Evaluation of the Capacity for Water Recycling for Colorado Oil and Gas Extraction Operations
Colorado freshwater consumption for hydraulic fracturing (HF) completions has more than doubled in the last 10 years, since 2013. Consumption of water for HF is unlike other water uses, as it permanently removes the water from the water cycle by locking it deep in hydrocarbon reservoirs or contaminating the water with hydrocarbons, radionuclides, and high salt content. Additionally, current oil and gas produced wastewater injection disposal facilities are considerable sources of local and regional air quality degradation, due to emissions of toxic and carcinogenic air pollutants and ozone precursors.
This report, completed by FracTracker Alliance, tracks water consumption by Colorado’s oil and gas extraction companies over the course of a ten year period, 2013-2022. Water consumption volumes were plotted alongside wastewater production volumes and oil production volumes. Plots of the data tracking are presented and discussed.
Key findings of the report:
- Colorado’s oil and gas industry has produced enough wastewater statewide to completely satisfy the current and past needs of source water for HF completions, over the ten-year period of this analysis; 2013-2022.
- Water use for HF completions have risen sharply over the last ten years, more than doubling statewide.
- Average volumes of water consumption per individual HF well completion have also risen sharply, and are over four times higher than 2013.
- Implementation of recycling requirements for sourcing HF water would alleviate the pressure on freshwater resources.
- Within Colorado, recycling wastewaters for use as HF waters would reduce stress on freshwater resources the most for Weld County.
- Implementation of the new rules and wastewater recycling requirements proposed in HB 23-1242 would reduce the amount of freshwater consumed for HF operations, but would not inhibit Colorado oil and gas operators from continuing operations at their current level of exploration and production.
For more information about this analysis, contact Fractracker Alliance Western Program Coordinator Kyle Ferrar at ferrar@FracTracker.org.
The politics of water are a major part of colonial history, and in the Western U.S., states are still increasingly grappling with the issue of water conservation. State disagreements over reducing reliance on withdrawals from the Colorado river recently made national headlines, and revived the old western adage “whiskey is for drinking, water is for fighting.” As the source of many headwaters, Colorado’s water conservation policies impact freshwater access for tens of millions of people in more than just the seven states plus Mexico that make up the Colorado River Compact. As the impacts of climate change escalate, the serious drought spanning from the Mississippi River to the Pacific Ocean has the potential to worsen and create a climate justice emergency resulting from lack of access to freshwater resources for marginalized communities.
Unconventional oil and gas extraction activities have become increasingly water and energy intensive, as oil and gas companies expand drilling into the remaining reservoirs and source rock. Colorado is a particularly striking example of a state where the freshwater demands for oil and gas extraction have substantially increased, even while the rates of new drilling and hydraulic fracturing (HF) operations slow.
In 2022 Colorado oil and gas companies injected over 10 billion gallons of water for HF operations, down from over 15 billion gallons in prior years. For comparisons, the entire city of Denver supplies about 80 billion gallons of water per year to households. The fact that just HF (not including the other water uses of oil and gas extraction such as enhanced oil recovery) consumes 15 to 20 percent of that of the greater Denver Metro is substantial. For further comparison, the volume of water consumed in 2022 was greater than many smaller city’s utilities provide to their city residents, including Fort Collins. In fact, water consumption for HF completions totaled over 8.9B gallons in Weld County alone in 2021, about the same volume of water distributed annually by the City of Greeley Water and Sewer Department.
While the majority of freshwater resources consumed in the state are for agricultural and domestic use, nearly the entirety of those water volumes are returned to the water cycle, the majority directly back to surface waters. Injecting water for HF cannot be compared to these other water uses, because the industrial process seals freshwater deep in reservoirs where it either remains inaccessible or returns to the surface contaminated with hydrocarbons and brines and is via deep well injections without consideration for the chemical composition or the risk they pose to the public or underground sources of drinking water. Produced waters are exempt from the Resource Conservation and Recovery Act (RCRA) disposal requirements that would otherwise be applied to more strictly regulated hazardous wastes of similar toxicity.
