r u b b e r - s t a m p i n o " i n d i c a t i n g that by passage of H.B. 307R we are i n essence the Kansas version of the EPA. I n response I i n d i c a t e d t h a t the O i l and Gas A d v i s o r y Committee had c r e a t e d a subcommittee to study s e n s i t i v e groundwater areas in Kansas i n an e f f o r t t c d e v e l o p s p e c i f i c pond r e g u l a t i o n s f o r those a r e a s . Rep. Puncan s p e c i f i c a l l y requested that the subcommittee be steered so that r e g u l a t i o n s would be developed by the end of the summer.
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Perhaps I a m p l a c i n a myself under pressures which are nonexistent, b u t I feel that staff has an obligation to carefully review pond applications. I am comfortable with the procedures for reviewina all o t h e r pit permits but drill pits. Technical staff is aware of certain areas in Kansas which are potential pollution hazards from the outset of drillina operations. They have Generally identified those areas as follows: Eastern Kansas where s a l t water is used as a d r i l l i n a fluid in areas where the Doualas aroup outcrops. 2. 3. Northeast surface. Kansas where q l a c i a l till exists at
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I t is s t a f f ' s recommendation that in these a r e a s special precaution be taken. Thoucih staff agrees with some measure of precaution there are areas of d i s a g r e e m e n t . The main c o n c e r n s with implementing such measures are that staff would be usurping the function of the subcommittee; t h a t d r i l l p i t s have gone v i r t u a l l y unregulated for 20 years and six months more won't c r e a t e any harm; and t h a t s t a f f simply does not have the e x p e r t i s e . O n the o t h e r hand, s t a f f a a r e e s t h a t these areas are problem areas that reauire sane additional p r o t e c t i o n . The e x p e r t i s e that staff lacks is in the area of lining p i t s what type and t h i c k n e s s l i n e r , whether and when d r i l l i n g f l u i d s should be removed, d i s p o s a l of the l i n e r upon abandonment. Staff aenerally agrees that a minimum linino requirement should he enforced in the above-noted a r e a s , i . e . , 10 ml. l i n e r , and that d r i l l i n a fluids should be removed as soon as p o s s i b l e . The real problem i s that s o l i d waste l a n d f i l l s do not accept the l i n e r and r e l a t e d residue and there are no locations at which such disposal can be accomplished other than o n - s i t e h u r i a l . This, t o o , i s a problem in t h a t the b u r i a l s i t e will be a soft, wet location u n t i l the l i n e r rots (not in our lifetime) and unsuitable for farminn.
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Staff would like an indication as to whether minimum standards should be adopted for these named a r e a s , i . e . 10 ml. l i n e r s or whether we should maintain s t a t u s quo for a few more months. The next meeting of the subcommittee i s March 20, 1987, and staff is r e l a t i v e l y c e r t a i n t h a t the subcommittee would agree with these minimum g u i d e l i n e s . The next oil and Gas Advisory meeting is scheduled for March 26, 1987. Please advise. cc: Jack McCord Rex Krieg Duane Rankin Bea Stong Rick Hestermann Dennis Anderson Rich Claytor
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Mlka Hiydtn K*1th It. Henley Rich Kraxtmkt HtrgtlH Wright Judith A. HcConiMlt
Governor Chtlnun Conlsiloner Comlisloner Executive Director
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CONSIRVATION DIVISIO N
(CXI, O n end WM<) 200Cokxdo D e t t o y Building 202 Wt 1MSM< WICHrTA, KANSAS 07202-1286 RE: DATE: must Changes May 13, In R e p o r t i n g Forms and R e g u l a t o r y 1987 f o r m s , or they w i l l be r e j e c t e d . The Update
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As of May 1 , 1 9 8 7 , a l l r e p o r t s and a p p l i c a t i o n s f o l l o w i n g forms have r e c e n t l y been u p d a t e d : AC0-I6 CSP-l U-l Hew P o o l / D i s c o v e r y A l l o w a b l e D e t e r m i n a t i o n Pond Permit A p p l i c a t i o n A p p l i c a t i o n for I n j e c t i o n Well
be s u b m i t t e d on t h e c u r r e n t
5/87 1/87 1/87
U-B ACO-1
A p p l i c a t i o n to Amend I n j e c t i o n Well Completion Report
Order
1/87 5/86
(For other forms and dates, sea the attached list.) In addition, some significant changes have been made In the Commission's Rules and Regulations, changes are as follows: Some highlights of those!
K . A . R . 8 2 - 3 - 1 0 3 . N o t i c e of Intention To Or 111. Intention to Drill form 00-1 must now be filed for any storage well. T h e : definition of storage well Is as follows: "a well used to Inject or extract natural gas for storage purposes." Please note, that the tiling of this Intent does not replace tho filing of any other necessary applications and permits. ; K.A.R. 82-3-130. Completion Report. REMINDERI Affidavit of Completion (form AC0-1) must bo filed with the Commission within; 120 days from spud date. Failure to comply will result In a $100 administrative penalty, and the rights to confidentiality) will be lost. If completion of the well Is delayed, an Incomplete ACO-1 must be filed within the 120 day period, and an amended (and complete) ACO-1 shall follow. Letters requesting confidentiality must bo sent to the Proration Department.: Copies of the request for confidentiality must accompany all additional affidavits filed with the Commission. i K.A.R. 82-3-131. Vacuum and High Volume Pumps. The changes In this regulation are with regard to high volume pumps. A high; volume pump Is defined as one which Is capable of producing total fluids In excess of 2500 barrels per day. Please note that;; most oilfield submersible pumps would fall under this definition. All vacuum and high volume pumps may be Installed only; after application and approval by the Commission. K.A.R. 82-3-138. New Podl and Discovery Allowable Applications. These applications may be granted administratively. The ne' AC0-I6 (enclosed) Is now the only acceptable form tor these applications. Instructions on the form must be followec" completely. A State-supervised test must accompany the application for all discovery and development wells drilled durlncj the effective two-year period granted by this regulation. K.A.R. 82-3-203. State and Pool Allowable and Proration. Effective May 1, 1987, oil allowables as per this regulation havr; changed both In the depth and allowable schedules. The Increased allowable Includes the 25 barrel bonus formerly artdod Into'; the allowable. Therefore, a 25 barrel per day bonus In no longer applicable. Discovery allowables will be figured at 1 1/2;;' times the current dally allowable set by this regulation. K.A.R. 82-3-405. Mechanical Integrity Requirements. Please note the following changes in the required test pressures: ,
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I. New Injection or disposal wells being converted to Injection or disposal wells shall be tested at 300 psl or the maximum requested Injection pressure, whichever Is greater. II. Previously permitted Injection or disposal wells, or wells having passed an Initial pressure mechanical Integrity test a the pressures Indicated above shall be tested according to the following guidelines: a) Wells located In areas having salt water bearing zones with sufficient bottom hole pressure to sustain a statl fluid level at or above fresh or usable water bearing zones shall be pressure tested at 300 psl. b) Wells located In areas without salt water bearing zones with sufficient bottom hole pressure to sustain a statl fluid level at or above fresh or usable water bearing zones shall be pressure tested at 100 psl. K.A.R, 82-3-600 through 603. Surface Ponds & Spill Notification. This new set of regulations was adopted by the Commlsslo as a result of the passage of House Bill 3078, which transferred this authority from the Kansas Department of Health an Environment to the Commission. AlI surface ponds (Including drill pits) must be permitted prior to use. These regulation require that all emergency pits be empty of fluids. Failure to empty emergency pits will result In an administrative penalt of up to $1000 and possible license review. In addition, this regulation requires that all spills be reported to th appropriate district office within 24 hours of occurence. Failure to do so will result in an administrative penalty of up t $1000 and possible license review. Please fIridenclosed the following Information a list of the current Conservation Division forms and applications an update list of Administrative Penalties copies of some of the most recently updated forms a list highlighting some Important regulatory requirements
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If you should have any questions or need additional forms, please contact the Conservation Division at (316) 263 -3238.
