4 Million Reasons

Our Washington County, Pennsylvania has a long, disturbing history when it comes to football field sized impoundments, 15 to 20 feet deep, which are used by the oil and gas industry to ‘hold’ their liquid waste, or should we say, are supposed to hold those wastes, without leaking very much. These huge inground impoundments were the subject of a 17 September 2014 ‘Consent Order and Agreement,’ or COA, between Pennsylvania’s Department of Environmental Protection, or DEP, and Range Resources- Appalachia, LLC, or “Range,” the biggest shale gas producer in Washington County, where Range drilled the first Marcellus shale well in 2004. Their second Marcellus well was drilled on Ron Gulla’s farm in Hickory, as he describes in this video.

“What a long strange trip it’s been.”

Title on an album cover by the Grateful Dead definitely applies here!

The heading of the 53 page COA regarding their impoundments includes this: “Violations of the Oil and Gas Act, the 2012 Oil and Gas Act, the Clean Streams Law, the Solid Waste Management Act, and the Dam Safety and Encroachments Act,” and goes on to list 8 “Impoundments or “Centralized Impoundments” in the COA. One of the eight impoundments is permit number 95- 7- 60915- 6, Amwell Township 15, also known as “Jon Day” in Amwell Township, Washington County, with the ESCGP number ESX09- 125- 0030. This impoundment isn’t more than a few miles from where Range’s Yeager Impoundment and drill cuttings pit, in the same township, became the focus of two major, lengthy lawsuits, and the focus of the book, ‘AMITY AND PROSPERITY‘ by Eliza Griswold.

Range paid a whopping $4.15 million, which was probably the largest COA to date.
We’ve also followed the Jon Day impoundment, Amwell Township 15, or whatever you want to call it, which is only a few miles away, in the same township, with this storyboard of photos:

Day Impoundment
Amwell Township
South of Washington, Pennsylvania

Began by holding ‘FRESHWATER.’
Definition of freshwater: “Fresh to the site.”

SPILL in April 2010.
Pennsylvania DEP fine: $40,975

Photo shows surface disturbance caused by some sort of aerators in the impoundment:

“SIGNIFICANT LEAK” in April 2014.
Excavation of 15,000 tons (30 million pounds) of chloride- contaminated soil.

Photo shows the emptied impoundment with white plastic covering one side. The vehicles parked beside the impoundment give you an idea of the impoundment’s massive size:

Close- up photo of white plastic covering the side of the emptied impoundment:

This sign was posted by a neighbor of the Jon Day well pad and impoundment in May 2012.
“Range is not a good neighbor! Range and drilling equals no water. Range says prove it!”

DAY UNIT. 55% production decline in 35 months.
(File photo of the original fracking of the Day wells, illustrating the rapid production decline of Marcellus shale wells).

The COA from the Pennsylvania DEP goes on to state, “Amwell Township 15: On April 15th, 2014, Chloride impacted soils were encountered during the removal of the centralized impoundment’s liner.”

And further: “On February 11, 2013, Range failed to properly contain and control frac fluid; specifically, approximately twenty five (25) barrels of frac fluid discharged onto the ground while pumping fluids from holding tanks to the centralized impoundment.”

Under the “Impoundment Closure and Site Assessment” section is this, “Range shall cease all use of, including but not limited to any fluid storage operations, in accordance with the schedule set forth in Appendix A, at the Hopewell Township 11, Hopewell Township 12, Cecil Township 23, and Kearns Centralized Impoundments, and continue the closure of the Yeager centralized impoundment (collectively, the “Closed Impoundments”), and shall complete the permanent closure of those facilities in accordance with the schedule identified in Appendix A to this Consent Order and Agreement.”

18 September 2014 – Pa. DEP Fines Range Resources $4.15 Million for Violating Environmental Regulations – Consent order and agreement will close five Washington County impoundments.

For some reason, the Amwell Township 15 impoundment got a ‘hall pass’ that begins with this excerpt from the COA:
“Impoundment Upgrades and Investigation- Amwell Township 15 and Chartiers Township 16 Impoundments:
a. Prior to placing the Amwell Township 15 and Chartiers Township 16 Impoundments back into service for the purpose of storying any fluids, Range shall submit a request for a Letter of Amendment to the Dam Permits for a Centralized Impoundment at Marcellus Shale sites…”
and further under d. “Range shall operate each Upgraded Impoundment in accordance with the conditions of the current centralized impoundment dam permit for each Upgraded Impoundment (as amended), the Department’s regulations, the additional operating requirements contained in the Design Standards (as defined in Paragraph 4.a), and an approved Letter of Amendment for Dam Permit.”

BOTTOM LINE: In spite of all the violations and checkered history of these massive impoundments, all across our Washington County, the photos below give you a revealing update on that particular impoundment, as seen from the air yesterday.
It was full of those orange-colored fluids AGAIN!
Jon Day well pad and impoundment aka Amwell Township 15 impoundment on June 7, 2021
Elementary school nearby

Trinity South Elementary School is just to the south of all this industrial activity, including well pads, a compressor station, and the Jon Day impoundment, as seen in this file photo from 1 July 2012:

Some added insight on these impoundments

Since these massive impoundments began to appear all over our county, I did a file review at the Southwest office of the DEP, eight years ago, on a new impoundment (HIBBITS Centralized Impoundment) being installed in Donegal Township, and as seen in this photo from 2012:

Hibbits Centralized Impoundment in Donegal Township, Washington County, Pennsylvania in 2012
On the Instruction Sheet narrative Page 4 of 4, timestamped 29 November 2012 by the “DEP Southwest Region Oil and Gas,” was a very telling paragraph:

“If the liquid in LDV- 1 exceeds the allowable leak action rates listed in Section IV.f.i of the “Design and Construction Standards for Centralized Impoundments,” dated December 2010 the impoundment will be drained as needed to perform repairs. The impoundment’s water depth (h) will be in the [15 to 20] feet range; therefore, the “allowable leakage rate” will be up to 490 [gallons per acre per day]. The surface area of the line below elevation 1238.87 feet is 160,090 square feet (3.68 acres).”

Allowable Leakage Rate? What??
490 gallons per acre per day, over 3.68 acres, amounts to 1,803 gallons per day!
That’s over 54,000 gallons per month, and was still considered within permitted limits!


Can you imagine having one of these massive pits, full of orange-colored fluids, containing who knows what, above your water well?
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