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A Hazy Future Report Cover

A Hazy Future: Pennsylvania’s Energy Landscape in 2045

Report Calculates Impacts from PA’s Planned Natural Gas Infrastructure

FracTracker Alliance released the report: A Hazy Future: Pennsylvania’s Energy Landscape in 2045 today, which details the potential future impacts of a massive buildout of Marcellus Shale wells and associated natural gas infrastructure.

Industry analysts forecast 47,600 new unconventional oil and gas wells may be drilled in Pennsylvania by 2045, fueling new natural gas power plants and petrochemical facilities in PA and beyond. Based on industry projections and current rates of consumption, FracTracker – a national data-driven non-profit – estimates the buildout would require 583 billion gallons of fresh water, 386 million tons of sand, 798,000 acres of land, 131 billion gallons of liquid waste, 45 million tons of solid waste, and more than 323 million truck trips to drilling sites.

A Hazy Future - Impact Summary

“Only 1,801 of the 10,851 unconventional wells already drilled count as a part of this projection, meaning we could see an additional 45,799 such wells in the coming decades,” commented Matt Kelso, Manager of Data and Technology for FracTracker and lead author on the report.

Why the push for so much more drilling? Out of state – and out of country – transport is the outlet for surplus production.

“The oil and gas industry overstates the need for more hydrocarbons,” asserted FracTracker Alliance’s Executive Director, Brook Lenker. “While other countries and states are focusing more on renewables, PA seems resolute to increase its fossil fuel portfolio.”

The report determined that the projected cleared land for well pads and pipelines into the year 2045 could support solar power generation for 285 million homes, more than double the number that exist in the U.S.

A Hazy Future shows that a fossil fuel-based future for Pennsylvania would come at the expense of its communities’ health, clean air, water and land. It makes clear that a dirty energy future is unnecessary,” said Earthworks’ Pennsylvania Field Advocate, Leann Leiter. Earthworks endorsed FracTracker’s report. She continued, “I hope Governor Wolf reads this and makes the right choices for all Pennsylvanians present and future.”

A Hazy Future reviews the current state of energy demand and use in Pennsylvania, calculates the footprint of industry projections of the proposed buildout, and assesses what that would look like for residents of the Commonwealth.

About FracTracker Alliance

Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is a national organization with regional offices across the United States in Pennsylvania, the District of Columbia, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional, and national level, informing their actions to positively shape our nation’s energy future.

Questions? Email us: info@fractracker.org.

Radium Watersheds a Risk

By Greg Pace – Columbus Community Bill of Rights, and Julie Weatherington-Rice – Environmental Consultant

columbus_classiimap

Figure 1. Map of Columbus, OH Watersheds and Class II Injection Wells

Most Ohio residents are unaware of the frack fluid deep underground injection occurring north of Columbus, underneath the region’s source water protection watersheds (Figure 1).

Materials injected are liquids that have as much as ten times the salt concentration of sea-water. Mixed with this “brine” solution is a combination from hundreds of chemicals that are used in different stages of horizontal hydraulic fracturing, the process used to extract natural gas, petroleum, and hydrocarbon liquids used to make industrial materials such as plastics. BTEX compounds including benzene are always present in the wastewater, along with formaldehyde, bromides, ethylene glycol (antifreeze), and arsenic, with many other carcinogenic and otherwise highly-toxic substances.

Radioactivity of Shale Gas Wastewater

One of the biggest questions in this mix of toxic disposal is how much radioactive content exists. Radium-226 is most worrisome, as it has a very long half-life (1,600 years). It is water-soluble and, once it enters the human body, seeks to find a home in our bones where it will emit its cell-formation-destabilizing effects for the remainder of our lifetime. This radionuclide is known to cause leukemia, bone cancers, blood disorders, and other diseases.

The state of Ohio does not monitor the content of materials that are injected into our Class II injection wells deep in the ground. This oil and gas waste can come from anywhere, including Pennsylvania’s Marcellus shale, which is the most highly-radioactive geology of all the shale plays in the country. Radium-226 readings as high as 15,000 pico-curies per liter have been read in Marcellus shale brines. The EPA drinking water limit for radium-226 is 5 pico-curies per liter, which puts the Marcellus reading at 3,000 times higher than the drinking water limit.

Exposure through drinking water is a pathway to human disease from radium-226. Once oil and gas waste is disposed of underground in a sandstone or limestone layer, the fluids are subject to down-gradient movement, wicking through capillary action, and seepage over time. This means that the highly radioactive wastewater could eventually end up in our underground drinking water sources, creating radium watersheds. This practice is putting our watersheds at risk from radioactive contamination for hundreds of years, at least.

Can injected fluids migrate?

Depending on whether you confer with a geologist who works with the oil and gas industry, or from an independent geologist, you will get a different opinion on the likelihood of such a pollution event occurring. Industry geologists mostly claim that deep injection leaves very low risk of water contamination because it will not migrate from the planned area of injection. On the other hand, independent geologists will tell you that it is not a matter of if the liquids will migrate, but how and when. The ability to confirm the geology of the underground area layer of injection “storage” is not exact, therefore accuracy in determining the probability for migration over time is poor.

Figure 2. Ohio Utica Brine Production and Class II Injection Well Disposal
View Map Fullscreen | How FracTracker maps work

We do know, however, that all underground systems in Ohio leak – Research by The Ohio State University and the US Geological Survey show that the age of the water in brine formations is far younger than the age of the rock deposits they are found in. See where wastewater is being created and disposed of in Ohio using the dynamic map above (Figure 2).