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1. 2. No lease ID sign. Failure to preserve formation samples and failure to file well histories, loqs, and surveys. Failure to file notice of temporary aban^ donment of wells (form CP-111). Failure to file notice of intent to aban^ don wells (form CP-1). Failure to file plunging report (form CP-4). Failure to verify information required by the Commission. Failure to file affidavit of well comple^ tion (form ACO-1). Failure to file notice of commencementi discontinuance, and abandonment of injec^ tion or disposal operations (form U-5). Failure to file application to amend in^ jection or disposal wells orders (form 0 - 8 ) . Failure to file annual report showing per^ formance of injection or disposal wells (form U-3C). Failure to file notice of intent to trans^ fer injection of disposal well ownership (form 0 - 2 ) . Failure to obtain Commission approval prior to using an injection or disposal well pur^ suant to making application therefore (form 0-1). 13.
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Penalties
K.A.R.* 82-3-126 Penalty S100
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82-3-107 82-3-111 82-3-113 82-3-117 82-3-128 82-3-130
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S100 S100 S100 S100 S100
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S100 S100
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82-3-407
S100
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82-3-408
$100
12.
82-3-400
S1000 S, shutdown S5000 s shutdown $10,000 f shutdrwn n2-3-103 ( 106 82-3-103 S 106 82-3-120 82-3-405 82-3-603 $250 $500 $1000 82-3-603 $250 $500 $1000 $5000
First violation Second violation Third violation (requires license review)
Failure to install surface pipe required by Commission. Failure to complete Alternate 2 cementing procedures. Operating without a valid license. Failure to run Mechanical Integrity Test. Failure to report a spill within 24 hours. First violation (possible license review) Second violation (possible license review) Third violation (possible license review)
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$5000 S500 S1000
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Failure to empty fluids from an emergency pit. First violation (possible license review) Second violation (possible license review) Third violation (possible license review) Administrative Regulation
Kansas
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ATTACHMENT 3 SURFACE PONDS STUDY COMMITTEE January 2 3 , 1987 10:00 a.m. Committee Members Present: Mike Dealy, Chairman; Frank Novy, Bill Bryson, Gyula Kovach, Don Ubel, Larry Knoche, Ralph O'Connor, Ralph Davis, Keith Reavis, Bill Horigan, Shari Feist, Nedra Jennings. Warren Kirkpatrick, Doug Louis, Bea Stong, Jim Schoof, Dennis Anderson, Duane Rankin, Don Butcher, Rick Hestermann, James Browne.
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KCC Staff Members Present:
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This committee was established by the O i l and Gas Advisory committee. The purpose of the committee is to investigate the need for special surface pond requirements in designated areas. The following areas should be studied and recommendations made: 1. 2. designation of hydrological and geological area parameters; delineation of areas; designation of fluid parameters; construction and abandonment requirements of surface ponds; disposal of pit contents upon pit being abandoned; the economic impact of requirements.
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3. 4. 5. 6.
Four study groups will be assigned to study and develop recommendations for the six areas of study. Study group (A) will look at recommendation of #'s 1 & 2 above; Study group (B) will look at recommendation of iTs 4 & 5 above; Study group (C) will look at recommendation of #3 above; Study group (D) will look at recommendation of #6 above.
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Study Group (A) R. O'Connor - Ch. G. Kovach F. Novy R. Davis
Study Group ( B ) B. Horigan - C h , L. Knoche D. Ubel
Study Group (C) B. Bryson - C h . K. Reavis N. Ginest
Study Group (D) N. Ginest - C h . 8. Horigan B. Bryson K. Reavis
Shari Feist was appointed for legal counsel for all committees.
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Study Committee
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January 2 3 , 1987
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Study Group ( A ) - Parameters and A r e a s , committee concerns and discussion. 1. 2. Documentation - put tangible evidence together; Largest impact on drilling pits, economic impact greatest on lining drilling pits; (reference w a s made to this in Congress this past summer); Type of operations and fluids, concerns with type o f pits construction. Study al1 types of pits; Documentation to come from KCC o r KDHE files; look at degree of protection; Do brief introduction into practices; Look at permanent installation and temporary installation; concerns with salt sections; Monitor some cases to develop background; Possible set up in KCC to unitize fee funds to initially help with emergency pits; Study "Drestic Method" for parameter development.
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3. 4. 5. 6. 7. 8. 9. ;
Ralph Davis made a motion that all background and case history information to be correlated by a separate group with one person from K C C , KDHE, GMD, and one industry person to b e in this group. Bill Bryson seconded this motion. Motion carried. This fifth study group ( E ) to consist o f Larry Knoche a s Chairman; Don Ubel, Ralph Davis, and Bill Horigan. Study group time frame set for next month f o r general outline of where the problems a r e located; get a basic feeling statewide. Study Group ( B ) - Construction S Disposal, committee concerns and discussion. i.
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discuss practices and alternatives and what problems a r e connected with each; discussion on liners; determine if pit constantly holds fluids o r is used f o r emergency only; time frame; how long will pond b e used; look at on-site disposal, and at drilling pits not at the muds;
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Surface Pond Study Committee Page 3 January 23, 1987 6. 7. 8. 9. consider depth of water table v . depth o f pit;
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transporting pit contents t o off-site disposal; look a t solid waste statutes; look a t present types of disposal methods; study types o f pits used; determine cost o f available disposal methods.
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Study Group ( C ) - fluid parameters, committee concerns and discussion, 1. 2. 3. 4. classifying chemical make-up (work i n cooperation with Mudco and other industry representatives); look a t usable water and brine; determine what kind o f tests needed o n fluids, trace elements o r chloride t o permit; swab fluid back into p i t ; leave situation open for staff to make recommendations; look into liquid fraction; determine o r study what effect time has o n fluid standing i n pit and the subsequent fluid - solid separation; discussed KCC records and files containing basic fluid data.
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Study Group ( D ) - Economic Impact, committee concerns and discussion. 1. 2. 3. 4. set base line for current costs t o the industry for the use o f p i t s ; look a t economics of what it will cost Kansas and the society o f Kansas if our groundwater i s contaminated; look a t EPA study on economic impact, look a t industry, state economy, i.e. additional staff.- Look a t Productivity Waste Study; look a t cost benefits.
Next meeting date set for March 20, 1987 (Friday) or K0HE offices i n Wichita.
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SURFACE PONDS STUDY COMMITTEE February 2 , 1987 NAME Michael T . Dealy, Chairman ADDRESS Equus Beds Groundwater Groundwater Management Dist. HZ 313 Spruce Street Halstead, K s . 67056-1925 Maurice L. Brown Company 200 Sutton Place Wichita, K s . 67202 Kansas Geological Survey 1930 Avenue "A", Campus West Lawrence, K s . 66046 Mobil Oil Company Terminal Annex, P.O. Box 5444 Denver, C o . 80217 Big Bend Groundwater Management District No. 5 125 South Main, P.O. Box 7 Stafford, K s . 67578 Kansas Dept. of Health & Envir. Building 740 - Forbes Field Topeka, K s . 66620 Kansas Corporation Commission 4th Floor - State Office Building Topeka, K s . 66612 Donald C . Slawson Oil Producers 200 Douglas Wichita, K s . 67202 Kansas Dept. of Health & Envir. Building 740 - Forbes Field Topeka, K s . 66620 Northwest Kansas Groundwater Management District No. 4 1175 South Range, Box 905 Colby, K s . 67701 Kansas Corporation Commission 302 West McArtor Dodge City, K s . 67801 TELEPHONE (316) 835-2224
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Frank E . Novy, Vice-Chairman
(316) 265-4651
Howard O'Connor
(913) 864-3965
Noel 6inest
(303) 278-2745
Ralph Davis
(316) 234-5352
Larry Knoche
(913) 862-9360
William R. Bryson
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(913) 296-5113
Bill Horigan
(316) 261-5134
Gyula Kovach
(913) 862-9360
Keith Reavis
(913) 462-3915
Don Ubel
(316) 225-6760
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SURFACE PONDS STUDY COMMITTEE ORGANIZATIONAL STRUCTURE
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OIL AND GAS ADVISORY COMMITTEE
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SURFACE PONDS STUDY COMMITTEE 2) 3) 4) 5) A)
1) GEO-HYDROLOGIC PARAMETERS
SENSITIVE AREAS FLUID CLASSIFICATION POND CONSTRUCTION DISPOSAL METHODS ECONOMIC IMPACT
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GROUP (A) 'l>PARAMETERS 2)AREAS

