Alberta Landspraying While Drilling (LWD) Review

Landspraying While Drilling (LWD) Review by LWD Review Team (John Begg, Kevin Ball, Barry Cole, Lowell Calder, Barry Adams, Bruce Cairns, Dom Ruggieri, Suzanne Hawkes-Gill) Public Lands and Forests Division, Alberta Sustainable Resource Development December 2003, released three years later in 2006, only after FOIP and public pressure.

On July 1, 1996, guidelines for LWD on White Area public land grasslands were approved for a two-year trial period, as a method to reduce the area of native prairie disturbed during sump construction. The approval of the guidelines had been pursuant to a field study undertaken during 1994/1995 to monitor the effects of LWD on native prairie using conventional equipment and methods. The research project concluded that little adverse effect was observed save for short-term coating of vegetation by land spray materials until rainfall washed materials off or until it was redistributed by wind.

By 1998, after a further two-year trial period, Public Lands accepted LWD as a potential disposal practice on native grassland, provided appropriate conditions were adhered to.  In 2001, due to increased vegetation stress from drought conditions in the Grassland National Region, Alberta Sustainable Resource Development – Public Lands and Forest Division, suspended the authorization of Landspraying While Drilling (LWD) on public rangeland, native prairie throughout the province. A review has been initiated because of industry’s request to lift the moratorium and desire to continue using LWD on native prairie on public rangeland.

The review of LWD file paper trail and of field inspection reports from the Medicine Hat office highlighted a number of major issues including LWD projects being applied outside of the approved area, no final field report, field plans of poor quality, heavy loading rates of LWD materials and siting problems.

The survey of LWD sites within CFB Suffield highlighted concerns with the poor distribution of LWD residual solids; associated smothering impacts to grassland vegetation where there were skins and mudpacks of LWD materials; mechanical impacts like rutting; and siting problems such as application on sand dunes, watercourses, wetlands and steep slopes.

Four alternatives to LWD on native prairie were outlined including conventional sumps, remote sumps, transport to cultivated land or tame grassland, or to a disposal facility.

Most of the issues highlighted in the file review and field survey were also mentioned in staff comments, including adherence to the approved spray area, problems with spread distribution, site selection problems and problems with record keeping.

In other jurisdictions, experience with LWD was mixed. Two of three land management agencies interviewed expressed concerns about LWD. The Eastern Irrigation and CFB Suffield allow LWD but with special conditions, while the Special Areas Board does not allow LWD on native range.

A significant number of problems and issues have been identified through the review of hundreds of project files and field reports, from a field survey of project sites, from the experience of LWD in other jusidictions, as well as the experience of departmental staff.

The file review and field observations revealed that on a high percentage of sites, LWD is not being applied according to the guidelines.  This is having a negative impact on native range. The current LWD policy needs to be revised with stakeholder input, to address these operational concerns.

From the review it is apparent that drilling waste applied under the LWD persists on native range longer than previously thought and may have negative impacts on native prairie even when applied according to the current guidelines. Further research will need to take place to determine the exact nature of these impacts.

As a result of this review, the committee feels that issues and operations deficiencies must be addressed before LWD can be resumed on native prairie. Recommendations are provided to address the key issues identified in the review to address administrative, operational and environmental issues.  A number of research priorities are also highlighted.
The study did not include any analysis of direct or indirect impacts on wildlife or livestock.

One of the major issues raised by Public Lands staff during the intervening years since LWD was adopted as an approved practice was that LWD materials were found to persist for much longer time periods that the original research suggested and that there was a general concern about the evenness of spread distribution on the landscape over the treated area.

Visible impacts to vegetation were correlated with areas where spread materials persisted…and were observed on 71% of sites.

Site selection problems were observed on 35% of sites…. Inappropriate sites…included a) water courses and wetlands – 19% of sites; b) sandy/dune type sites-9.5% of sites and c) application on steep slopes – 7% of sites. Ruts were up to 8 inches deep on several wetland sites where LWD application took place.

A number of impacts on vegetation were apparent where LWD materials occurred as skins or mudpacks.  In these circumstances, LWD materials were in evidence as a smothering layer, which could suppress or eliminate the normal mid grass species associated with the range site and replace them with disturbance/weedy species.

In terms of mechanical impacts, the main one of concern was rutting which was observed twenty percent of LWD with the most common locations being turning areas, the tops of sand dunes and wetlands.

Site selection problem were evident on thirty seven percent of surveyed sites that included LWD application through watercourses and wetlands, fragile sand plains, on sand dunes as well as steep slopes.

