Excerpts from File Review of 7/2/12 of Phoenix Pad S Permit # 117- 21148
From 12/20/2011 Surface Activities Inspection Report from DEP Water Quality Specialist Terra Tokarz of the Mansfield District Office:
“On 12/20/11 I conducted a routine inspection at the Phoenix S well pad site. ... Sean Van Fleet, DEP Solid Waste Specialist, accompanied me during part of the inspection ... The Highlands Rig #4 had recently moved onsite and was drilling the tophole portion of the well. Kelly Dunbar, company man, was available during the well pad portion of the inspection. Five wells were permitted for the Phoenix Pad S location. The wells were spudded on 10/27/11. The Highlands rig was at 5,675 feet on the first of two wells to be drilled at the site. “
“We observed impoundment 2, which is shown as a 6 million gallon freshwater impoundment in the E&S plan. The impoundment contained what appeared to be flowback. The field conductivity of the fluid was over 16 mS/cm. A sample was collected ... Upon arrival, Mr. Van Fleet observed two trucks that had discharged into the impoundment. The impoundment appeared to be constructed per the detail found in the E &S plan...A hole was observed in the liner near the top of the impoundment...During a subsequent inspection, it was confirmed that the flowback in the impoundment was generated at the Phoenix pad C location. Two wells were recently completed at the Pad C site. The flowback/production fluid was being transferred to the Phoenix S “freshwater” impoundment for storage.”
“The operator is reminded that the flowback/production fluid being transferred to Impoundment 2 must be used in its entirety for completion activities solely at Pad S. If fluid is transferred from Pad S impoundment for reuse or disposal elsewhere then the impoundment would become a centralized waste impoundment and would require additional permits for such activity.”
“I observed the disturbed area where impoundment 1 is to be constructed. As per correspondence with EQT, it is the Department’s understanding that Impoundment 1 is being redesigned to serve as a centralized waste impoundment...”
“No violations were cited...”
From 5/9/12 DEP Surface Activities Inspection Report from DEP Water Quality Specialist Terra Tokarz:
“On 5/9/12 I conducted an incident inspection a the Phoenix Pad S site....The area surrounding impoundment 2 and the proposed centralized impoundment was inspected. The area is separate from the Phoenix Pad S well pad, though still under the same ESCGP. EQT was preparing to initiate a 13-‐ stage frac on the Phoenix 590934 well. “
“..on 5/8/12 EQT notified the department that an estimated 300 – 500 gallons of flowback had been released onto the ground in a channel along the east side of the impoundment access road. The release occurred....while pumping flowback from Impoundment 2 through a 12” line to Phoenix Pad S to be utilized during the frac. The flowback was generated at Phoenix Pad C location and transferred to Phoenix Pad S impoundment for storage and subsequent use during completion activities at Pad S...The 12” line was staged in the channel alongside the east side of the access road. A subcontractor... was onsite and observed fluid flowing down the channel. Upon discovery the pumps were shut off. The flowback traveled south an estimated 250 – 300’ down the length of the channel and into a rock apron located at the terminus...a minimal amount of flowback was recovered due to migration down the channel and infiltration into the ground...a 2” hole was discovered in the bottom of the12” line approximately 100’ – 150’ from the pump. The 12” line had been reused from another site. The hole had been made in the line for a connection with a saddle valve. The hole was never patched and the line was not pressure tested prior to beginning the flowback transfer. The pump ran an estimated 5 – 10 minutes prior to the discovery of the release. “
“A representative of Castleberry and Associates was on site to sample MW-‐1 and MW -‐5 in association with monitoring being completed for the proposed centralized waste impoundment across from impoundment 2 and adjacent to the release area.. The MW’s were initially sampled on 4/30/12.” –( Note: MW = Monitoring wells, required with an application for a centralized impoundment )
“Based on the observations noted above, EQT is in violation of the following statutes and regulations:
-‐25 Pa Code 78.56 (a) or failure to contain a pollutional substance generated from completion of a well(s) in a pit, tank or series of pits and tanks.
-‐35 P.S. 691.402 for causing or allowing a pollutional discharge with the potential to pollute the Waters of the Commonwealth
-‐35P.S. 6018.301 for an unpermitted discharge of residual waste into the ground.”