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GROUP (B) 4)CONSTRUCT 5 ) DISPOSAL

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GROUP (C) 3)FLUID

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GROUP (D) 6)ECONOMIC

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GROUP (E) 7)DOCUMENT CASES

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KOVACH NOVY DAVIS
KNOCHE UBEL
REAVIS GINEST
HORIGAN BRYSON REAVIS
UBEL DAVIS HORIGAN
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INPUT;
ISSUES AND CONCERNS RECOMMENDATIONS
OUTPUT; FINDINGS AND
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SURFACE PONDS STUDY COMMITTEE MEETING Friday, March 2 0 , 1987 10:00 a.m. Minutes
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Present:
Mike Dealy, Bill Bryson, Mike Cochran, Larry Knoche, Ralph D a v i s , Keith R e a v i s , Don Ubel, Frank Novy, Howard O'Connor, Shari F e i s t , Bill H o r i g a n , tledra J e n n i n g s . (Mot p r e s e n t Noel Ginest.) Alan S n i d e r , Bea S t o n g , Rick Hestermann, Rex Krieg, Dennis Anderson, Jim Schoof, Ned Marks, D o n R u t c h e r , Ann R i d e r , James Browne, Doug Louis.
Non-members Present:
Approval of Minutes In the second paragraph, line 9, change the typographical error in the word drastic. Page 1, under Members Present and Study Group (A), change Ralph O'Connor Howard O'Connor. Additions to the Agenda The Commission asked Shar i F e i s t to subnit proposal for interim measures for d r i l l p i t s . This policy to outlin e g e n e r a l a r e a s . This needs to be discussed for a report back to the Oil and Gas Advisory. The Commission is asking for t h i s committee's input on t h i s policy s t a t e m e n t . Mike Cochran w i l l be s i t t i n g in for Gyula Kovach. Noel Ginest reported back on his study group via a l e t t e r .
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Study Group Progress Reports A. Case Documentations Larry Knoche s u b m i t t e d a r e p o r t i n c l u d i n g maps t h a t reflected h i s t o r i e s for Eastern Kansas over the l a s t 20 y e a r s , and for the of the s t a t e over the l a s t 8 - 10 y e a r s . Harvey County reflected have a problem. Butler County reflected no p o l l u t i o n , however, the Burrton no problems at t h i s time. Field case r es t does
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Barton County nothing was turned i n . The southeast d i s t r i c t had approximately 3 0 3 contamination instances.
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The question a r i s e s : Short term u s e w a s okay - b u t when t h e pond ( p i t ) was used f o r a long p e r i o d of time w a s t h i s where t h e problems originated? What we need t o look a t i s if t h e pond w a s okay under a n y u s e a s opposed t o long o r short term u s e . Amend t h e map on Contamination S i t e s in Kansas t o r e f l e c t as having two ( 2 ) surface pond problems. Harvey Ccunty
Amend page 1, paragraph 3 , t o read: "Although u s e a n d p o l l u t i o n from surface ponds h a s decreased considerably since t h e 1950's . . . " ' Change a l l "storage ponds" t o "surface B i l l Bryson motioned t o a c c e p t contamination with no conclusion. Motion carried. ponds." a s documentation of
the r e p o r t
Parameters Howard O'Connor commented t h a t t h e i r c o m m i t t e e w a s w a i t i n g for z'r.e r e s u l t s of t h e case documentation. This committee h a d n o r e p o r t a t t h i s time. B i l l Bryson w i l l submit t o a l l members a s e r i e s of models that EPA. will have a v a i l a b l e Tuesday, March 2 4 , 1 9 8 7 . Mike Cochran h a d a g e n e r a l l i s t of parameter s that was submitted t o Howard O'Connor f o r review by t h i s committee.
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B i l l Horigan commented that i t would be very helpful t o be s p e c i f ic i n an area; that there may b e special conditions that need t o b e lcz'.-:ei. into when making specific requirements. Shari Feist commented that i t had been requested t h a t we p u t together a Table I-type s e t of rules for t h i s committee. Bea Stong suggested that t h e i n f i l t r a t i o n need t o be looked a t . r a t e s in O'Connor's crc\:?
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Surface Ponds Committee Meeting March 20, 1907 Page 3
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Bill Horigan stated that their committee had not had a meeting yet, but several things were discussed. There are several other s t a t e s where p i t regulations have already been established, to take a look at those and proceed from there. The concept of l i n e r s keeps coming up, hut Horigan does not feel that liners are the solution. The decision was made to u t i l i z e S C S for s o i l samples; K D H E t o do lab check for heavy metals; groups B and C to coordinate to make final analysis on salt systems v. brine water; and fluids v. fluid removal from the p i t s . D. Fluid Classification
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Keith Reavis reported that he had asked for information on drilling fluids and that he had only heard from Davis M u d at t h i s time. Other reports will be sent to the committee members. There is no evidence to report on at this time. Bill until this April Bryson stated again that E P A fluid classifications won't be ready March 24, 1987. An agreement was made with operators to hold confidential. This information will be released approximately 10, 1987.
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Economic Impact (1) (2) A d d economic c o s t of doing d i f f e r e n t management options developed for treating fluids in the p i t s . B a s i c a l l y w e a r e t a l k i n g about s e p a r a t i n g the amount of m u d fror water and the timing regarding t h i s . Include also the use of a temporary (spray-on) sealant, Gunnite or a similar material. i.e.,
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Any other questions and concerns should be directed to Noel Ginest. Additional Concerns and Issues Discuss Notice of Policy Statement This question was put to Shari F e i s t : What does the Commission expect fror. this committee regarding this policy statement? This is s t r i c t l y for comment and input only.
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Surface Ponds Committee Meeting March 20 , 1907 Page 4
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Ralph Davis motioned: That the Chairman of this committee make a recommendation to the Commission that this polio/ is premature and not based on s c i e n t i f i c data/ that scientific data is not there and that they should wait for any recommendation from this committee, that there already exists the Rules and Regulations and expertise within the agency. Frank N o v y seconded the motion. 1 Abstention. Motion carried. The next meeting set for Wednesday/ April 22/ 1987, at 10:00 a.m.
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ATTACHMENT A KCC ,-Admin. M t g . D a t e : Today's Date: April 8, 1987 1 , 1987 Agenda Item
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Attorney: S taff:
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Title
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In the matter of the enforcement of K.A.R. 82-3-600 et seq. with regard to surface ponds in environmentally sensitive areas in the State of Kansas.
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Issue(s): Whether the Commission should adopt a policy statement concerning the adoption of precautionary measures relating to surface pond construction and abandonment in environmentally sensitive areas pending termination of the Surface Pond Study Committee's Study?
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Staff recommends adopting the revised Policy Statement.
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Attachment: Memo
Original policy statement, revised policy statement, minutes from Surface Pond Study Committee meeting, letter from Chairman Mike Dealy relating SPSC concerns.
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:ATS jcR?cp.,vncti ::II.-I33IOM ;F THE STATE: : F KA;ISAS Heith R. Henley/ Rich Kowalewski Margalee Wright Chairran
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In t h e ratter of d e s i g n a t i n g c e r t a i n geological a r e a s as p o t e n t i a l pollution h a z a r d s s u b j e c t t o s p e c i a l s u r f a c e pond c o n s t r u c t i o n c r i t e r i a p u r s u a n t t o K.A.R. 32-3-600. MOTICK 01-' L'OLICY STATEMENT The S t a t e C o r p o r a t i o n Commission
DOCKET N O . CONSERVATION
of t h e S t a t e of Kansas/
To:
All O i l a n d G a s Producers and O i l a n d G a s P u r c h a s e r s / R o y a l t y O w n e r s / Landowners/ a n d a l l P e r s o n s Whomsoever Concerned: You/ a n d e a c h of y o u ( a r e hereby n o t i f i e d t h a t t h e S t a t e C o r p o r a t i o n C o m m i s s i o n of t h e S t a t e of K a n s a s i n t e n d s t o d e s i g n a t e t h e f o l l o w i . - . g g e o l o g i c a l areas a s p o t e n t i a l pollution hazards subject to special surface pond c o n s t r u c t i o n c r i t e r i a p u r s u a n t t o K . A . R . 9 2 - 3 - 6 0 0 . These a r e a s a r e generally i d e n t i f i e d a s follows:
1.
E a s t e r n Kansas/ where s a l t water i s used as a d r i l l i n g fluid i n a r e a s where t h e Douglas group outcrops. N o r t h e a s t Kansas/ where e x i s t s a t t h e surface. glacial till
2. 3.
Statewide/ where a s a l t member i s penetrated in t h e d r i l l i n g process and where dune sane, a l l u v i a l s / and t h e Dakota are a t t h e surface. a r e a s t h e S t a t e C o r p o r a t i o n Commission of t h e implement a policy requiring that surface ponds materials and that d r i l l i n g fluids be removed a s d r i l l i n g process i s completed.
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In these d e s i g n a t e d State of Kansas intends t o be l i n e d with a r t i f i c i a l soon a s possible a f t e r t h e
The Commission i n v i t e s written public comment regarding t h e adoption of t h i s p o l i c y . Please iiuke w r i t t e n comments a v a i l a b l e t o Sh.iri M. F e i s t no later than April 17, 1 9 8 7 . All p a r t i e s in a n y way i n t e r e s t e d o r concerned s h a l l take notice o: the foregoing and govern themselves accordingly.
Shari M. Feist Acting Director Kansas Corporation Commission 200 Colorado Derby Building 202 West F i r s t Street Wichita, Kansas- 67202 (316) 263 - 3238
ORIGINAL
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CO x -+,*< THE STATS CORPORATION COMMISSION OF THE STATE CF KANSAS 3efcre Commissioners: Keith R. Kenley, Chairman Rich Kowalewski Margalee Wright DOCKET MO. CONSERVATION CIYISIC
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In the ratter of enforcement of K.A.R. 32-3-600 et seq. with regard to surface ponds in environmentally sensitive areas in the State of Kansas.
NOTICE OF POLICY STATEMENT The St3te Corporation Commission of the State of Kansas, T o : All Oil and Gas Producers and Oil and Gas Purchasers/ Royalty Owners/ Landowners/ and all Persons Whomsoever Concerned: 'iou, and each of you/ are hereby notified that the State Corporation Commission of the State of Kansas intends to adopt the following policy relating to surface ponds. In certain environmentally sensitive areas where potential pollution hazards exist as determined by the respective district geologist and the technical staff of the Conservation Division office located in Wichita, Kansas, an on-site inspection shall be required, prior to the initiation of drilling activities. As a result, surface pond permit applications for drill pits shal'l, be filed simultaneously with the Notice of Intention to Drill. Both the drill pit application and the Notice of Intent shall be filed with the Conservation Division at least five (5) day3 prior to the commencement of any drilling pursuant to K.A.R. 82-3-103 in order to facilitate such inspections. At the time of inspection, the respective district geologist may require that special precationary measures be taken with respect to pond construction and/or abandonment procedures. The Commission invites written public comment regarding the adoption of this policy. Please make written comments available to Shari M . Feist no later than May 1 5 , 1987. All parties in any way interested or concerned shall take notice of the foregoing and govern themselves accordingly.
S h a n M. Feist Acting Director Kansas Corporation Commission 200 Colorado Derby Building 202 West F i r s t Street Wichita, Kansas 67202 (316) 263 - 3238
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THE STATE CORPORATION COMMISSION OF THE =TATE OF KANSAS Keith R. Henley, Chairman Rich Kcwalewski Marcalee Wriaht In the matter of enforcement of K.A.R. 82-3-600 et seq. with regard to surface ponds in environmentally s e n s i t i v e areas in the State of Kansas.
DOCKET M O . CONSERVATION DIVISION
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NOTICE OF INTERIM POLICY STATEMENT The State Corporation Commission of the State of Kansas, T o : All Oil and Gas Producers and Oil and Gas Purchasers, Royalty Owners, Landowners, and all Persons Whomsoever Concerned: You, and each of y o u , are hereby notified that the State Corporation Commission of the State of Kansas intends to adopt the following interim policy relating to surface ponds. K.A.R. 82-3-600 authorizes the Commission to require the sealing of "any surface pond, except burn p i t s , with artificial materials . . . . if an unsealed condition will present a pollution threat to soil or water resources." Thus, in certain environmentally sensitive areas where groundwater or surface water pollution may exist and where the use of surface ponds may aogravate such conditions as determined by the respective district geologist and the technical staff of the Conservation Division office located in Wichita, Kansas, an on-site inspection may be required, prior to the initiation of drilling activities. As a result, surface pond permit applications for drill pits shall be filed simultaneously with the Notice of Intention to Drill. Both the drill pit application and the Notice of Intent shall be filed with the Conservation Division at least five (5) days prior to the commencement of any drillling pursuant to K.A.R. 32-3-103. In order to expedite such inspections, operators may notify the respective district geologist and request a site inspection prior to the filing of the drill pit application and Notice of Intent. At the time of inspection, the respective district geologist may require that additional protective measures be taken with respect to pond construction and/or abandonment procedures. A waiver of such additional requirements may be requested "pursuant to K.A.R. 82-3-100. This policy is intended to be an interim measure subject to the findings and recommendations of the Surface Ponds Study Committee, a subcommittee of the Oil and Gas Advisory Committee. The Commission invites written public comment regarding the adoption of this policy. Please make written comments available to Shari M . Feist no later than June 1 , 1987. All parties in any way interested or concerned shall taken notice of the foregoinc and govern themselves accordinoly.
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Shari M . Feist Acting Director Kansas Corporation Commission 200 Colorado Derby Buildina 202 West First Street Wichita, Kansas 67202
(316) 263 - 3238 SECOND REVISED POLICY STATEMENT
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KS Smolan-Salemsburg Saline and McPhsrson T| ScientiticAechnica I 11 0 - r w 7-yes
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Production Are* Northeast Kansas (basin, region, etc) (oil, ga, injection well, etc) (exploration, development, production, or other)
Production Type oil Production Category waste disposal
Description of Operation In tha Smolan-Salamsburg area, 44 injection wells were injecting into the Hutchinson Salt Member of the Wallington Formation, commonly callad the Lost Circulation Zone. Throught injection of oilfield brine, this salt member was being dissolved. Aa a result, highly salty water was intruding Into the Smokey Hill River through outeropings, making i t unusable during low-flow stages. T h e Smokey Hill River is the water supply source for several communities in northeast Kansas. T h e dissolving of tha salt member also caused subsidence and sinkholes to appear in t h e a r e a , creating tha potential for further collapsa of subsurface. |n 1 9 8 3 - 1 9 8 4 , the K C C ordarad that Injection into t h a Hutchinson Salt Mambar be, diseontinuad. Exemptiona w e r e granted to several operators for the continuanca of injection into the salt formation.
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Pathway of Contamination (yea/no) Ground W a M f l y e e Surf. WaterWoi So? l y e s (reserve, holding or emergency pit; tank, well, battery; spill; injection well; bhwdown, etc.) (mud, brine, produced water, workover fluid, (rac fluid, ate.) (describe nature of available analysis, cite key numbers if available)
Damage Source Injection of oilfield brine into t h e Hutchinson Salt, causing dissolving of t h a salt, pollution of tha Smokey Hill River and subsidence and collapsa of the sujasurfacs irr AreaJ the area. /> Extent
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Waste Stream
Oilfiald brine, dissolved Hutchinson Salt.
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Brine injected into a solid salt formation known as the Lost CIrciuatlon Zona has caused collapse and subsidence in the area because of injected brines dissolving the formation. These brines have caused significant contamination of tha Wellington aquifer and the Smoky Hill River, rendering the Smokey Hill River unusable. Several residents in the araa hava lost their domestic water wells due to tha salt pollution, and have lost trees and plants as a result of irrigating with the salty water.
Flora yes
Human Health lyes
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Violations State Reg