While the majority of HF water is still sourced from freshwater sources, Terra Energy uses nearly 100% recycled produced water for HF operations in the Piceance Basin on the Western Slope. The recycling operations at Terra save about 100,000 truckloads of water a year by investing in piping and pumping infrastructure for produced water in the Piceance Basin in Garfield County, Colo. But rather than investing in recycling capabilities, operators on the Front Range instead invested in midstream infrastructure to claim as much freshwater as possible. Anadarko and Noble Energy invested tens of millions of dollars building fresh water pipelines and have created midstream companies to sell access and distribute fresh water to other Front Range operators. With Noble Energy’s increased access to freshwater, the company used over 32M gal. of water to HF individual wells in 2021, averaging over 22M gal per well; and even then these were not the largest individual or average volumes used by operators in 2021 on the Front Range. Selling access to Coloradans’ fresh water on the Front Range was so lucrative that Noble Energy Partners and its Midstream water piping business recently sold to Chevron for a total valuation of over $13.3 Billion.
Unfortunately there has been little pressure from Colorado regulators for oil companies to conserve freshwater, much less to recycle. To address this major gap in the regulations, House Bill 23-1242 has been proposed in the state legislature by Rep. Boesenecker and Sen. Cutter.
Starting in 2024, if passed the bill would require Colorado oil and gas companies to report water use information to the Colorado Oil and Gas Conservation Commission (COGCC), including volumes of freshwater utilized for HF and volumes of wastewater exiting each of the operator’s oil and gas locations. The bill also requires the COGCC to adopt rules requiring that operators use decreasing percentages of freshwater and correspondingly increase the proportion of recycled or reused water. Additionally each oil and gas operator would be required to report the daily vehicle miles traveled for any trucks hauling water to, within, or from the operator’s oil and gas operations in the state.
In light of the new bill (HB 23-1242), this FracTracker report explores Colorado’s existing regulatory data to better understand freshwater use for HF in Colorado. This report clearly demonstrates that operators in the state of Colorado produce enough wastewater to completely satisfy the needs of current water demands for HF operations. This is true, even if volumes of produced wastewater are only reused once. With the institution of water sharing agreements within basins and even the state as a whole, and the implementation of wastewater treatment and recycling facilities, it should not be necessary for HF completions to consume any volumes of freshwater.
The analyses presented below utilize datasets from FracFocus.org and the COGCC. The data were plotted and figures are presented that explain the relationships between frac water injection volumes, produced water volumes, and oil production volumes. The data shows that the volume of water used by HF has more than doubled in the 10 year period 2013-2022, and average water volumes used for HF wells has increased fourfold. Based on the last ten years of COGCC reported data, it is currently possible for operators to source the vast majority, if not all, of their HF water requirements from produced water, given the volumes of produced water reported to the COGCC. The locations of HF events and relative volumes of water used are presented in the map below.
Colorado Oil and Gas Well Water Use
This interactive map looks at the locations of Colorado’s hydraulically fractured oil and gas wells reported to FracFocus, a publicly accessible website where oil and gas production well operators can disclose information about ingredients used in hydraulic fracturing fluids at individual wells.
View the map “Details” tab below in the top right corner to learn more and access the data, or click on the map to explore the dynamic version of this data. Data sources are also listed at the end of this article.
In order to turn layers on and off in the map, use the Layers dropdown menu. This tool is only available in Full Screen view.
Items will activate in this map dependent on the level of zoom in or out.
The analyses presented utilized data from two sources, FracFocus and the Colorado Oil and Gas Conservation Commission (COGCC). The following report therefore deals with volumes of water consumed for HF (also referred to as ‘freshwater’, ‘frac water’, or ‘HF water consumption’), and the wastewater that returns to the surface following HF completions (also referred to as ‘produced’ waters’ or just ‘wastewater’).
Since 2012, oil and gas operators in Colorado have been required to report hydraulic fracturing injection water (frac water) and chemical volumes to a data intermediary called FracFocus, and FracFocus provides complete data downloads of their database. The COGCC, Colorado’s principal oil and gas regulator, provides data downloads of monthly production volumes for oil, gas, and produced water. Monthly production data was downloaded for the years 2012-2021. The COGCC monthly production data was merged with the FracFocus dataset and analyzed using Python v3.9.12. The merged dataset along with the annotated Python code for the data analysis and plot generations are available at this link.
The quality of analyses are entirely dependent on the quality of data. Therefore we begin this report with a short quality assessment audit of the datasets used for the analysis. The FracFocus dataset of all wells reporting HF operations was screened for completeness against the COGCC monthly oil and gas well production datasets and the “Well Spots (APIs)” dataset. Results show that there is likely a substantial count of oil and gas wells that have undergone HF completions but were never reported to FracFocus, as well as volumes of oil, gas, and wastewater production data that has gone unreported to the COGCC.
