For schools and hospitals analysis, 2017

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities


View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

Utica Class II Injection
Well Distance (Miles) Schools Medical Facilities Schools Medical Facilities
0.5 3 1 9 0
0.5-1 19 (22) 9 (10) 16 (25) 13 (13)
1-2 79 (101)  41 (51) 88 (113) 79 (92)
2-3 84 (185) 49 (100) 165 (278) 122 (214)
3-4 85 (270) 79 (179) 168 (446) 112 (326)
4-5 92 (362) 63 (242) 196 (642) 166 (492)
5-10 388 (750) 338 (580) 796 (1,438) 584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.


Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).


Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

Utica Class II Injection
Well Distance (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 3 1,360 453 7 3,312 473
<1 21 7,910 377 19 7,984 420
<2 96 35,390 376 90 41,565 462
<3 169 67,713 401 215 104,752 487
<4 241 97,448 404 350 176,067 503
<5 317 137,911 435 505 254,406 504
<10 600 280,330 467 1,126 569,343 506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.


Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

Utica Class II Injection
Distance from Well (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 . . . 1 . .
<1 . . . 2 25 13
<2 2 22 11 9 186 21
<3 7 874 125 30 4,460 149
<4 12 1,912 159 45 6,303 140
<5 21 2,471 118 61 9,610 158
<10 60 6,727 112 135 20,836 154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools


View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.

figure6

Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

Marcellus Class II Injection
Distance from Well (Miles) # Sum Avg # Sum Avg
0.5 19 5,674 299 1 . .
<1 52 (71) 16,992 (22,666) 319 5 (6) 1,544 257
<2 169 (240) 52,737 (75,403) 314 16 (22) 5,032 (6,576) 299
<3 133 (373) 36,112 (111,515) 299 18 (40) 6,132 (12,708) 318
<4 88 (461) 25,037 (136,552) 296 21 (61) 5,235 (17,943) 294
<5 56 (517) 15,685 (152,237) 295 26 (87) 8,913 (26,856) 309
<10 118 (635) 37,131 (189,368) 298 228 (315) 69,339 (96,195) 305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.

Conclusion

A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

  1. their role in induced seismicity,
  2. potential water and air quality issues, and
  3. concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above


By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Oil and Gas Wastes are Radioactive – and Lack Regulatory Oversight

Highlighting the maps of radioactive oil and gas exploration and production wastes created in collaboration with the Western Organization of Research Councils

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
Scott Skokos, Western Organization of Research Councils

Oil and gas waste can be radioactive, but it is not considered “hazardous,” at least according to the federal government. In this article, we summarize several of the hazardous risks resulting from the current federal policy that fails to regulate this massive waste stream, and the gaps left by states. Of the six states mapped in this assessment, only the state of Montana has initiated any type of rule-making process to manage the waste.

When it comes to unconventional oil and gas waste streams:

Nobody can say how much of any type of waste is being produced, what it is, and where it’s ending up. – Nadia Steinzor, Earthworks

To address some of these gaps, FracTracker Alliance has been working with the Western Organization of Resources Councils (WORC) to map out exactly where radioactive oil and wastes are being dumped, stored, and injected into the ground for disposal. The work is an extension to WORC’s comprehensive No Time to Waste report.

Why is accurate waste data so hard to come by? The Earthworks report, Wasting Away explains that the U.S. EPA intentionally exempted oil and gas exploration and production wastes from the federal regulations known as the Resource Conservation and Recovery Act (RCRA) despite concluding that such wastes “contain a wide variety of hazardous constituents.” As a result, there is very little waste tracking and reporting of oil and gas waste data nationally.

State Waste Management Maps

Some data is available at the state level, so we at FracTracker have compiled, cleaned, and mapped what little data we could find.