Compliance Issues
(OmNo UYes) at time oi damag
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In light.of tha acknowledged hazard associated with injection Into tha Hutchinson salt, the question arises as to why the KCC pmvided exemptions for the continued injection into the salt zone.
Documentation
Court Ordar from the Stata Corporation Commission of Kansas summarizing tha tastimony and decision on revoking all injection walls in the araa, D e c 8 , 1 9 8 3 .
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3-" g o> O o ? 52. _ . ^> n > -* I Case No. KS04 Description of Operation: These were short term exemptions given to 4-5 operators after a review by the Oil and Gas Advisory Committee solely to enable them to find alternative disposal facilities. Although injection of brine into this formation could contribute to subsidence, it should be remembered that this is also a natural phenomenon in this area. Brine injection has contributed to this result and should not be considered the sole cause. These were short term exemptions to allow 4-5 operators to find alternative disposal arrangements. There is presently no injection of brine into the Hutchinson salt.
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Damage Description: Compliance Issues:
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Production Area Northeast Kansas (basin, region,etc.) (oil, gaa, injection well, etc) (exploration, development, production, or other)
Production Type oil Production Category Development
Description of Operation Between Fabruary 9 and 2 7 , the Elllott1 w a s drilled on the property o f Mr. Lawrence K o e h l i n g . While drilling, the Hutchinson Salt member was penetrated, dissolving 100-200 cubic feet of salt which was disposed of in the reserve pit. The reserve pit lies 200 feet away from a well used by Mr. Koehling for his ranching operations. Within a few weeks of the drilling of the EH'ntt 0 1 , Mr. Koehling's nearby well began to pump water containing the saltwater drilling fluid. Aa confirmed by the K C C , the saltwater plume would eventually pollute t h e Koehling's domestic water well and the water walla on a farmstead over a mile dqwnstream. The drilling company was not fined for pollution of groundwater, and Mr. Koehling received no compensation for damages sustained.