Screening the COGCC dataset of “Well Spots (APIs)” revealed five incorrect API numbers listed in the FracFocus database, likely simple transcription errors. Table 1 below identifies the incorrect and corrected API numbers. Determining whether Colorado operators have failed to report HF operations to FracFocus is not definitively answerable from the downloadable COGCC datasets, as COGCC does not provide aggregated data on which wells have undergone HF completions. Limiting the COGCC data to wells that report spud dates post-2013 identified 2,008 unique API identification numbers that were not reported in the FracFocus database. Of those, 1,170 (58%) are reported as drilled horizontally, and another 356 are directional. It seems unlikely that there would be such a high count of horizontally drilled wells that were not subject to HF completion.
|FracFocus API Number||Corrected API|
Table 1. FracFocus Corrections. The short table provides corrections to the FracFocus database for HF wells in Colorado.
Data completeness as a result of reporting delays is likely the biggest issue. Tracking monthly submissions shows that there is likely a substantial delay in the reporting of production data to the COGCC. Operators are required to report production volumes to the COGCC within 45 days of the end of the month, and are also required to submit reports of HF operations to FracFocus.org within 30 days of the conclusion of well completion activities. The extent to which both these are followed is not clear, but the data shows that over 6% of the production reports submitted in 2022 were over one year late. While the majority of late reports were for the years 2019-2021, late reports spanned all the way back through 1999. Of note, the majority of the late data in the 2022 dataset is for the years 2019, 2020, and 2021; meaning that the production summaries that follow consequently under-report wastewater and oil production volumes, particularly for years 2019-2022.
A major logistical concern with requiring oil and gas operators to utilize produced water volumes for HF operations is whether there are enough volumes of produced water to satisfy the needs of HF activity. The following sections provide critical analyses of the existing regulatory data in order to answer this question. In addition to looking just at water use and water production, the analyses below also provide insight into the response of oil production to increased HF water volumes.
Hydraulic Fracturing Water Volumes
Beginning with statewide data, plotting annual sums of water consumption alongside wastewater production provides a broad overview of the relationship between water in vs water out. The chart below in Figure 2 shows annual volumes of water consumption for hydraulically fracturing (HF) oil and gas wells in Colorado compared to the counts of completed HF operations. As of 2022 the volume of freshwater injected during HF operations has more than doubled (tripled in 2018) while the number of HF events has decreased 60% since 2013. Figure 3 shows that average volumes of water used for HF completions has steadily increased since 2013 as well. Maximum injection volumes have varied widely on the other hand. In sections below, plots (Figures 10-12) show that the drastic increases in HF water volumes have had a minimal impact on increasing oil production.
Keeping in mind that water production data is under reported, particularly for 2020 through 2022, the data in Figure 4 shows that, with the exception of 2018 when HF operations consumed over 15B gallons of water, volumes of produced water have remained consistently greater than HF water consumption volumes. While the capacity may exist statewide, the transportation of produced water long distances typically requires tanker trucks, which degrade local and regional air quality as the miles traveled increase. While a statewide water sharing pact may be possible, the pipeline infrastructure required to accomplish this goal is likely not feasible at this point in time.
While a state-wide water sharing agreement may be limited by geography, basin-wide water sharing agreements have been highly successful in Colorado. Operators in the Piceance Basin have profited from a water sharing agreement coupled with water recycling facilities that have allowed them to reduce reliance on freshwater resources as well as operating costs. Figure 5 plots water volumes consumed in the Piceance Basin for HF alongside wastewater production volumes per year. Of note, the majority of the HF water volumes may be sourced from recycled waters, but the COGCC does not currently track sources of water. The plotted data shows that the basin produces more than enough wastewater to provide ample volumes of water for HF completions.
Data for the Denver-Julesburg (DJ) Basin is presented in Figure 6, below. The plot shows that while the HF operations in the basin have in certain years consumed drastically elevated volumes of water, wastewater volumes would still be able to offset the majority of HF water requirements. Hydraulic Fracturing operations in the DJ Basin consume the majority of frac water in the state, and the drastic increase in consumption 2017-2020 and then 2021 is particularly pronounced. Similar trends are viewable in the county-specific plots, presented in Appendix A. The plots show that the majority of HF water consumption in the DJ Basin is driven by Weld County (Fig 1A), and the majority in the Piceance Basin is driven by Garfield County (Fig 2A).
