WVEC Action Alert

April 10, 2012

Oppose Centralized Pits for Storing Oil and Gas Wastewater

WV DEP’s Office of Oil and Gas is proposing a set of “Design and Construction Standards for Centralized Pits” that natural gas production operations can use to store wastewater (e.g. drilling or hydraulic fracturing fluids, sometimes referred to as flowback water).

• The use of such pits poses an unnecessary risk to human health and the environment, no matter how well designed or constructed.

• This risk is unnecessary because there are much safer alternatives available to handle this waste stream.

• The alternatives include closed containment (tanks) and closed-loop drilling systems.

• These alternatives have long been in use by drillers nationwide, and are currently used throughout this region by responsible operators.

• The alternatives are affordable, and can even save money for the operator.

• The Division of Oil and Gas has the authority to mandate the use of these alternatives, rather than authorizing the construction of centralized pits.

• As proposed, the “Design and Construction Standards for Centralized Pits” will be difficult and costly for the agency to administer and enforce.

Urge the Office of Oil and Gas to scrap this proposal and, instead, mandate the use of alternatives such as closed containment (tanks) and closed-loop drilling systems.

Comments will be accepted until Thursday, April 12, 2012 at 5 p.m.  We know turnaround time is short. But submitting comments by email is easy.

Comments may be submitted in writing by email to dep.oogcomments@wv.gov or through the U.S. Postal Service to: John Kearney, Office of Oil and Gas, 601 57th Street SE, Charleston, WV 25304.

The complete “Design and Construction Standards for Centralized Pits” proposal can be found here.