Spill Risks to Columbus, OH Water

According to area geologist, Dr. Julie Weatherington-Rice, the source for Columbus’s water to the north is mostly from surface water. This water comes from the Delaware and Morrow county watersheds that feed into sources such as the Hoover and Alum Creek reservoirs. The major threat from injection wells to our watershed is from spills, either from trucks or from storage at the injection well sites themselves.

Dead fish floating in Vienna area pond contaminated by injection well system spill Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

Figure 3. Dead fish floating in Vienna area pond contaminated by injection well system spill. Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

In April 2015, as much as 8,000 gallons of liquid leaked from a malfunctioning pipe in the storage apparatus of an oil/gas waste storage and injection well site in Vienna, OH. This caused a wildlife kill in two ponds (Figure 3), and the spill was not contained until 2/3 mile downstream in a tributary. The firm who owned the facility was found negligent in that they did not install a required containment liner for spills. The incident was discovered by neighboring residents, but apparently employees knew of the leak weeks before. Of note in this incident was that Ohio Department of Natural Resources, the regulatory agency that oversees all oil/gas production activity in Ohio including injection, stated that there was “minimal impact to wildlife.”

Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

Figure 4. Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

In March, 2016, a tanker truck carrying produced waste from a hydraulically fractured well pad overturned outside of the Village of Barnesville, Ohio (Figure 4). The truck spilled 5,000 gallons of liquid waste into a field that led into a tributary, leading the fluids to enter one of the city’s three drinking water supply reservoirs. The water source was shut down for more than two months while regulators determined if water levels were safe for consumption. There was a noted spike in radium-226 levels during water testing immediately after the spill.

Of greatest concern is that, although many millions of gallons of frack waste have been injected into the wells north of Columbus over the past few years, we expect that this activity will increase. For the first time, the United States began exporting its own natural gas in 2016, to regions such as Europe and South America. As the industry consolidates from the depression of oil prices over the past two years and begins to ramp up again, we expect the extraction activity in the Marcellus and especially Utica to increase to levels beyond what we have seen since 2011. The levels of injection will inevitably follow, so that injection wells in Ohio will receive much more than in the past. The probability of spills, underground migration, and human-induced earthquakes may increase steeply, as well.

An Aging Disposal Infrastructure

On our Columbus Community Bill of Rights website, we show pictures of some of the Class II injection wells in Morrow County, most of them converted from legacy production wells. These old wells are located in played out oil/gas fields that may still be producing or have abandoned but not plugged (closed) wells, allowing other routes for injected liquids to migrate into shallow ground water and to the surface. The dilapidated condition of these converted Class II wells makes it hard to believe that they are used to inject millions of gallons of wastewater under high pressure. While many of the wells in the state are as deep as 9,000 feet, all of the injection wells we have seen in Morrow County are only 3,000-4,000 feet deep. This situation puts surface water at greater risk over time, as it is probable that, over the generations, some of the fluids will migrate and wick into the higher subterranean strata.

Figure 5. Ohio Class II Injection Wells by Type
View Map Fullscreen | How FracTracker maps work

One well (Power Fishburn unit, photo below) showed signs of poor spill control when we took our October 2015 injection well tour. While we were there, a brine tanker arrived and began pumping their load into the well. The driver took pictures of our license plates while we were there watching him. A year later, there is a whole new structure at the well, including a new storage tower, and an extensively beefed-up spill control berm. Maybe we need to visit all of the facilities when they come by to use them!

Another well (Mosher unit, photo below) which hadn’t been used since 2014 according to available records, showed signs of a spill around the well. The spill control berms look as if they probably had flooded at some point. This well sits on the edge of a large crop field.


Figures 6a and 6b. Photos of Class II injection wells. Click on the images to expand them.

North of Columbus, the city of Delaware’s underground source water is at risk of becoming contaminated from underground migration of disposed wastewater over time, through wicking and seepage effects (as explained earlier in this article). They are also vulnerable to their reservoir being contaminated from surface spill migration through their watershed.

Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

Figure 7. Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

South of Columbus is another threat – drill cuttings from the drilling process have been authorized for disposal at a “remediation” landfill adjacent to the Alum Creek (Figure 7). The bioremediation treatment used is not indicated to solve the problem of removing radionuclides from the materials. This landfill had been remediated under the Ohio EPA twice when it was a toxic drum dump, after toxins were found to have been leaching into the watershed creek. Columbus’s Alum Creek well, as well as Circleville, are at risk of contamination in their drinking water if radionuclides from the cuttings leach into Alum Creek. Again, this is a long-term legacy of risk to their water.

Radiation Regulatory and Monitoring Gaps

Since The Ohio legislature deemed the radioactive content of shale cuttings to be similar to background levels in the 2013 state budget bill, cuttings can be spread around to all licensed landfills in Ohio with absolutely no accountability for the radium and other heavy metal levels in them. Unfortunately, the measuring protocol used in the pilot study for the Columbus facility to demonstrate to Ohio EPA that radium-226 was below EPA drinking water limits has been shown in a University of Iowa study to be unreliable.  The inadequate protocol was shown to indicate as little as 1% of the radium levels in shale waste samples tested.

As such, there have been hundreds of incidents where truckloads of cuttings have been turned away at landfills with crude radiation monitors. In 2013 alone, 2 loads were turned away in Ohio landfills, and over 220 were turned away from Pennsylvania landfills.

Ohio has a long way to go before it can be considered a clean energy state. The coal industry polluted significant water sources in the past. The fracking industry seems to be following suit, where contaminations will surprise us long into the future and in broader areas.