Of note, the sharp decrease of HF water consumption volumes in 2020 can be attributed to the market downturn during the Covid-19 pandemic. Regardless of Covid-19, the HF water consumption volumes have trended down since 2018 for both basins and most counties. This trend is likely an economic correction considering the lack of substantial response in oil production to extremely high HF injection volumes. Adams County HF volumes are an outlier of these trends (see Fig 5A), as extraction development encroaches on suburban communities surrounding Denver. Suburban and even more urban drilling will likely increase as oil companies (operators) explore for reservoirs farther from the established and nearly exhausted sweet spots of the DJ Basin.
The following plot analyses limit the full state datasets just to wells that have undergone HF completions, according to the FracFocus database. The plots of wastewater production volumes are limited to just the three-year period following the HF completion of each well, presented in the plots in one-year increments. To focus on just HF wells the FracFocus database was merged to COGCC monthly production data, then the monthly production data was filtered to include the subset of operational production wells that had completed HF operations. This particular method was employed to assess the contribution of flowback and produced water volumes specifically from HF wells. While FracFocus reports a total of 13,651 hydraulic fracturing events for the 2012-2021 timeframe, a total (N=11,831) hydraulically fractured wells had reported production data, according to the COGCC, and were included in this analysis. As above, plots were created for the full state data and for individual basins. Additionally, plots for individual counties are included in Appendix A.
Annual wastewater production volumes from HF wells for the full state are shown below in Figure 7. While the trendlines for wastewater volumes from just the HF wells show a more visibly correlated relationship to HF water consumption than wastewater volumes for all production wells, the increased volumes of HF water consumption 2019-2022 are barely reflected in the wastewater production volumes. At the elevated water consumption volumes there is a clear disconnect between increased water consumption and increased oil production.
Trends in the statewide data show that when injection volumes are unreasonably high, such as during the year 2018, the volumes of wastewater produced comprise a smaller percentage of the volumes injected. Beyond 2019 only the ‘Year 1’ estimates should be considered accurate, due to incomplete data, and the produced water volumes for 2020 and 2021 are likely under-reported. Table 2 below presents the data points used to generate the graph, and reports the percentage of “returned” produced water volumes to HF water consumption volumes. As seen in the table below, 2019 is a distinct outlier. If the incomplete data (2019-2021) is dismissed, the data shows that wells that undergo HF completions in Colorado return an average 30% of injected water volumes in the first 12 months following HF completion, 38% after 24 months, and 44% after 36 months. While these volumes may not fulfill the consumptive needs of all HF completions, these production wells represent just a fraction of the produced water volumes generated in the state.
Separating the DJ and Piceance Basin HF water consumption and wastewater production data shows similar trends to the separation of total produced water volumes for each basin, discussed above. The DJ Basin, shown in Figure 8, is largely responsible for the gap between HF water consumption volumes and wastewater production volumes. In the Piceance Basin the majority of water consumed by HF operations returns to the surface as wastewater, even following the disproportionate volumes used for HF from 2017 through 2019, more than half the injected volumes were reported to have returned to the surface as produced water volumes. Figure 9 below visually demonstrates that relationship in the Piceance Basin.
Impact of Increased HF Water Volumes on Oil Production
While injection volumes of water consumed during HF completions varied widely by basin, there is a conserved trend showing that the response of oil production to extreme volumes of injected HF water is largely inconsistent. Figures 10 and 11 present the production and HF water use data for the entire state of Colorado and just for the DJ Basin. The similarity in the plots makes it clear that nearly the entirety of oil production volumes reported to the state are produced from the DJ Basin.
In both plots below (Figures 10 and 11), oil production from 2013 through 2016 aligned closely with the consumed HF water volumes. In 2017, volumes of water used for HF completions rose dramatically, while oil production lagged far behind, and this trend disconnecting HF water use from oil production continued through 2022. A similar trend was visible in the data for the Piceance Basin, where spikes in the consumption of water for HF activities had little impact on oil production volumes. In the case of the Piceance both volumes of water consumption and oil production were nearly an order of magnitude smaller. The data shows that the extreme volumes of water that were consumed for HF operations since 2017 did not generate a corresponding increase in oil production of comparable magnitude. Of note, many of the HF operations in producing formations on the Western Slope target tight gas rather than tight oil.
Existing Sources of Pollution
In addition to the threat of water scarcity, the development of produced water recycling infrastructure can be completed in a manner that reduces the uncontrolled releases of pollutants that cause local and regional air quality degradation. Currently the vast majority of produced waters are re-injected underground using class II disposal wells, and recent inspections by certified thermographers show that class II injection disposal facilities are considerable sources of uncontrolled emissions.