State-specific maps have been created for Montana, North Dakota, Colorado, and Wyoming – see below:

ND Radioactive Waste mapNorth Dakota – View map fullscreen

co-radioactive-featureColorado – View map fullscreen

Sources of Radioactivity

When we hear about “radioactive waste” associated with the energy industry, nuclear power stations and fission reactors are usually what come to mind. But, as the EPA explains, fracking has transformed the nature of the oil and gas waste stream. Components of fracking waste differ from conventional oil and gas exploration and production wastes in a number of ways:

  • In general, the waste stream has additional hazardous components, and that transformation includes increased radioactivity.
  • Fracking has allowed for more intrusive drilling, penetrating deep sedimentary formations using millions of gallons of fluid.
  • Drilling deeper produces more drill cuttings.
  • The process of hydraulic fracking introduces millions more gallons of fluid into the ground that then return to the surface. These returns are ultimately contaminated and require disposal.
  • The formations targeted for unconventional development are mostly ancient seabeds still filled with salty “brines” known as “formation waters.”
  • In addition to the hazardous chemicals in the fracking fluid pumped into the wells for fracking, these unconventional formations contain larger amounts of heavy metals, carcinogens and other toxics. This also includes more radioisotopes such as Uranium, Thorium, Radium, Potassium-40, Lead-210, and Polonium-210 than the conventional formations that have supplied the majority of oil and gas prior to the shale boom.

A variety of waste products make up the waste stream of oil and gas development, and each is enhanced with naturally occurring radioactive materials (NORM). This waste stream must be treated and disposed of properly. All the oil and gas equipment – such as production equipment, processing equipment, produced water handing equipment, and waste management equipment – also need to be considered as sources of radioactive exposure.

Figure 1 below explains where the waste from fracking goes after it leaves the well pad.

Radioactive Oil and Gas Pathway Life Cycle

Figure 1. Breakdown of the radioactive oil and gas waste life-cycle

Three facets of the waste stream particularly enhanced with NORMs by fracking include scales, produced waters, and sludges.

A. Scales

When injected into the ground, fracking fluid mixes with formation waters, dissolving metals, radioisotopes and other inorganic compounds. Additionally the fracking liquids are often supplemented with strong acids to reduce “scaling” from precipitate build up (to prevent clogging up the well). Regardless, each oil well generates approximately 100 tons of radioactive scale annually. As each oil and gas reservoir is drained, the amount of scale increases. The EPA reports that lead-210 and polonium-210 are commonly found in scales along with their decay product radon at concentrations estimated to be anywhere from 480 picocuries per gram (pCi/g) to 400,000 pCi/g). Scale can be disposed of as a solid waste, or dissolved using “scale inhibitors.” These radioactive elements then end up in the liquid waste portion of the waste stream, known as produced waters.

B. Produced Waters

In California, strong acids are used to further dissolve formations to stimulate additional oil production. Acidic liquids are able to dissolve more inorganic elements and compounds such as radioisotopes. While uranium and thorium are not soluble in water, their radioactive decay products such as radium dissolve in the brines. The brines return to the surface as “produced water.” As the oil and gas in the formation are removed, much of what is pumped to the surface is formation water.

Consequently, declining oil and gas fields generate more produced water. The ratio of produced water to oil in conventional well was approximately 10 barrels of produced water per barrel of oil. According to the American Petroleum Institute (API), more than 18 billion barrels of waste fluids from oil and gas production are generated annually in the United States. There are several options for managing the liquid waste stream. The waste could be treated using waste treatment facilities, reinjected into other wells to enhance production (a cheaper option), or injected for disposal. Before disposal of the liquid portion, all the solids in the solution must be removed, resulting in a “sludge.”

C. Sludges

The U.S. EPA reports that conventional oil production alone produces 230,000 million tons – or five million ft3 (141 cubic meters) – of TENORM sludge each year. Unconventional processes produce much more sludge waste than conventional processes. The average concentration of radium in sludges is estimated to be 75 pCi/g, while the concentration of lead-210 can be over 27,000 pCi/g. Sludges present a high risk to the environment and a higher risk of exposure for people and other receptors in those environments because sludges are typically very water soluble.