Map Data for Download

Woody Biomass & Waste-To-Energy

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

While solar and wind energy gets much of the attention in renewable energy debates, various states are also leaning more and more on burning biomass and waste to reach renewable energy targets and mandates. As is the case with all sources of energy, these so-called “renewable energy” projects present a unique set of environmental and socioeconomic justice issues, as well as environmental costs and benefits. In an effort to document the geography of these active and proposed future projects, this article offers some analysis and a new map of waste and woody biomass-to-energy infrastructure across the U.S. with the maximum capacities of each facility.

 

Map of U.S. Facilities Generating Energy from Biomass and Waste

View map full screen to see map legend, additional layers, and bookmarks
How FracTracker maps work

Woody Biomass-to-Energy

To illustrate the problems of woody biomass-to-energy projects, one only needs to look at Michigan. Michigan’s growing practice of generating energy from the wood biomass relies on ten facilities that currently produce roughly 209 Megawatts (an average of 21 MW per facility) from 1.86 million tons of wood biomass (an average of 309,167 tons per facility). Based on our initial analysis this is equivalent to 71% of the wood and paper waste produced in Michigan.

Making matters worse, these ten facilities rely disproportionately on clearcutting 60-120 years old late successional northern Michigan hardwood and red pine forests. These parcels are often replanted with red pine and grown in highly managed, homogeneous 20-30 year rotations. Reliance on this type of feedstock stands in sharp contrast to many biomass-to-energy facilities nationally, which tend to utilize woody waste from urban centers. Although, to provide context to their needs, the area of forest required to service Michigan’s 1.86 million-ton demand is roughly 920 mi2. This is 1.65 times the area of Chicago, Milwaukee, Detroit, Cleveland, Buffalo, and Toronto combined.

 

Panorama of the Sunset Trail Road 30 Acre Biomass Clearcut, Kalkaska Conty, Michigan

 

Based on an analysis of 128 U.S. facilities, the typical woody biomass energy facility produces 0.01-0.58 kW, or an average of 0.13 kW per ton of woody biomass. A few examples of facilities in Michigan include Grayling Generating Station, Grayling County (36.2 MW Capacity and 400,000 TPY), Viking Energy of McBain, Missaukee County (17 MW Capacity and 225,000 TPY), and Cadillac Renewable Energy, Wexford County (34 MW Capacity and 400,000 TPY).

 

The relationship between wood processed and energy generated across all U.S. landfill waste-to-energy operations is represented in the figure below (note: data was log transformed to generate this relationship).

 

Waste-To-Energy

Dr. Jim Stewart at the University of the West in Rosemead, California, recently summarized the Greenhouse Gas (GHG) costs of waste landfill energy projects and a recent collaboration between the Sierra Club and International Brotherhood of Teamsters explored the dangers of privatizing waste-to-energy given that two companies, Waste Management and Republic Services/Allied Waste, are now a duopoly controlling all remaining U.S. landfill capacity (an additional Landfill Gas Fact Sheet from Energy Justice can be found here).

Their combined analysis tells us that, by harnessing and combusting landfill methane, the current inventory of ninety-three U.S. waste-to-energy facilities generate 5.3 MW of electricity per facility. Expanded exploitation of existing landfills could bring an additional 500 MW online and alleviate 21.12 million metric tons of CO2 pollution (based on reduction in fugitive methane, a potent greenhouse gas). Looking at this capacity from a different angle, approximately 0.027 MW of electricity is generated per ton of waste processed, or 1.64 MW per acre. If we assume the average American produces 4.4 pounds of waste per day, we have the potential to produce roughly 6.9 million MW of energy from our annual waste outputs, or the equivalent energy demand created by 10.28 million Americans.

 

The relationship between waste processed per day and energy generated across all U.S. landfill waste-to-energy operations is represented in the figure below.

 

Conclusion

Waste burning and woody biomass-to-energy “renewable energy”projects come with their own sets of problems and benefits. FracTracker saw this firsthand when visiting Kalkaska County, Michigan, this past summer. There, the forestry industry has rebounded in response to several wood biomass-to-energy projects. While these projects may provide local economic opportunity, the industry has relied disproportionately on clearcutting, such as is seen in the below photograph of a 30-acre clearcut along Sunset Trail Road:

 

As states diversify their energy sources away from fossil fuels and seek to increase energy efficiency per unit of economic productivity, we will likely see more and more reliance on the above practices as “bridge fuel” energy sources. However, the term “renewable” needs parameterization in order to understand the true costs and benefits of the varying energy sources it presently encompasses. The sustainability of clearcutting practices in rural areas—and the analogous waste-to-energy projects in largely urban areas—deserves further scrutiny by forest health and other environmental experts. This will require additional mapping similar to what is offered in this article, as well as land-use analysis and the quantification of how these energy generation industries enhance or degrade ecosystem services. Of equal importance will be providing a better picture of whether or not these practices actually produce sustainable and well-paid jobs, as well as their water, waste, and land-use footprints relative to fossil fuels unconventional or otherwise.

 

Relevant Data

All US Waste-to-Energy Operations along with waste processed and energy produced (MW)

All US Woody Biomass-to-Energy Operations along with waste processed and energy produced (MW)

Landfill disposal of drill cuttings

Landfill Disposal of WV Oil and Gas Waste – A Report Review

By Bill Hughes, WV Community Liaison

As oil and gas drilling increases in West Virginia, the resulting waste stream must also be managed. House Bill 107 required the Secretary of the West Virginia Department of Environmental Protection to investigate the risks associated with landfill disposal of solid drilling waste. On July 1, 2015, a massive report was issued that details the investigation and its results: Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

While I must commend the State for looking into this important issue, much more needs to be done, and I have serious concerns about the validity of several aspects of this study. Since the report is almost 200 pages long, I will summarize its findings and my critiques below.