From 5/10/2012 Surface Activities Inspection Report from Terra Tokarz :
“On 5/10/12 I conducted a follow up inspection at the Phoenix Pad S site to verify the spill clean up status.” …
“ Upon closer evaluation of the lower third of the channel, I observed what appeared to be a seep flowing from the west and surfacing inside the channel on the west side and above the channel bed. Field conductivity of the seep was 7.2mS/cm. I flagged the location of the seep (Seep #1) and collected a fluid sample...for SAC 517, bromide, lithium and strontium analyses. The soil appeared wet and glistening in other areas up the channel along the west inner slope and above the channel bed. I flagged another seep (Seep #2) up gradient of Seep #1. Seep #2 is oriented off of the SE corner of impoundment 2. The field conductivity was 6.6mS/cm.”
“No new violations are cited at this time.”
From E-‐mail From Jeremy Daniel, Water Quality Specialist Supervisor DEP to Kim Walker, David Fetty and Mike Cromley of EQT on 5/18/12, Subject: EQT Pad S Impoundment:
“ ... Based on these observations and the elevated chloride and TDS concentrations found in MW1 and MW5, it is possible that the liner in Impoundment 2 may have been compromised in some fashion. The Department recommends EQT evaluates the origin of the seep, the integrity of the impoundment liner, and ensures that all water from the seep is collected and handled appropriately.”
“Please contact me if you wish to discuss further or have any questions. We will provide you all with data and information as we receive it.”
“From 2012 Surface Activities Inspection Report 5/30/2012, Terra Tokarz:
“On 5/24 EQT informed the Department that multiple holes (6 to 7) had been observed in the liner near the NE corner of Impoundment 2. The holes were discovered on 5/21/12 during EQT’s visual inspection of the liner. All of the holes but one were located above the high fluid mark/staining. EQT stated that although one hole was located below the high fluid mark, it was undetermined whether the hole existed when the fluid level was above it... According to EQT, the holes were repaired on 5/22/12. The holes were concentrated in the NE corner where fluid transfer activities had been occurring. EQT stated that they ceased transfer of flowback from Phoenix Pad C to Impoundment 2 on 5/21/12 upon discovery of the holes. “
“No new violations cited at this time”.
From an e-‐mail from John Centofanti of EQT to Scott Perry DEP Oil and Gas Bureau Chief on 6/1/12:
“As requested during our discussion this morning, here is a high-‐level overview of EQTs plan of action for the Phoenix 5 pad...”
“1. Groundwater with elevated conductivity seeping from the base if north side of the impoundment is now fully contained within an excavated sump. Groundwater is flowing in now at approximately 3 gallons per minute. This is down from the 10 gpm we saw Wednesday after the heavy rains in the area. The collection sump has successfully halted off-‐site migration of this groundwater into the unnamed tributary. “…
“3. As of 11 a.m. this morning, dewatering of the impoundment is underway. We are pumping it down the well to frack it. Completion of the de-‐watering will occur within the next 48 -‐72 hours. There are 70,000 barrels of fluid in the pit, equating to approximately 700 water trucks. Using the large frack pumps is the most efficient and expeditious means to remove the water ...”
“4. Surface water sampling commenced this morning to characterize the unnamed tributary and, beginning approximately 1,500 feet downstream, the high quality and exceptional value streams upstream and downstream...”
5. “We have identified adjacent landowners, primarily a lumber company and Waste Management, and are updating them regularly.
“ * We are developing a pit liner integrity evaluation process to be implemented once the pit is dewatered....”
6/4/12 DEP Surface Activities Inspection Report from Terra Tokarz:
“ On 6/4/12 I conducted a follow up inspection to evaluate the status of flowback removal from Impoundment 2 and to conduct further field monitoring...The area surrounding impoundment 2, the spring discharge, the unnamed tributary ( UNT) and a wetland complex in the headwaters of the UNT were observed.”
“According to EQT, approximately 41,000 barrels (bbls) of flowback had been removed from the impoundment for use in the frac on Phoenix Pad S well 590935.