Federal Exemptions

According to the EPA, “because the extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact, these wastes are classified as Technologically Enhanced Naturally Occurring Radioactive Material (TENORM).” Despite the conclusions that oil and gas TENORM pose a risk to the environment and humans, the EPA exempts oil and gas exploration and production wastes from the definition of “hazardous” under Resource Conservation and Recovery Act (RCRA) law. In fact, most wastes from all of the U.S. fossil fuel energy industry, including coal-burning and natural gas, are exempt from the disposal standards that hazardous waste normally requires.

The Center for Public Integrity calls this radioactive waste stream “orphan waste,” because no single government agency is fully managing it.

Fortunately, the EPA has acknowledged that federal regulations are currently inadequate, though this is nothing new. A U.S. EPA report from the 1980’s reported as much, and gave explicit recommendations to address the issue. For 30 years nothing happened! Then in August, 2015, a coalition of environmental groups (including the Environmental Integrity ProjectNatural Resources Defense CouncilEarthworksResponsible Drilling AllianceWest Virginia Surface Owners’ Rights Organization, and the Center for Health, Environment and Justice) filed a lawsuit against the EPA, and has since reached a settlement.

Just last month (January 10, 2017) the U.S. EPA agreed to review federal regulations of oil and gas waste – a process they were meant to do every 3 years for the last 30 years. The EPA has until March 15, 2019, to determine whether or not regulatory changes are warranted for “wastes associated with the exploration, development, or production of crude oil, natural gas, or geothermal energy.” With the recent freeze on all U.S. EPA grants, however, it is not clear whether these regulations will receive the review they need.

State Regulations

Regulation of this waste stream is left up to the states, but most states do not require operators to manage the radioactivity in oil and gas wastes, either. Because of the federal RCRA exemptions most state policies ignore the radioactive issue altogether. Operators are free to dispose of the waste at any landfill facility, unless the landfill tells them otherwise. For detailed analyses of state policies, see pages 10-45 of the No Time to Waste report. FracTracker has also covered these issues in Pennsylvania and Ohio.

Another issue that screams for federal consideration of this waste stream is that states do not have the authority to determine whether or not the wastes can cross their borders. States also do not have the jurisdiction to decide whether or not facilities in their state can accept waste from across state lines. That determination is reserved for federal jurisdiction, and there are not any federal laws regulating such wastes. In fact, these wastes are strategically exempt from federal regulation for just these reasons.

Why can’t the waste be treated?

This type of industrial waste actually cannot be treated, at least not entirely. Unlike organic pollutants that can be broken down, inorganic constituents of the waste cannot be simply disintegrated out of existence. Inorganic components include heavy metals like arsenic and bromides, as well as radioactive isotopes of radium, lead, and uranium. Such elements will continue to emit radiation for hundreds-to-thousands of years. The best option available is to find a location to “isolate” and dispose of these wastes – a sacrifice zone.

Current management practices do their best to separate the liquid portions from the solid portions, but that’s about it. Each portion can then be disposed independently of each other. Liquids are injected into the ground, which is the cheapest option where it is available. If enough of the dissolved components (heavy metals, salts, and radioisotopes) can be removed, wastewaters are discharged into surface waters. The compounds and elements that are removed from the liquid waste stream are hyper-concentrated in the solid portion of the waste, described as “sludge” in the graphic above. This hazardous material can be disposed of in municipal or solid waste landfills if the state regulators do not require the radioactivity or toxicity of this material to be a consideration for disposal. There are not federal requirements, so unless there is a specific state policy regarding the disposal, it can end up almost anywhere with little oversight. These chemicals do not magically disappear. They never disappear.

Risks

There are multiple pathways for contamination from facilities that are not qualified to manage radioactive and hazardous wastes. At least seven different environmental pathways provide potential risks for human exposure. They include:

  1. Radon inhalation,
  2. External gamma exposure,
  3. Groundwater ingestion,
  4. Surface water ingestion,
  5. Dust inhalation,
  6. Food ingestion, and
  7. Skin beta exposure from particles containing the radioisotopes.