Summary of Waste Disposal Concerns in Report

The page numbers that I reference below refer to the page numbers found within the PDF version of the full study.

  1. Marcellus shale cuttings are radioactive: pgs. 17, 139, 142, 154
  2. We do not know if there is a long term problem: pg. 19
  3. About 30 million tons of waste in next few decades: pg. 176
  4. Landfill liners leak: pg. 20
  5. Owning & operating their own landfill would be expensive & risky for gas companies: pgs. 186-7
  6. Toxicity and biotic risk from drill cuttings is uncharted territory: pg. 78
  7. Landfill leachate is toxic to plants & invertebrates: pgs. 16, 95, 97
  8. Other landfills also have radioactive waste: pgs. 14-15
  9. We have no idea if this will get worse: pgs. 96, 154
  10. If all systems at landfills work as designed, leachate might not affect ground water: pg. 41

Introduction

WV Field Visits 2013

Drilling rig behind a wastewater pond in West Virginia

Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College – supported by over 2,300 pages of semi-raw data and graphs and charts and tables – requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide independent perspective and to help reflect on how sections of this report might be interpreted.

The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the legislature told the WV Department of Environmental Protection DEP to do. Secondly, the DEP then added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. The most constricting factor was the large body of existing data possessed by the DEP that was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.

And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency, do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing natural gas industry – which is supported by most in the political administration. Therefore, we must be cautious here. The presence and influence of political and economic factors need to be considered. Also, for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.

My comments below on the report’s methods and findings are organized into three broad and overlapping categories:

  • GOOD  –  positive aspects, good suggestions, important observations
  • GENERAL  –  general comments
  • FLAW  –  problems, flaws, limitations
  • MOVING FORWARD  – my suggestions & recommendations

I. Water Quality: EPA Test Protocols & Datasets

Marcellus Shale (at the surface)

Marcellus Shale (at the surface)

GENERAL  It is obvious that a very smart and well-trained set of researchers put a lot of long, detailed thought into analyzing all of the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all of the existing years’ worth of leachate chemical and radiological information.

GOOD  There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some non-detect values, and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and draw some conclusions.

FLAW 1  The most glaring flaw and the greatest limitation pertaining to the data sets is the nature of the very data set, which was provided to the researchers from the DEP. It is to the commendable credit of the DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill; that way we could keep track of where the drill cuttings are located when there are future problems.

To the best of my knowledge, until the states in the Marcellus region started allowing massive quantities of black shale waste material to be put into local landfills, we have never knowingly deposited large quantities of known radioactive industrial waste products into generic municipal waste landfills. The various waste products and drill cuttings of Marcellus black shales have been known for decades by geologists and radiochemists to be radioactive. We know better than to depose of hazardous radioactive waste in an improper way. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.

FLAW 2  All of the years of leachate test samples were processed for radioactivity using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem, we chose the wrong test protocol for assessing leachate samples. We speculated that the commonly used and familiar clean drinking water test procedure would work. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately, all of the chemistry test results should still be reasonably useful and accurate.

At first, three years ago, this was understandable and possibly not an intentional error. Now it is widely known by hydrogeologists and radiochemists, however, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high TDS — Total Dissolved Solids. Method 900.0 is designed for samples with low dissolved solid like finished drinking water supplies.

Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. It is clearly known now, however, that the protocols that were used for all samples from the start when testing for gross alpha, gross beta and radium-226 and radium-228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on several very important topics, including:

  • surface water quality,
  • potential ground water contamination,
  • exposure levels at landfills and public health implications,
  • and policy and regulations considerations.

Labs certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. These protocols are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations like flowback and produced water and brines and leachate. The required lab process for sample size, preparation, and testing will guarantee that the results will be incorrect.

In no place in the final 195 page report have I seen any discussion of which EPA test protocol was used for the newer samples and why was it used. It has also not yet been seen in the 2,300+ pages of supportive statistical and analytical results, either. The fact that the wrong protocol was used three years ago is very understandable. However, this conventional EPA 900 series was still being used on the additional very recent (done in fall of 2014 and spring of 2015) samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol.

The clean drinking water procedures should have been used along with the 901.1M (gamma spec) process, for comparison. It is understandable for the new data to be consistent and comparable with the very large existing dataset that a case could be made for using the incorrect protocol and the proper one also. There should have been a detailed discussion of what and why any test method was being used, however. That discussion is usually one of the first topics investigated and explained in the Methods section. Having that type of discussion and justification seems to represent a basic science method and accepted research process – and that omission is a serious flaw.

MOVING FORWARD  We all know that if we want to bake an appetizing and attractive cake we must use the correct measuring cups for the ingredients. If we want to take our child’s temperature we need an accurate thermometer. When our doctor helps us understand our blood test results, we all want to be confident the right test was used at the lab. The proper test instrument, recently calibrated and designed for the specific sample, is crucial to get useable test results from which conclusions can be drawn and policy enacted.

It seems that the best suggestion so far to test high TDS liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium instrument with at least a 21-day hold period (30 days are better), while the sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties that might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. Radon 222 (a gas) must not be allowed to escape.

The potential environmental impacts to water quality section of this report seems to demonstrate that if you do not want to find out something, there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some the Marshall University folks did not seem to have the option to stray into important scientific foundational assumptions and, for the most part, just had to work with the stale data sets given to them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results of limited value.