“According to C&A (Castelberry and Associates , the field conductivity of the spring was around 30,000umhos/cm and flow was between 3 -‐ 5 gallons per minute (gpm). The sump below the spring was continuing to capture the discharge and pump it to the 500 bbl tank staged adjacent to the impoundment. The tank was emptied for the first time earlier in the day (an estimated 400 bbls) and the fluid taken to Phoenix Pad E for storage.”
“To the east of the UNT, along a break in slope between the impoundment and UNT, numerous seeps had been identified by C&A. C&A established stations at the seeps and recorded conductivity measurements. The seeps are located upgradient of what appears to be a wetland system that contributes to the UNT. Any wetlands contributing to Rock Run in this area would be considered Exceptional Value (EV) based upon the upper portion of Rock Run being classified as Class A Wild Trout Waters by the PA Fish and Boat Commission. We observed seep stations A – H, which ranged in conductivity from 43,051 umhos/cm ( Station B) to 15,128 umhos.cm ( Station H)...Stressed vegetation was apparent along the seep locations.”
“The violations cited on 5/31/12 remain outstanding. No new violations were cited during this inspection.”
E-‐mail from John Ryder, Director, District OG Operations DEP to John Centofanti 6/5/12:
“ I also wanted to alert you about an additional seep located on the Northwest Side of impoundment S that has not been addressed. I just spoke with Jeremy Daniel in the field and he indicated the seep was actually discovered by your consultant yesterday but that there has been no action taken to capture the fluids to
date. Jeremy Daniel indicated that the field conductivity at this seep is in the 8,000 microsiemen range....”
E –mail: EQT’s Kim Walker responds to Jeremy Daniel after DEP business hours on 6/5/12 with “ our daily update regarding the activities on the Phoenix S well pad for 6.5.12:
Among the updates:
“ ,,,Pumping activities will continue to bring down the water level to approximately 12 -‐16” of water remaining... Preliminary soil results from sampling below the previously identified holes in the northeast corner of the pit were obtained. Both soil and geotextile were sampled for chloride only. Results indicate chloride results of <5mg/l in soils...Visual survey of the liner is occurring now by EQT water group. No additional holes have been found. Will contract to conduct an electrical liner integrity survey.... Monitoring and sampling in Rock Run initiated today.”
E –mail from Jennifer Means, DEP Environmental Programs Manager, Eastern Oil and Gas Operations, to Kim Walker and others 6/6/12 Re: EQT Phoenix S Pad Update 6.5.12:
...First and foremost, it is the Departments position that the liner will ultimately have to be removed so that the area beneath can be fully investigated for evidence of release. This should aid in identifying additional sampling locations, excavation, etc. The number of seeps being identified with extremely elevated conductivity and areas of recently stressed vegetation indicate a significant release with a broad impact...”
“Additionally, we do not see how we can immediately move forward with processing the centralized impoundment permit application for this site that is currently in-‐house due to the inability to characterize pre-‐existing ground water conditions...”
E-‐mail from EQT’s Kim Walker to DEP’s John Ryder, Jeremy Daniel, Jennifer Means and Terra Tokarz among others, 6:03 pm 6/8/12: Daily update Phoenix S well pad 6.8.12:
“Dewatering activities have removed 100,000 bbls of water from the pit. There is approximately 6 -‐8” of water remaining (estimated 1000 – 2000 bbls)... Pumping activities and water hauling will continue to completely dewater the pit. ... Waste Management has been onsite to sweep up the sediment along the sidewalls of the pit to initiate sediment removal efforts and to aid in the detailed inspection of the liner...Visual inspection of the liner is ongoing. No additional holes have been found.”
E-‐mail from Kim Walker to same as above paragraph on 6/9/12 11:01 am: EQT Phoenix S Pad Update 6.8.12:
“Hello All, ...Visual inspection of the liner yesterday evening (6.8.12) identified the presence of holes towards the bottom of the pit.... Next Steps... Continue sediment removal activities and commence roll up/ removal of the liner... Material to be placed in close top roll offs for disposal... Thanks.”
Surface Activities Inspection Report from DEP Water Quality Specialist Matthew Nuss 6/11/12:
“On 6/11/12 a follow up inspection to evaluate the status of the
flowback removal from Impoundment 2 and to perform further field monitoring was conducted.”