According to the EPA, the low-level radioactive materials in drilling waste present a definitive risk to those exposed. High risk examples include dust suppression and leaching. If dust is not continuously suppressed, radioactive materials in dust pose a risk to people at these facilities or those receptors or secondary pathways located downwind of the facilities. Radioactive leachate entering surface waters and groundwaters is also a significant threat. A major consideration is that radioactive waste can last in these landfills far longer than the engineered lifespans of landfills, particularly those that are not designed to retain hazardous wastes.

Cases of Contamination

North Dakota

In North Dakota, the epicenter of the Bakken Oil Fields, regulators were not ready for the massive waste streams that came from the fast growing oil fields. This  allowed thousands of wastewater disposal wells be drilled to dispose of salty wastewater without much oversight, and no places in state for companies to dispose of radioactive solid waste. Many of the wastewater disposal wells were drilled haphazardly, and as a result many contaminated surrounding farmland with wastewater. With regard to radioactive solid waste, the state until recently had a de facto ban on solid radioactive waste disposal due to their radioactivity limit being 5 picocuries per gram. The result of this de facto ban made it so companies either had to make one of two decisions: 1. Haul their radioactive solid waste above the limit out of state to facilities in Idaho or Colorado; or 2. Risk getting caught illegally dumping waste in municipal landfills or just plain illegal dumping in roadsides, buildings, or farmland.

In 2014, a massive illegal dumping site was discovered in Noonan, ND when North Dakota regulators found a gas station full of radioactive waste and filter socks (the socks used to filter out solid waste from wastewater, which contain high levels of radioactivity). Following the Noonan, ND incident North Dakota regulators and politicians began discussions regarding the need for new regulations to address radioactive solid waste.

In 2015, North Dakota moved to create rules for the disposal of solid radioactive waste. Its new regulations increase the radioactivity limit from 5 picocuries per gram to 50 picocuries per gram, and sets up new requirements for the permitting of waste facilities accepting radioactive waste and the disposal of radioactive waste in the waste facilities. Dakota Resource Council, a member group of WORC, challenged the rules in the courts, arguing the rules are not protective enough and that the agency responsible for the rules pushed through the rules without following the proper procedures. Currently the rules are not in effect until the litigation is settled.

Pennsylvania

In Pennsylvania, the hotbed of activity for Marcellus Shale gas extraction, the regulatory body was ill equipped and uninformed for dealing with the new massive waste stream when it first arrived on scene. Through 2013, the majority of wastewater was disposed of in commercial and municipal wastewater treatment facilities that discharge to surface waters. Numerous facilities engaged in this practice without amending their federal discharge permits to include this new waste stream.

Waste treatment facilities in Pennsylvania tried to make the waste streams less innocuous by diluting the concentrations of these hazardous pollutants. They did this by mixing the fracking wastes with other waste streams, including industrial discharges and municipal waste. Other specialized facilities also tried to remove these dissolved inorganic elements and filter them from the discharge stream.

As a result of site assessments by yours-truly and additional academic research, these facilities realized that such hazardous compounds do not simply dilute into receiving waters such as the Allegheny, Monongahela, and Ohio rivers. Instead, they partition (settle) into sediments where they are hyper-concentrated. As a result of the lawsuits that followed the research, entire river bottoms in Pennsylvania had to be entirely dug up, removed, and disposed of in hazardous waste landfills.

Action Plans Needed

Massive amounts of solid and liquid wastes are still generated during drilling exploration and production from the Marcellus Shale. There is so much waste, operators don’t know what to do with it. In Pennsylvania, there is not much they can do with it, but it is not just Pennsylvania. Throughout the Ohio River Valley, operators struggle to dispose of this incredibly large waste stream.