II. Marcellus is Radioactive

GOOD 1  Of course, geologists have known that the Marcellus Shale is radioactive for many decades, but also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge this fact to the public. And finally we now have a public report that clearly and unambiguously states that Marcellus shale is radioactive. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be echoing the industry’s intentional deception by declaring that:

…it was only dirt and rock…

So this report represents progress and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.

GOOD 2  Another very important advance is that finally after eight years of drilling here in Wetzel County, we now have a test sample from near the horizontal bore. The WVU WRI study researchers were never given access to any samples taken from the horizontal bore material itself, however. That was, of course, what they were supposed to have been allowed to do, but they were only given access to study material from the vertical section of the well bore. This report describes how we are getting closer to actually testing good samples of the black shale. It seems that we have gotten closer – but let’s see how close.

Page 11 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1,000 deviated/horizontal wells or wells with laterals have been drilled in the past few years, that number represents a very small fraction of wells drilled: less than .3%. Even if a high quality sample could have been obtained it might be a challenge to extrapolate test results to the waste being produced from the other wells in WV. These limitations are completely ignored in the report, however. Given the available documentation from the DEP, this seems to be a serious flaw that compromises the reliability of the entire report.

III. Samples From Vertical vs. Horizontal Well Bores

FLAW  The actual samples tested from at least two of the three wells used in the study do not seem to be from the horizontal bore material. The sample from the third well might have come from the horizontal bore, but just barely. There is no way to know for sure. I will try to show this within the below chart using information provided by Antero to DEP Office of Oil & Gas. This information is in state records on Antero’s well plats, which become part of the well work application and also part of the final permit.

Table 1. Details about the samples taken from three Antero wells in Doddridge County, WV – and my concerns about the sampling process*

Antero well ID API # Sample’s drilling depth Marcellus depth** Horizontal bore length** Comments / Issues
Morton 1H 47-017-06559 6,856 ft. 7,900 TVD*** 10,600 ft. ~1,044 ft. short of reaching Marcellus formation
McGee 2H 47-017-06622 6,506 ft. 6,900 TVD 8,652 ft. ~394 ft. short of reaching Marcellus
Wentz1 H 47-017-06476 8,119 ft. 7,900 TVD 8,300 ft. Just drilled into Marcellus by 219 ft.
* Original chart found on page 11 of report
** Based on information from Antero’s well plat
*** TVD = Total Vertical Depth

Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. Well plats are very detailed, technical documents provided to the DEP by the operator regarding the well location, watershed, and leased acres and property boundaries. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats also give the depth of the Marcellus and the length and heading of the lateral or horizontal bore. The Marshall University report gives the drilling depth when the sample was taken on the surface. Using these available well plat records from the DEP it appears that at two of the wells the sample (and its test results included in the report) came from material produced when the experienced drilling operator was not yet into the shale formation.

On the third well, Wentz 1H, the numbers seem to indicate that the sample was taken when the driller said that they were just barely within the shale layer – by 219 feet. Since the drill cuttings take some time to return to the surface from over 7,000 feet down, drilling just a few hundred feet would not at all guarantee that the returned cuttings were totally from the black shale. The processing of the drill cuttings at the shaker table and separator and centrifuge and the mixing in the tubs all cast some doubt on whether the sample, wherever it was taken from, was truly from the horizontal bore material.

On page 11 there is a clear and unambiguous statement:

Three representative sets of drill cuttings from the horizontal drilling activities within the Marcellus Shale formation were collected.

A successful attempt to get three such samples might have then allowed an appropriate waste characterization to be done as needed to accomplish the five required research topics listed in the report’s cover letter. Only an accurate chemical and radiological waste characterization would have allowed scientifically justifiable conclusions to be formulated and then allow for accurate legislation and regulations. It does not seem that West Virginia yet has the required scientific data upon which to confidently formulate laws and regulations to protect public health with regard to shale waste disposal.

Would it not seem prudent – if one wanted a good, representative sample – to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings returning to the surface were, in fact, from the Marcellus bore? That approach would have been eminently defensible and easily accomplished by just waiting for drilling to progress into the lateral bore far enough that the drill cuttings returning to the surface were in fact from the black shale. There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero-provided information on the well plats is incorrect and not intended to be accurate, or perhaps the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.

IV. Research Observations Review

Landfill disposal of drill cuttings

Landfill disposal of drill cuttings

GOOD There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these proposals are very accurate and should be implemented. For example:

The report clearly restates that drill cuttings are known to contain radioactive compounds. Since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the well samples should be tested for radiological isotopes. Good idea. They are not required to do that now, but this recommendation should be implemented immediately (pgs. 17 and 21).

GOOD The report recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site wastewater treatment plants, should also test their effluent for radioactive isotopes. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. Such contaminants will pass through traditional wastewater treatment plants.

It is also very useful that the report recommends that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and required to take into consideration the significantly more challenging chemical and radiological makeup of the shale waste products.

V. Economic Considerations on an Industry Supported Mono-Fill

The legislature asked that the DEP evaluate the feasibility of the natural gas industry to build, own, or operate its own landfill solely for the disposal of the known radioactive waste. This request seems to be a very reasonable approach, since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of the special waste material.

The discussion of the economic considerations is extremely complete and detailed. They are given in Appendix I and take into consideration a very thorough economic feasibility study of such a proposed endeavor. This section seems to have been compiled by a very talented professional team.

FLAW  However, some of the basic assumptions are a bit askew. For example:

The initial Abstract of the financial analysis states that two new landfills would be needed because we do not want to have the well operators to drive any further than they do now. Interesting. This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Homebuilders in rural settings should know they will have to incur expenses for their waste disposal needs. Should gas companies expect that communities to provide cheap waste disposal for them?