Collaborating with FracTracker on the Front Range, Earthworks inspected class II injection well facilities using a FLIR GF320 optical gas imaging camera. Uncontrolled emissions were documented at six of the twelve sites visited. Footage from five sites are presented in the story map below. The emissions include toxic and carcinogenic volatile organic compounds (VOCs) that degrade local air quality and are the dominant precursor to ozone on the Front Range, in addition to potent greenhouse gasses such as methane. A formal complaint was submitted for each site, but none of the documented leaks were considered violations by the Colorado Air Pollution Control Division. The calculated VOC emissions from the storage tanks where we observed uncontrolled emissions were reportedly below the threshold for control measures or regulatory oversight, nevermind there were multiple tanks on each site. This is a major loophole for oil and gas operators in Colorado and is a major contributing source to ground-level ozone creation on the Front Range. Each of these documented emissions events would be blatant violations in states like California that are focused on ozone reduction, greenhouse gas reduction, and protecting communities from leaking carcinogens.
Figure 13. This storymap presents the locations of Class II wastewater injection and disposal facilities located in Colorado. These facilities were visited in March of 2023, and were inspected for emissions of methane and other hydrocarbons using a FLIR GF-320 optical gas imaging camera. Uncontrolled emissions were filmed at six of the twelve locations visited.
Current industry standards for water sourcing and disposal in Colorado are unsustainable and incredibly wasteful. Rather than prioritize sustainability and preserve access to freshwater for future agricultural and domestic needs, an entire midstream industry had developed on the Front Range of Colorado to streamline freshwater access. While these resources could instead be better applied to developing the infrastructure for wastewater recycling, Colorado operators instead continue to test the boundaries of maximum injection volumes. Total injection volumes topped 15B gallons in 2018 as operators attempted to increase production by maximizing their consumption of water, which did not result in the anticipated payoff, as shown in Figure 10. The increase in water consumption did not result in a comparable increase in oil production for the state of Colorado. At the state level, the economics of wasting the most precious natural resource does not make sense.
The FracFocus data presented showed that water consumption for HF completions peaked in 2018 with about 15B gallons consumed. In 2022, water consumption was still twice as high as 2013, when the data first started to be tracked. While 10B gallons of water may not be much compared to the total consumption for agriculture or domestic use, statewide, the other sectors do not remove fresh water from the water cycle or contaminate the water to the point of requiring specialized water treatment facilities. Additionally the vast majority (~90%) of water consumed for HF operations is occurring on the Front Range, in just Weld County. A more apt comparison is that HF operations in Weld County in 2022 used the same volume of water as the City Of Greeley Water Utility District distributes annually and one billion gallons more than the Fort Collins city water utility.
Ultimately, this report finds that the consumption of freshwater resources for HF completions in Colorado is calculably unnecessary. Operators in the state of Colorado produce enough wastewater to completely satisfy the needs of current water demands for HF operations. This is true, even if volumes of produced wastewater are only reused once. The efficacy of water sharing agreements within basins has already been proven and such tactics can be expanded throughout the state as a whole. The same goes for the implementation of wastewater treatment and recycling facilities. It is not necessary for HF completions to consume any volumes of freshwater.
Operations are expanding beyond Weld County, moving towards higher population densities like the suburbs of Denver in Adams County, as shown in the plots in Appendix A. The counties in Colorado where the majority of HF water consumption currently occurs house some of the fastest growing populations in the country. As communities grow additional stresses on freshwater resources will require a sustainable approach. Wastewater treatment and recycling practices are being employed for municipal water sources and agricultural irrigation in drought-prone areas across the country, yet the majority of the oil and gas industry has been unwilling to adopt sustainable practices so that communities can co-exist safely with the industrial extraction operations occurring around them. As shown in the OGI camera footage (Figure 13), this is evident for both air quality and freshwater conservation.
Stress on freshwater resources in arid and drought-prone regions will continue to grow as a result of climate change, particularly for areas with booming population density, like Colorado’s Front Range. As freshwater resources become stressed, the most marginalized communities will be the most impacted. Climate justice issues will accelerate as long as there is not a plan to address disparities and preserve resources sustainably. Water is the most important. Water is Life.
If passed, the proposed legislation in HB 23-1242 would be a first step in creating a sustainable framework for prioritizing freshwater conservation while oil and gas extraction continues in Colorado. As Colorado becomes more reliant on wastewater recycling, it will be important to plan for sustainable infrastructure development as well as prevent the creation of new pollution sources. A recent report by the Environmental Defense Fund outlines challenges and risks involved with existing produced water recycling, and should be used to inform the development of new recycling practices.
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