Despite the favorable results reported by Christie et al. (1996) in the Pedocan Land Evaluation Inc. research report, LWD has not been a successful field technique on native rangeland.

The Field studies in 1995 were conducted very carefully.  The Research land sprays were at light rates and evenly sprayed over the application area, with excellent equipment and operational control.

Sprays conducted with drilling programs have not had the same level of operational control and are often very uneven. Typically, we observe mud packs deposited at the start of each spread load and then in a relatively dilute solution being applied.  It is not unusual to find mud packs in excess of one inch thick being dropped at the start of a load.

Mudpacks from poorly conducted land spray operations kill native prairie and take years to ameliorate.

Problem land sprays have been left with inadequate clean up.

Staff time to process applications, plan and monitor land spray applications has been unacceptably high. … Industry has failed to meet mapping and record keeping requirements. Mapping has been non-existent or completely inaccurate with examples of company maps with incorrect GPS coordinates and sites that have received double spray applications over the same land base.

In the scope of the last eight years, average precipitation to severe drought conditions have been experienced. During this period, staff have observed more evidence of LWD materials persisting on rangeland vegetation for prolonged periods. Drought conditions exacerbate the problem of residue build up.

We have major concerns that persisting LWD materials will increase the temperature regime on the rangeland surface. … Field staff have observed that the dark coloured land spray residue (low reflectance of sunlight) absorbs more of the suns radiation and heats the surface of the prairie. In other words, sprayed range will retain heat in much the same way as bare soil.

On a sunny summer day healthy native prairie will feel cool to the touch while the land sprayed areas are hot to very hot.  In this moisture-limited environment, increased temperature flux must have an impact. Subtle effects might occur to habitat, wildlife habitat values, and there may be increased potential to negatively impact nesting birds and small slow moving wildlife of which some are considered rare or endangered.

Water resources are increasingly scarce in southern Alberta and the energy sector is under growing scutiny to conserve water at all phases of production. Alternatives to LWD such as portable sumps, or flocking and reusing wagter coupled with hauling solids to a multi-well sump (one or two per drill program), have much less impact on the prairie and to dwindling water supplies.

We cannot ignore that one of the integrated uses on Public Land is food production.

Direct and indirect effects of spraying on wildlife and wildlife habitat. For example, spraying on native prairie can affect the nests, dens and burrows of several species including burrowing owls, long-billed curlew, marbled godwit, numerous species of passerines, waterfowl, and small mammals. There may be implications under the Wildlife Act as the house, nest of den of endangered species (e.g., burrowing owl) are protected throughout Alberta and throughout the year (“shall not willfully molest, disturb or destroy”). …

Equipment used for LWD can leave tracks and ruts on fragile soils or in wet areas. Recovery of this damage is very slow.

Given these concerns, the Fish and Wildlife Division recommends the moratorium be continued on LWD with spraying on native prairie, at least for public lands.

CFB Suffield employs environmental staff within Range Control that exercise oversight of oil and gas activities along with the Alberta Energy and Utilities Board.
LWD has been allowed on the base since 2001.
Rates of 1/4 to 1/2 the EUB rates are applied.
Base environmental staff have observed problems with LWD operations including:
– LWD materials are not distributed over the land properly.
– Problems occur where the operations start and stop.
– Pooling in low areas has been observed.
– There is concern over potential adverse effects on Kangaroo rats, other species at risk and ground-nesting species.
– Base staff have observed improper application around wetlands: buffers are not observed.
– Base staff suspect there is adverse effect on sandy soils.
LWD is not allowed during spring to allow migratory birds to nest.
LWD is only allowed on pipeline rights of way because these lands are used fairly intensively impacted already.

The AEUB [now ERCB] had conducted drilling waste audits on 51 LWD sites throughout the Province. The information (paper) audit consisted of a review of information supplied from companies on disposals conducted between 2001 and 2003.  Of the 51 audits, eight passed….

Discussion and Summary
The review of the LWD file paper trail and of field inspection reports from the Medicine Hat office highlighted a number of failures and problems, which were common to both review components.  The most common problem was that of LWD projects being applied outside of the approved area. … Finally, siting problems were common to both review components with LWD materials being applied through watercourses, on high wildlife habitat like sagebrush cover and on fragile sand dune sites. … The file review and field observations revealed that on a high percentage of sites, LWD is not being conducted according to the guidelines and is having a negative impact on native range. [Emphasis added]

Part of the FOIP records that forced the release – three years later – of this report by Alberta Sustainable Resource Development

“Underground Gas Storage Facility: The Base holds a unique underground gas storage formation. While it was thought to be used by [redacted] it was found that they were storing other operator’s gas.”

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