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

Comprehensive and sound financial details later explain that having the natural gas operators build, operate, and eventually close their own radioactive waste depository landfill would involve a lot of their capital and involve some risk to them. It is stated that their money would be better used drilling more wells. The conclusion then seems to be that, all around, it is simply cheaper and less risky for the gas industry to put all their waste products into our Municipal Waste Landfills, and later residents should incur the costs and risk to build another land fill for their household garbage when needed.

VI. Report Omissions

  1. Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do, as well. However, rather than raising a very red flag and expressing concern over a problem that no one has looked into, the report implies we should not worry about any radioactive waste because it might be in all landfills (pg. 139).
  2. Nowhere within the radiological discussion is there any mention of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure.” The speciation process is sort of a slice and dice procedure, showing exactly what isotopes are responsible for the activity that is being indicated. This process, however, does not seem to have been done on the landfill leachate test samples. The general scanning process cannot do that. Appendix H, pages 141-142, contains detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used, and why.
  3. A short discussion of the DEP-required landfill entrance radiation monitors is included on page 146. The installed monitors are the goalpost type. Trucks drive between them at the entrance and when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high-energy gamma radiation. However what is omitted on page 144 is that the primary form of decay for radium-226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium-226 include both alpha particles and some gamma radiation, but radium-266 is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings. However those monitors are still useful since they will detect the high-energy gamma radiation from a truck carrying a lot of medical waste (pg. 17).
  4. It is stated on page 144 that the greatest health risk due to the presence of radium-226 is the fact that its daughter product is radon-222. Radium-226 has a half-life of 1,600 years, compared to radon’s 3.8 days. This difference might seem to imply that radon is less of a concern. Given the multitude of radium-226 going into our landfills means that we will be producing radon for a very long time.

VII. Resource Referenced in Article

Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

Name that oil and gas storage container [quiz]

By Bill Hughes, WV Community Liaison

We were recently asked if there is a reliable way to determine what constituents are being housed in certain types of oil and gas storage containers. While there is not typically a simple and straightforward response to questions like this, some times we can provide educated guesses based on a few photos, placards, or a trip to the site.

One way to become better informed is to follow the trucks. The origins of the trucks will determine whether the current stage in the extraction process is drilling or fracturing (the containers cannot be for both unless they are delivering fresh water). Combine that with good side-view photos of the trucks will tell you if they are heavier going into the site or heavier leaving. Look for the clearance between the rear tires and the frame. Tanker trucks can typically carry 4000 gallons or 100 barrels.

For a quick guide to oil and gas storage containers, see the “quiz” we have compiled below:

Storage Container Quiz

1. What is in this yellow tank?

Photo 1

Q1: Photo 1

Q1: Photo 2 (same tank zoomed in)

Answer: This yellow 500-barrel wheelie storage tank in photos 1 and 2 is a portable storage tank, identified in the placard in photo 2 as having held oil base drill mud at one time. Drillers prefer to keep certain tanks identified for specific purposes if at all possible. This is especially true if they have paid extra to get a tank “certified clean” to use for fresh water storage. A certified clean tank does not mean that the water is potable (drinkable).

Other storage containers that hold fresh water are shown below:

Shark Tanks

Shark Tanks

Shark Tanks

Shark Tanks from the sky

2. What is this truck transporting?

Q2: Truck

Q2: Truck

Answer: This type of truck is normally used to haul solid waste – such as drill cuttings going to a landfill. Some trucks, however do not make it the whole way to the landfill before losing some of their contents as shown below.

Truck-spill

Truck spill in WV

3. How about these yellow tanks?

Q3: Photo 1

Q3: Photo 1

Q3: Photo 2

Q3: Photo 2

Answer: The above storage containers are 500-barrel liquid storage tanks, also called “frac” tanks.

In photo 2 you can see that at least one tank is connected to others on either side of it. In this case you need to look at the overall operation to see what process is occurring nearby — or what had just finished — to determine what might be in the container presently.

The name plate on photo 1 says “drill mud,” which means that at one time that container might have held exactly that. Now, however, that container would likely have very little to do with drilling waste or drill cuttings. The “GP” and the number on the sign refers to Great Plains and the tank’s number. These type of tanks do not have official placards on them for the purposes of DOT labeling since they are never moved with any significant liquid in them.

4: What about these miscellaneous tanks?

Q4: Photo 1 – Tank farm with 103 blue tanks

Q4: Photo 2 – Red tanks with connecting hoses

Q4: Photo 3 – Red tanks, no connections

Answer: There is no way to know – unless you have been closely following the process in your neighborhood and know the current stage of the well pad’s drilling process. Tank farms are usually just for storage unless there is some type of filtering and processing equipment on site. The drilling crews (for either horizontal or vertical wells) do not mix their fluids with the fracturing crew. That does not mean that one tank farm could not store a selection of flowback brine—or produced water, or drilling fluids. They would be stored in separate tanks or tank groups that are connected together – usually with flex hoses.

Since I am in the area often, I know that the tanks in photos 1 and 2 were storing fresh water. Both sets were associated with a nearby hydraulic fracturing operation, which has very little to do with the drilling process.  You will never see big groups of tanks like this on a well pad that is currently being drilled.

The third set of tanks with no connections on an in-production well pad are probably just empty and storing air – but not fresh air. These tanks are just sitting there, waiting for their next assignment – storage only, not in use. Notice that there are no connecting pipes like in photo 2. The tanks in photo 3 could have held any of the following: fresh water, flowback, brine, mixed fracturing fluids, or condensate. Only the operator would know for certain.