Pathway of Contamination fe'-X:. (yes/no) Ground Water [yes Surf. Water Soil (reserve, holding or emergency pit; tank, well, battery; spill; injection well; btowdown, etc.) (mud, brine, produced water, workover fluid, frac fluid, etc.) (describe nature of available analysis, cite key numbers if available)
Damage Source Seepage of drilling pit fluids into freshwater aquifer. Drilling fluids contained high levels of salts. Area! Extent Waste Stream Drilling pit fluids and salts
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Waste Analysis Water smplea from the Koehling Ifves^pdk waterji^M show chloride concentrations of 900 900 and 950pfo m . Background cjMdsntrationslwf chloride would b e in the range o f 9 5 0 pfo 100-150ppm.
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Affected Biota (yes/no) Fauna Damage Due to the seepage o f reserve pit fluids containing high levels o f salt, the groundwater on the Koehling ranch has Description been polluted with salts, chlorides reaching 950ppm in the freshwatar aquifar. It i s antlcipatod b y the KCC that the saltwater plume will continue moving, thus polluting the Koehling domestic water well and the water well utilized b y a farmstead over one m i l e d o w n s t r e a m f r o m the K o e h l i n g ranch. I t i s a l s o stated b y the KCC that other walls drilled in the area w o u l d have s i m i l a r l y affected tha groundwater.
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(0<*No UYM) at tint* at da/nag
Compliance Migration o f drilling p i t fluids containing contaminants has bean documented i n this area. Uning o f reserve p i t s is. Issues n o t required, thus there i s n o fin* or penalty levied against an oil and gas operator for p o l l u t i o n o f tha g r o u n d w a t e r I n this area. There i s n o m e c h a n i s m o t h e r than a private l a w s u i t for the r e c o v e r y o f damages o n the part of private landowners.
Documentation S u m m a r y Report, K o e h l i n g Water Well P o l l u t i o n , 22-10-1SW, KCC C o n s e r v a t i o n Div., J i m S c h o o f , C h i e f Engineer. Nov. 1966.
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Damage Source:
Subsequent investigation has indicated that the specific pit referred to in this case was not the source of this pollution. KDHE installed two monitoring wells (one at SE corner of the pit and one 100 f e e t downstream). Samples from t h e well at the pit were analyzed at about 60 ppm chlorides. The other well sample analyzed at 750 ppm chlorides, therefore, other potential sources are being investigated (all injection and disposal wells in the vicinity have passed MIT's and all lines have passed pressure tests at 100 psi). The KDHE reports that the Koehling's well was not completed i n a manner that prevents surface contaminants from entering the well bore. There is suspicion that microbial contamination (there is a cattle pen in the area) is the real health threat in this case and that other old pits and brine spills could be contribution to the problem. KCC is continuing to work with the KDHE in investigating this case.
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Compliance Issues:
Lining of reserve pits is being addressed by the KCC (see comments attached to KS03 covering surface pond regulations in Kansas). The comment concerning recovery of damages is true for all regulating agencies at local, State and Federal levels. Further, it has no relevance to the objective of this study. Memo from M . Larson (KDHE geologist)dated March 2 0 1 , 1987 concludes that "...the pit is not the source".
Documentation:
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(oil, gas, injection well, etc.) (exploration, development, production, or other)
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Description of Operation On July 12,1931, the Topeka KDHE received a complaint from Albert Richmaiar, a landowner operating an irrigation well in the South Solomon River valley. His irrigation well had encountered salty water. An irrigation well belonging to a n adjacent landowner, L. M. Paxson, had become salty in the fall of 1980. Oil has bean produced in the area since 1952, a n d since 1962, secondary recovery has been used. Upon investigation by the Kansas Department of Health and the Environment(KDHE), it was discovered that the cause of the pollution was a saltwater injection well. Upon receipt o f the saltwater complaint, a casing profile caliper log w a s run which revealed numerous holes in the casing of the injection well. T h e producing formation, the Kansas City-Lansing, requires a s much a s 9 0 0 psi at the wellhead to inject the brine to create a profitable enhanced oil recovery project. After attempts at repair, the operator, Petro-lowis, decided to plug the well.
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(reserve, holding or emergency pit: tank, well, battery; spill; injection well; blowdown, etc.) (mud, brine, produced water, workover fluid, frac fluid, etc.) (describe nature of available analysis, cite key numbers if available)
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Damage Source Saltwater pollution o f groundwater aquifer due to casing holes in injection well operating at up to 800 psi. ttV* Area! Extent c
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brine
Waste Analysis Piichmeier and Paxson wells snow CI cone at over 6000 mg/l and 4700 mg/l respectively i n 7 / 8 1 . As wells w h e r e pumped, the C I cone, decreased.
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Injection wall used in secondary recovery process (Madden-Davis #2) contaminated two water wells used for irrigation. Casing of injection well was found to be full of hales.
Violations Stat* Rags. | Compliance Issues NA
oi (0-No UYes) at time oldamage
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Documentation
Blackburn G., Bryson W.G. 1983. Rtehmeier Pollution Study, Sec. 16 TWP 9S Range 25W. Kansas Ospt. of Health and Environment, Division of Envirnment, Topeka KS.
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Case No. KS06 Description of Operation:
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Waste Analysis:
As of March, 1987 the levels were down to the point that some of the irrigation wells have been retuned to service.
Compliance Issues:
The UIC program was put in place in 1984 in Kansas. Mechanical Integrity testing under this program would have caught this casing leak and minimized the environmental damage. March 1 7 , 1987 letter from M . Larson ( K D H E geologist) to Keith Reavis of Groundwater Management Division #4 gives information indicating the remediation effort is showing success.
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Production Area Southeastern Kansas (basin, region, etc) (oil, gaa, injection well, etc.) (exploration, development, production, or other)
Production Type o i l Production Category Description of Operation production
On inspection by the Joint Oil and Gas Regulatory Office, the George Loase in Woodson County was found to h a v e a n unpermitted e m e r g e n c y pond full of oilfield brine which overflowed into a field a n d tributary of t h e Neosho River 2 0 0 feet from the tanK battery on site. A saltwater tank had overflowed causing tha emergency pit to fill. The operator was contacted on Nov. S, 1985 and asked to stop the flow from the tank into the pond, and ampty the pond within 10 days. O n Nov. 28, the tank was not overflowing, but the emergency pit was still full of fluid. The operators were again contacted. On January 2 . 1 9 8 6 , the lease was again inspected and the pit was Still full of saltwater. O n Feb. 1 4 , 1 9 8 6 , a $ 5 0 0 penalty w a s assessed against the operator ( t r i a d Projects), and it was ordered that the pit b e closed and property abandoned.
Daacrfpttan of Waste and Damage Pathway of Contamination (yes/no) Ground Water Surf. Wafer y e s So yes (reserve, holding or emergency pit: tank, wall, battery; spill: injection well: blowdown, etc.) (mud, brine, produced water, woikover fluid, trac fluid, etc.) (describe nature of available analysis, cite key numbers if available)
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Damage Source Saltwater pollution of soil and surface water due to runoff from saltwater tank a n d overflow of illegal emergency p i t ^tT^>
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Waste Stream Oilfield brine
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':'y."-.CiS| Waste Analysis Water samples from the pit and brine tanks showed CI cone, ranging from 2 2 , 0 0 0 to 26,500 ppm.
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Oilfield brine from the saltwater tank and illegal emergency pit flowed over an adjacent field and into the Neosho River, 200 feet away. The Kansas Department of Health and Environment found that the overflow of oilfield brines and the use of the emergency pond has caused and is likely to cause pollution to the soil and waters of the state.
Vw/atwnjSfafeflegs.l-~T| Complanca Issues
(O-NoUYea)attimaofdamsga
Unwillingness of oil and gas operator to comply with state rules and regulations governing oil and gas operations.
Documentation
Letters from lawyers for the Tried Projects to the Oept of Health and Environment about an appeal from their decision and payment of penalty. Letters from the KS Oept. of Heaith and Environment stating case against me Triad Projects. Court Order Assessing a Civil Penalty, from the Oept of Health and Environment.
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Compliance Issues:
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As a result of the new KCC Surface Pond Regulations (see comments attached to KS03) all new applications for pits requires an on-site inspection as part of the permit procedure.
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Production Area Production Type Production Category Southeastern Kansas oil production (basin, regbn.etc.)
(oil, gat, injection well, etc) (exploration, development production, or other)
Description of Operation On January 3 1 , 1986, the Kansas Department of Health and the Environment inspected the Rate lease in Montgomery County, operated by Marvin Harr of El Dorado, Arkansas. The lease contained ah unpermitted amergancy pond, containing water which had 56,500ppm chlorides. A large leaking area was observed on the south side of the pond, allowing the flow of salt water down the slope for about 30 feet The company was notified and asked to apply for a permit and install a liner as the pond ws constructed of sandy clay and sandstone. The operator was directed to immediately empty thepond and backfill if a, liner were not in stalled. On Feb.'24 the lease was reinspected and tha emergency pond waa still full and actively leaking. It appeared that the lease had been shut down. A 'pond order* was issued requiring the company to drain and fill the pond. On April 2 9 , the pond waa still full and leaking. A fine of $ 5 0 0 w a s imposed and i t w a a ordered that the pond b e drained and filled.
Description of waste and Damage

