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Marcellus Issues in West Virginia: An Introduction

Site Construction
(including roads and sediment control)

Site construction for horizontal wells not only includes the creation of the flat pad where drilling takes place and a road to the pad but also ancillary construction of pipelines, impoundments or pits and roads to these sites. A pad for a traditional vertical well was usually about a half acre, the pad for a horizontal well is 5 acres or more. The land disturbance involved in creating the flat pad can be substantially more than the area of the pad.

Operators in West Virginia are required in ยง22-6 to use the West Virginia Erosion and Sediment Control Field Manual created by the Office of Oil and Gas. A revised edition was released in 2012 and is better than the previous, outdated, edition. The revised edition is still flawed.

Industry created, based upon research conducted in Texas for the EPA, a RAPPS manual for operators. The RAPPS manual has a variety of sediment control features whose use is dependent on a site's original grade, soil type and local rainfall. Both the research for the EPA and the RAPPS manual point out the difficulty in sediment control on sites constructed on 15% or steeper grades which is often the case in West Virginia.

The NRCS and other federal agencies developed RUSLE2 Windows computer program that can be used to determine the best sediment controls to use for a particular site based on soil type, local rainfall and grade. This program is used, for example, by highway engineers and the Office of Surface Mining for construction projects.

The West Virginia Department of Environmental Protection's Division of Water has an excellent Erosion and Sediment Control Best Management Practices manual that is more protective of the environment than the Office of Oil and Gas' manual which is based on the premise that since the EPA exempted oil and gas construction activities from NPDES requirements, these activities can be carried out using much lower (or nonexistent) standards. Other states require oil and gas construction activities to meet the same NPDES requirements that all other construction activities must meet.

The Office of Oil and Gas' manual freely borrows some, but not nearly all unfortunately, the ideas/illustrations from neighboring Pennsylvania's manual for the oil and gas industry.

There's a Forest Service report on the effects of site construction and drilling of a vertical well in the Fernow Experimental Forest. Scientists there measured the amount of sediment released from the vertical well site's construction and pointed out the deficiencies of the earlier edition of the field manual (which persist in the revised edition).

There's also a Forest Service study about the importance of timing in the installation of proper sediment control features. The best sediment control that can be done at any site is the establishment of a good coverage of grass as soon as possible after a phase of construction is completed. The Office of Oil and Gas doesn't require the planting of grass until after a well is fractured and reclamation has taken place. This can be months or years after a site's original construction began. The manual does require temporary seeding of areas that are not to be graded or worked for 21 days.

The study for the EPA carried out in Denton, Texas is well worth reading, not just for the issue of sediment release from construction sites but also for the types of chemical pollution that leave well sites in stormwater. One of the coauthors wrote a dissertation which includes an examination of the use of RUSLE2 computer program in determining the best types of sediment control for use at a particular site. There's also a presentation. This work was the basis for industry's RAPPS manual.


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