Digging into Waste Data

Digging into Waste Data

By Katie Mattern, FracTracker Summer Intern

Seeing is believing, as the saying goes. Without physically observing the amount of waste generated from hydraulic fracturing of unconventional oil and gas wells, it is difficult to comprehend the volume and scope of the waste produced.

The Pennsylvania Department of Environmental Protection (PADEP) makes a considerable amount of waste production data publicly available, speaking to the quantities of fluids and solids produced by 25 oil and gas operators across 25 counties. This figure, however, is only about 40% of all of the operators according to StateImpactPA. Also, complete data is not available for the 25 companies that are included, but let’s dig into some waste data simply as an exercise.

Dig Into Basic Cabot Waste Statistics

In order to gain a sense for industry trends we decided to look at data pertaining to Cabot Oil and Gas Corporation, specifically, whose entire 2013 inventory of oil and gas wells were in Susquehanna County and the surrounding region. The first and second halves of 2013 contain fairly complete records for Cabot – such as well location, waste facility location, waste type, waste quantity, and disposal method. It is interesting to note that in the comments section, all but a few of the well permit sites read “Entire water fraction of waste stream recycled at a centralized treatment plant for reuse by Cabot,” even for drill cuttings that were taken to a landfill.

The following analysis focuses on the waste generated by 264 Cabot wells during this period. All of Cabot’s unconventional oil and gas wells in Pennsylvania during 2013 were in Susquehanna County and the surrounding region.

Waste Produced

In the first 6 months of 2013 (Period 1), liquid waste – consisting of produced fluid, servicing fluid, hydraulic fracturing fluid (frac fluid) waste, and drilling fluid waste – totaled 745,898 barrels (Bbl) or over 30,000,000 gallons. Solid waste – or drill cuttings – totaled 51,981 tons.1 To put this into perspective, 745,898 Bbls is equivalent to the water usage requirements of about 4 wells in West Virginia.2 The 51,981 tons of drill cuttings weighs about the same as the average amount of garbage produced by 65,029 Americans per year, or 1.5 times the population of Susquehanna County. The fluid waste is also enough to fill approximately 48 Olympic swimming pools.

Period 2 (July through December) of 2013, consisting of 319 reporting wells, experienced a 77% increase in liquid waste, climbing past the 1 million Bbl mark to 1,340,143 Bbl. This figure is the equivalent of filling almost 85 Olympic swimming pools. Similarly, drill cuttings increased to 96,165 tons, almost double the amount generated in Period 1. The total amount of waste generated by Cabot for the entire year yields more than 2 million Bbl of liquid waste and nearly 150,000 tons of solid waste from drill cuttings1 – more than 130 Olympic swimming pools worth of water and a weight of solid waste equivalent to the average waste generated by more than 120,000 American per year- over 2.8 times the population pf Susquehanna County (see infographic below).

Digging into waste data infographic

Waste Composition

According to Cabot’s waste data, most of the liquid waste is made up of produced fluid,1 which is the saline water that returns to the surface as a byproduct of the drilling process. This fluid can be up to 10 times saltier than ocean water and can also be radioactive.3 Frac fluid waste3 contributed to the next largest amount of waste, followed by drilling fluid waste and servicing fluid. Produced fluid tripled from Period 1 to Period 2, while frac fluid waste remained fairly steady, and drilling fluid waste decreased slightly. However, the amount of servicing fluid waste generated between the first and second half of 2013 increased more than 12 times.1 Overall, the following increases were seen between Period 1 and Period 2 in 2013:

  • Fluid waste from hydraulic fracturing rose by nearly 80%
  • Solid waste rose by 85%
  • The number of unconventional oil and gas reporting wells only increased by about 20%, from 264 to 319.

Examining the data from FracFocus that is available for these reporting wells,4 it is interesting to note that the average true vertical depth of the wells decreased by about 100 feet between the two periods. Therefore, it is difficult to understand why the amount of drill cuttings increased by 85% in Period 2. Why is there such a large increase in both solid and liquid waste between these two periods when there was only a 20% increase in the number of wells? There are various theories that could result in such a dramatic increase in period 2 compared to the 6 months prior, including but not limited to:

  1. The use of more liquids for the construction or drilling processes,
  2. Longer lateral distances per horizontal well,
  3. More lax operating procedures,
  4. More detailed reporting by Cabot, and/or
  5. Stricter reporting/enforcement by the PADEP.
Dig into waste date. Waste Impoundment - Photo by Pete Stern 2013

Waste Impoundment – Photo by Pete Stern 2013

Waste Produced Means Waste Transported

Although Cabot is responsible for producing large amounts of waste, they also are recycling their liquid waste (as is listed for every site in the Period 2 data). To do so, the company transports their waste to a centralized treatment plant. There, the water is filtered so that it can be mixed with more freshwater and chemicals and be reused at another well site. However, hauling so much fluid to the centralized treatment plant requires numerous trips by tanker trucks, as well as dump trucks and trailer trucks taking drill cuttings to landfills. Some treatment facilities for PA waste are located as far away as Ohio, West Virginia, and New York. Cabot trucks travelled approximately 114,000 miles5 in Period 1 of 2013, and over 1,122,000 miles were travelled in Period 2 of 2013. The total miles travelled to transport Cabot’s waste is equivalent to almost 50 times around the earth – for one company in one state, operating in only two counties.1

Additional Considerations

Further analysis should examine the air pollution and carbon footprint generated from such extensive traffic. The miles make a difference, considering that a highly efficient tractor trailor only gets ~10 miles per gallon.