Pathway of Contamination (yea/no) Groundwater
Damage Source Leakage from illegal amorgeney pit containing oilfield brine, chloride concentrations of (reserve, holding orup to SS.OOOppm. p-|^5 emergency pit: tank. Area! .* (?" well, battery; spill; .* injection well; 1 Extent &>yrt* biowdown, etc.) Waste Stream Oilfield brine
Surf. Water
So yes
Waste Analysis Water samples from pit show CI cone, from 30,500 ppm (4/29/S6) to 56,500 ppm (1/31/86). Leakage from the pit show CI cone, of 17,500 ppm (2/24/86).
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Damage Tha Kansas Department o f Health and the Environment statad that '...the usa o f tha pond,...has causad o r i s Description l i k o r y t o causa pollution to tha soil and the waters o f tha State. Tha saltwatar pond causad salt pollution ol tha soil around tha production site as tha pond was leaking water containing 17,000ppm chlorides onto the soil.
Violations Slato Raga
(OmNo ImYaa) at tsma of demaig
CompSanea Unwillingness of oil and gas operator to comply with stata rules and regulations governing oil and gas operations. Issues In this casa, tha operator apparently chosa to shut down production and abandon the site rathar than comply with Kansas rules and regulations applying to oil and gas activitiaa.
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Documentation KOHE Ordar assessing civil penalty, in the matter of Marvin Harr, Casa No. 88-E-77, Juna 10,1988. *Pond Order* issued by KDHE, in tha matter of Marvin Harr, Case No. 88-PO-008, March 2 1 , 1 9 8 6 .
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Case No. KS08 Compliance Issues: This was handled by the KDHE prior to full authority for oil and gas activities being given to the KCC (see Surface Pond Regulations - Kansas attached to KS03). KDHE never had authority to shutdown operations. The KCC does have the authority to revoke an operator's license.
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D c r 1 p t ion of Operation
Production Ana Production Type Production Category Central Kansas oil secondary recovery (bas/'r), region.ete.) (oi, gaa, injection weft etc.; (exploration, development production, or other)
Description ot Ogamse/i Ik ,6i j j t o l f and its predecessors began secondary flooding operations in tho East Gladys Unit i n Sedgwick CdtBnyrDuring secondary recovery, water is pumped into a target formation at high pressure, enhancing oil production. This pumping of water pressurizes the formation, allowing for brine to come to the surfaca through unplugged or improperly plugged abandoned wells. When Gulf began their secondary recovery in this area, it was with tha Knowledge that a number of abandoned wells existed and could lead to eeocapa of saltwater into groundwatar. Three improperly plugged wells in dose proximity to tho Gladys unit wars the source of groundwater pollution resulting in the destruction of fresh groundwater on tha preparty of G e r a l d Blood w h o runs a peach orchard in the area The saltwater forced up through tha pressuring of tha Gladys Moid flowed into tha unplugged walls and ime the groundwater below the surfaca. Salt water gradually migrated Into tha groundwater from which he draws irrigation water and water for his residence.
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Description ot Wasts and D a m a g e