“At the time of this inspection the flowback had been removed and the liner was being pressure washed. The sediment at the bottom of the pit was being solidified for off-‐site disposal. Numerous holes were observed in the liner. A photo is attached to this report, the holes are indicated by orange circles. A representative from EQT stated it was believed there were approximately 75 – 100 holes identified to date.”
“ These constitute violations of”:
“ 25 Pa. Code 78.56 (a) (4) – Operator failed to maintain an impermeable pit containing a pollutional substance.”
“ 25 Pa. Code 78.56 (a) (4) ( iv) – After the liner was determined to be torn or otherwise lost its integrity, the operator failed to manage the pit to prevent the pits contents from leaking form the pit, and “
“25 Pa. Code 91.34 (a) – Persons engaged in an activity which includes the impoundment, production, processing, transportation, storage, use, application or disposal of pollutants shall take necessary measures to prevent the substances from directly or indirectly reaching the waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause.”
From a DEP Surface Activities Inspection Report from DEP Water Quality Specialist Terra Tokarz 6/12/12:
“ On 6/12/12 I conducted a follow up inspection. Department staff Jeremy Daniel, Water Quality Specialist Supervisor, Jessica Ritenour, Professional Geologist and myself met with EQT personnel....”
“The impoundment was empty and workers were recovering rainwater accumulating in the bottom. We walked downward into the impoundment to observe the holes in the liner. EQt estimated 75 -‐100 holes were discovered towards the bottom of the north inner impoundment slope near the NE corner. EQT discovered the holes on 6/8/12 upon removal of the flowback fluid. The punctures were up through the liner, rather than down into the subgrade material. The punctured liner was pointing up and towards the north (see photos). EQT informed us that they would be contracting a third-‐party forensic expert to evaluate the liner> We discussed removal of the liner, excavation of the impacted soil and staging of the soil pending chemical analysis and acceptance by the landfill.”....
“The Department had previously requested a site characterization and clean up plan to be submitted to the Environmental Cleanups Program by 6/22/12.”
E-‐mail from Jennifer Means to John ( ? , John Centofani, EQT is among many copied) 6/14/12 9:06 am:
“John, Jeremy Daniel had a discussion with our Water Supply Program yesterday. There is a significant concern in regards to some of the public water supply wells in the vicinity of the Pad S pit. Specifically, Wellsboro’s Pump House and Wooden Shanty wells and Duncan Township’s Well #1 and Well #2. We are under the impression that EQT has notified Dan Brought, Wellsboro Municipal
Water Authority. We are unaware of any notification made to Duncan Township as of today.”
“The Department is requesting that EQT promptly make contact with both Municipal Authorities and collect samples from each of the public water supply wells previously listed. It is imperative to have this data as soon as possible to document if there has been any impact to any of these wells, so we are requesting a rush on the analysis. I understand that EQT has collected samples from these water supplies in the past. The predrill parameters should be sufficient at this time....
E-‐mail from Kim Walker, EQT to numerous DEP and EQT 6/14/12 4:56: “Duncan Township and Wellsboro wells were sampled today (6-‐14-‐12). Results to be expedited and provided to PADEP upon receipt”
Letter to Richard Hill, EQT from Jennifer Means, DEP, 6/18/12: Re: Administrative Incompleteness Review Letter Phoenix S Centralized Impoundment Application...
“The application must be revised to reflect the following:... 2. Due to contamination of surrounding groundwater from leaking Pad S Pit, water quality monitoring data collected to date does not accurately characterize the background chemistry of groundwater at the site. Additionally, seeps and flow patterns observed during the spill response at the Pad S Pit do not agree with the groundwater flow patterns depicted in the April 15, 2012 report titled, “Phoenix Resources Lease, Preliminary Groundwater Monitoring Plan for the proposed Pad S Centralized Water-‐Storage Impoundment, Duncan Township, Tioga Pennsylvania”. Therefore, it also appears that the current water quality monitoring network does not accurately characterize the flow systems on the site and adjacent areas.” ...
EQT daily updates from Kim Walker continue in the file until June 21. Nothing past 6/21/12 was in the file as of Monday July 2nd. No mention of the public water supply test results was found.