While reusing the majority of liquid waste in an effort to reduce the amount of fresh water needed for hydraulic fracturing is a positive step, transporting recycling water by truck still results in fuel used, pollutants emitted, and traffic impacts.

Cabot Oil and Gas Corp. was the second largest unconventional shale gas producer in PA behind Chesapeake Appalachia LLC, which had more than 809 reporting wells in Period 2 of 2013. With a total of 62 companies operating in PA at this time,6 the cumulative effects of waste transportation undoubtedly add up. Serious efforts should be made on the part of all oil and gas companies to reduce their waste and provide accurate and timely waste reports.


References and Resources

  1. Data obtained from the PA DEP Oil and Gas Reporting Website
  2. Data originally posted on FracTracker.org
  3. Data obtained from New York State Water Resources Institute
  4. True vertical depth measurements are missing for many of the sites in Period 1. Data obtained from FracFocus
  5. Miles calculated in Microsoft Excel using formula obtained from Blogspot.com
  6. Data obtained from StateImpact Pennsylvania

Utica Shale Drill Cuttings Production – Back of the Envelope Recipe

By Ted Auch, OH Program Coordinator, FracTracker Alliance

Ohio is the only shale gas state in the Marcellus and/or Utica Shale Basin that has decided to go “all in.” i.e. The state is moving forward with shale gas production, Class II Injection Well disposal of brine waste from fracking, and more recently the processing and disposal of drill cuttings/muds via the state’s Solid Waste Disposal (SWD) districts and waste landfills. The latter would fall under the joint ODNR, ODH, and EPA’s September 18, 2012  Solidification and Disposal Activities Associated with Drilling-Related Wastes advisory. It occurred to us that it might be time to try to estimate how much of these materials are produced here in Ohio on a per-well basis using basic math, data gleaned from Ohio’s current inventory of Utica wells and the current inventory of PLAT maps, and some broad assumptions as to the density of Ohio’s geology.

Developing the Estimate

1) Start with a 341 Actual Utica well lateral dataset generated utilizing the ODNR Ohio Oil & Gas Well Database PLAT inventory or the current inventory of 1,137 permitted Utica wells. Generate a Straight Line lateral dataset by converting this data from “XY To Line” with the following summary statistics:

Variable

Actual

Straight Line

#

341

1,137

Minimum

186

50

Maximum

20,295

12,109

Sum

2,196,856

7,190,889

Mean

6,442 ±1,480

6,386 ±1,489

Median

6,428

6,096

2) Average Vertical Depth for 109 Utica wells utilizing data from the ODNR RBDMS Microsoft Access database = 6,819 feet (207,843 centimeters)

Average Lateral + Vertical Footage = 13,205-13,261 total feet (402,488-404,195 centimeters) (Figure 1)

Ohio Utica Shale Actual Vs Straight Line Lateral Lengths

Fig. 1. An example of Actual and Straight Line Utica well laterals in Southeast Carroll County, Ohio

3) We assume a rough diameter of 8″ down to 5″ (20-13 centimeters) for all of 1) and 14″ to 8″ (36-20 centimeters) for the entirety of 2)

4) The density of 1) is roughly 2.61 g cm3 assuming the average of seven regional shale formations (Manger, 1963)

5) None of the materials being drilled through are igneous or metamorphic (limestone, siltstone, sandstone, and coal) thus the density of 2) is all going to be
≈2.75 g cm3

6) The volume of the above is calculated assuming the volume of a cylinder
(i.e., V = hπr2):

    1. Σ of Actual Lateral Length 49,205,721 cm3 * 2.61 g = 128,180,904 g
    2. Σ of Actual Lateral Length 153,991,464 cm3 * 2.75 g = 423,476,526 g

Average Lateral + Vertical Volume = 551,657,430 grams = 1,216,195 pounds =
608 tons of drill cuttings per Utica well * 829 drilled, drilling, or producing wells = 504,113 million tons

To put these numbers into perspective, the average Ohio household of 2.46 people generates about 3,933 pounds of waste per year or 1.78 metric tons.

7) Caveats include:

    • The coarse assumptions as to density of materials and the fact that these materials experience significant increases in surface area once they have been drilled through.
    • The assumptions as to pipe diameter could be over or underestimating drill cuttings due to the fact that we know laterals taper as they near their endpoint. We assume 45% of the vertical depth is comprised of 14″ diameter pipe, 40% 11″ diameter pipe, and 15% 8″ pipe. Similarly we assume the same percentage distribution for 8″, 6.5″, and 5″ lateral pipe.

Ohio Drilling Mud Generation and Processing

Caroll-Columbiana-Harrison Ohio Solid Waste District Drilling Muds Processed (January, 2011-April, 2014)

Fig. 2. Month-to-month and cumulative drilling muds processed by CCHSWD, one of six OH SWDs charged with processing shale gas drilling waste from OH, WV, and PA.

Ohio’s primary SWDs responsible for handling the above waste streams – from in state as well as from Pennsylvania and West Virginia – are the six southeastern SWDs along with the counties of Portage and Mahoning according to several anonymous sources. However, when attempting to acquire numbers that speak to the flows/stocks of fracking related SWD waste (i.e., drilling muds) the only district that keeps track of this data is the Carroll-Columbiana-Harrison Solid Waste District (CCHSWD). The CCHSWD’s Director of Administration was generous enough to provide us with this data. According to a month-over-month analysis they have processed 636,450 tons generating a fixed fee of $3.5 per ton or $2.23 million to date (Figure 2). This trend translates into a 1,046-1,571 ton monthly increase depending on how you fit your trend line to the data (i.e., linear Vs power functions) or put another way annual drilling mud increases of 12,546-18,847 tons.