-------- Original Message --------
Subject: | FW: Office of Oil and Gas Program Review Meeting |
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Date: | Tue, 13 Jul 2010 20:35:27 -0400 |
From: | Beth Little <blittle@citynet.net> |
To: | <blittle@citynet.net> |
I. Improvements in WV-DEP rule (35-CSR-4).
A. Require leaking wells to be repaired, or ordered closed.
B. Require fencing of pits.
C. Require landowner notification and approval of reclamation alterations, as well as start of operations (with more reasonable lead time).
II. New Legislation
1. TDS Standards (250 ppm) state wide (this is actually being dealt with in the Water and Waste Management Div, but it doesn’t hurt to mention it).
2. Improved funding for DEP – higher permit fees in order to hire more inspectors and higher bonds to cover accidents and abandonments
3. Eliminate Blanket Bond process (Currently $50,000 per company, which is inadequate to plug wells ($8-10,000 each) after their useful life.
4. Road repair bonds or similar requirements to maintain public roads damaged by heavy trucks carrying drill rigs and frac water, and some kind of traffic safety control during times school buses are on the road..
5. Require wastewater disposal tracking (cradle-to-grave water permits with documentation; i.e. records of where water came from and where it went).
6. Limits on withdrawals during low-flow periods, (e.g., flows less than 60 % of annual average flow). (this is also being dealt with in the Water and Waste Management Div, but it doesn’t hurt to mention it).
7. Public disclosure of fracing chemicals used in Underground Injection.
8. Additional studies required for permits in karst geology.
9. Amend W.Va. Code 22-6-6(d) to require a sediment control plan for well plugging and site remediation operations (currently exempted).
10. Require pits to be lined, operators to maintain the integrity of liners, and pits and liner materials to be disposed of at approved facilities, rather than buried on-site.
11. Require the operator to test all wells and springs used for domestic purposes, within 1000 feet of a well prior to drilling and record tests with DEP permit. Tests should include major ions, methane, NORMs, and fracing constituents.
12. Prohibit disposal of brine, including coal bed methane brines in underground mines.
13. Prohibit disposal of brines or frac water in publicly-owned waste water treatment facilities (unless they are specifically designed to treat such waters),
14. Reform process for hiring inspectors to reduce industry influence. Eliminate the current industry majority and require conflict-of-interest provisions for Oil and Gas Inspectors Board.
15. Additional funding mechanisms for inspections and enforcement (currently WV-DEP has 16 inspectors for 40,000 wells, with 900-3000 new well permits per year.)
-- Carla Beaudet speak...@fastmail.fm