Pathway ot Contamination (yea/no) Ground Water yes Surf. Water Soti yes (reserve, holding or emergency pit; rank, weH, battery; spill; injection weU; btowdown. etc.) (mud, brine, produced water, workover fluid, frac fluid, etc.)
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Damage Source Secondary recovery project pumpad water into the Miasissippian formation, pressuring the formation and forcing brine up into improporly plugged abandoned AreaJ wells. The brine then flowed into the groundwater table below tho surface, polluting the Extent groundwater with saltwater. ^tTT^ f*>fH ** Waste Stream brine
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Waste Analysis Water Vasptea tewa-weUs owned by Mr. Blood showed CI concentration of 9 7 7 and 755 (describe nature pprrt i r / l 92. j r r j 970, tha two walla showed C! concentrations of 1570 and 1730 mg/1 of available (Ppm>:. analysis, cite key numbers H available)
(barrels, gallons. etc.)
3/10/87
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Areal Extant 0319 0/ ':.!S NA ,971/Gerald Blood first discovered that he had a salt pollution problem in an irrigation
to rn
(acres)
Release
Duration Ongoing (yes/no) Fauna
El -
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Human He
Pollution of irrigation wells was first noted by Gerald Blood when (fal979â truck garden was killed by irrigation with salty water. As the pollution continued to migrate in the aqulferTifcontaminated two mora irrigation wells in the mid-197o's. By 1980, the pollution had contaminated the irrigation wells used to irrigate a whole section of Mr. Blood's land and adjacent landowners began to have saltwater pollution in their wells at this time. Mr. Blood lost a number of peach trees as a result of the contamination of his irrigation well, and lost the use of his domestic well.
Violation* $tata Regs. | CompSanee Issues
oi (OmNo 1mYes) at time of damage
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The Kansas Corporation Commission apparently doeanot provide aid to landowners who have suffered damages due to oil and gas activities, and the Bloods sued Gulf OH in civil court for damages. Tha Bloods won their suit for an unknown amount.
i*:
Documentation U.S. District Court for the district of Kansas, Memorandum and Order Blood vs. Gulf, Response to Defendants' Statement of Unoontroverted facta and Memorandum in Opposition to Motion for Summary Judgment. Means Laboratories, Inc. water sample results; Oept of Health, District Office #14. water samples results. Extensive miscellaneous memorandum, letters, analyais.
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Case No. KS1A Compliance Issues:
Aid to landowners who have suffered damages is not provided by any regulating agency. The mechanism for this is and has always been civil court. This situation could not occur today. The UIC program as implemented by the KCC would have precluded this occurrence through picking up abandoned wells in the area review process, requiring some pressure on the tubing/casing annulus and requiring periodic MIT's.
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Production Ana Production Type Production Category Central Kansas oil Production i&as/n, region,ate.) (oil, gaa, injaction waU, ate) (exploration, development, production, or other)
Description of Operation In September 1985, the Equus Beds Groundwater Management District performed an inspection of the McBurney Lease operated by Plains Oil Company in Harvey County after receiving a complaint about operations on the lease. The sits was found to contain an unlined saltwater holding pit which contained about four feet of saltwater. An injection well on the sits was found to be leaking salt water to the surface. The fiberglass holding tanks were covered with saltwater and oil. A flow was observed coming out of the fiberglass tank. Saltwater was found standing in tire tracks on the field road. Soil was infiltrated with oilfield brine up to 150 feat from the holding tank.- ft was found that an MIT test hod not been conducted on the injection well. Groundwater in this area is 20-30 feet below the-surfasa and brine left in a pit for a period or time or habitually spilled could infiltrate into the unconsolidated aquifer.
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Pathway of Contamination (yea/no) Ground Water Surf. Water Soal (reserve, holding or emergency pit; tank. waU, battery; spill; injection wail: biowdown, etc.) (mud, brina, produced water, wotkovar fluid, frac fluid, etc.) (describe natura of available analyaia, cite key numbers 1 available)
VS.
Damage Source Saltwater and o H spills from leaking injection well and possible brine contamination of groundwater due to use of unlined brine disposal pit 20-30 feet above groundwater. Area! Extent _ *n/T5 Waste Stream Brine and oil.
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Waate Analyaia Water sample from unlined brine disposal pit showed specific conductance of 43,680 (imhea/cm. Analysis on pit water<>chloridea18400mg/t, sodlum-8964mg/1. ammonia7.5mg/1
NA
(barrels; gallons. etc.)
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AraaJ Extant NA Oafeor" NA Release Duration NA
(acraa) (reiease may be ongoing, recently reported, etc.) (comment aa needed
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Atlected Biota (yes/no) Fauna Damage Brine tank was (raquantly allowed to overflow, killing vegetation i n an area extending 150 ft. Brine spills were Description c o n t a i n e d i n an u n l l n a d brine pit, creating the potential f o r brine contamination o f the fresh water a q u i f e r 20-30 feet below the pit
flora yes
Human Healt
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Violations State. Reg
(OwNo UYea) at time of damage
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Compliance In using an unapproved, unllned pit for saltwatar disposal, operator shows w U H u l disregard for rules and laauea r e g u l a t i o n a governing oil and gaa activities In Kansas. On follow-up investigation, it was noted that the p i t h a d been p u m p e d down, r e m o v i n g all b u t a small p o r t i o n o f the saltwater. Tha injection'wait wacsubsequently tested, and passed tha state tast.
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Documentation Equis Beds Goundwatar Management District #2. 313 Spruce, Heistoed, KS 67056-1925. (316) 335-2224. Latter to Warren Kirkpatriek, Joint Oil and Gas Regulatory Agency explaining the McSumey Lease Watar Quality Complaint. Joint Oil and Gaa Regulatory Agency, Olst. #2 3244 E. Oouglaa, Wichata, K S 67208. letter t o E q u i s B e d s Goundwatar Management D i s t r i c t * 2 a b o u t the McSumey Lease complaint Water analysis and MIT results.
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Case No. KS17 Damage Source: Since the injection well subsequently passed the MIT only the surface facilities could have been the damage source.
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3 rtWaste Analysis: This was probably an emergency pit that was being used in a manner that violates regulations - not a disposal pit.
Damage Description:
"Potential for brine contamination of the fresh water aquifer" does not represent documented damage.
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1

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Description of Waste and Damage

Damage Source Saltwater disposal well - gravity wall

Anal Extent Waste Stream Brine

(descnoe nature of available analysis, eHe key numbers I available)

Waste Volume Approximately 28.000 fcs. of total salt Released

(barrels, gallons, etc.)

NA May < August 1078

Data/ ffefame Duration

Four months (yo&too)

3 c+ E" 5 co =r 75- 3 3 co w p>

Description of Waste and Damage

Damage Sourtso iffld-ga*-wfl* Anal Extent ^

Waste Stream -Grilling mud, owns, freeing fluid. (Not-speaifie

Watte Analysis Nona?

p - . ' '. :>'.!?-'.,. y-.^J fc:;%-:

Waste Volume NA Released

(barrels, gallons, etc.)

Anal Extant NA Ctfso/ Lata 1981

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Wg/atfons Statu Rags. I

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Production Typo 0 8 Production Category Production

r , ^O0 _ .a-v, _ X TUT.

Doscriptton of Waste and Damaga

Damage Source Discharge of brine Into surface stream.

Arasl Extent Waste Stream Brine.

Waste Analysis NA - Stream below discharge tasted very saky.*

L e u than one h o u r . (yes/no) Faun

<3s " r Y i ' m e r . -H>e

Violations State Regs.|

l i (B-rVo fV*;fit fern*ofdama r . /i "i o

CompBanea - W f i W t r f - d t e a n a f B O af brine and oil Into a u r f s i e i i i abeam. ' ' Issues

S+reau*. polfuTiiJ*. TKft S+reau*. po

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Oscr1ptlon of Operation Production An* Appalachian Basi

Pmdu&lon Typ* NA Production Category Development Description o Operation

Damage Source Reserve pit Amal Extent Waste Stream D r i U i n WcWilr1

(describe nature of available analysis, dte key numbers If available)

Waste Volume Six to eight vacuum truckloads! U*wA>tr} Released

.ti. c i r ' . i V ' 1*3

Volitions Stof Roga. \Qjf\

(CNo UYat) at time a/dsmaga

Ca^c ^ 4^e. Ouvrt>N^ ^ t r i

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Reotbn Proof Category

Description of Oporatton Production Ana Appalachian Basin

Production Typa Oil/gas Production Category Production

(oM, gas, injection wet, ete.) (exploration, development, production, or other)

Description of w a s t a and Damaqa Pathway or Contamination (yes/no) Ground Water

Waste Volume H A Released

(barrels, gallons, etc.)

Damage Sourtso iffld-ga-wfl Anal Extent ^

l i (B-rVo fV;fit fernofdama r . /i "i o

S+reau. polfuTiiJ. TKft S+reau*. po

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CompEanea tawo-Na-raquiremewta fat1 construction cfwBroada<iniifpredt>atonilaa'lwWwi Vi^iwici -

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