Ohio, West Virginia, and Pennsylvania have all learned that this waste should not be allowed to be discharged to surface waters even after treatment. So it goes to other states – those without production or the regulatory framework to manage the wastes. Like every phase of production in the oil and gas industry, operators (drillers) shop around for the lowest disposal costs. In Estill County, Kentucky, the State Energy and Environment Department just recently cited the disposal company Advance Disposal Services Blue Ridge Landfill for illegally dumping hydraulic fracturing waste. The waste had traveled from West Virginia Marcellus wells, and ended up at an ignorant or willfully negligent waste facility.

In summary, there is inadequate federal oversight of potentially hazardous waste coming from the oil and gas industry, and there are serious regulatory gaps within and between states. Data management practices, too, are lacking. How then, is the public health community supposed to assess the risk that the waste stream poses to people? Obviously, a more thorough action plan is needed to address this issue.


Feature image: Drill cuttings being prepared to be hauled away from the well pad. Photo by Bill Hughes, OVEC

Koontz Class II Injection Well, Trumbull County, Ohio, (41.22806065, -80.87669281) with 260,278 barrels (10,020,704 gallons) of fracking waste having been processed between Q3-2010 and Q3-2012 (Note: Q1-2016 volumes have yet to be reported!).

Ohio Shale Activity, Waste Disposal, and Public Water Supplies

Ohio is unique relative to its Appalachian neighbors in the Marcellus and Utica Shale Basins in that The Buckeye State chose to “diversify” when it came to planning for the hydraulic fracturing revolution. One of the first things financial advisers tell their clients is to “diversify, diversify, diversify.” However, this strategy is usually meant to buffer investors when certain sectors of the economy underperform. Columbus legislators took this strategy to mean that we should drill and hydraulically fracture our geology to extract oil and gas (O&G), as well as taking in vast quantities of liquid and solid O&G waste from Pennsylvania and West Virginia.

Accepting significant quantities of out-of-state waste raises several critical questions, however. How will these materials will be contained? Will such volumes require more and larger waste landfills? And will the injection of liquid brine waste into our geology (photo below) make Ohio the “Oklahoma of Appalachia” with respect to induced seismicity?


Above: Example Class II salt water disposal (SWD) wells in Ohio

Risks to Public Water Supplies

There are also mounting concerns about public water supply (PWS) security, quality, and resilience. These concerns stem from the growing uncertainty surrounding the containment of hydraulically fractured and Class II injection wells.

To begin to assess the risks involved in locating these wells near PWS’s, we compiled and incorporated as many of the state’s PWS’s into our primary Ohio maps. In this post, we explore PWS proximity to Utica drilling activity and Class II salt water disposal (SWD) wells in Ohio.

Waste Disposal & Drilling Near PWS’s

Public water chartJust how close are public water supplies to Class II waste disposal wells and permitted Utica wells? As of January 15, 2017, there are 13 PWS’s within a half-mile of Ohio’s Class II SWD wells, and 18 within a half-mile of permitted Utica wells. These facilities serve approximately 2,000 Ohioans each, with an average of 112-153 people per PWS (Tables 1 and 5). Within one mile from these wells there are 64 to 66 PWSs serving 18 to 61 thousand Ohioans. That’s an average of 285-925 residents.

Above: Photos of SWD wells from the sky

While PWSs on the 5-mile perimeter of our analysis don’t immediately conjure up water quality/quantity concerns, they may in the future; the rate of Utica and Class II permitting is likely to accelerate under a new White House administration more friendly to industry and averse to enforcing or enhancing regulatory hurdles.

A total of 960 and 699 PWSs are currently within five miles of Ohio Class II and Utica wells. These facilities service roughly 1.5 million and one-half million Ohioans each day, which is ~13% and 4% of the state, respectively. The average PWS within range of Class II wells is 37% to 330 times the average PWS within range of Utica wells.

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Fifty-eight (58%) to 69% of the PWSs within range of Class II wells are what the Ohio EPA calls Transient Non-Community (TNC) (Table 2). TNC’s are defined by the OH EPA and OH Department of Agriculture as serving[1]:

…at least 25 different persons over 60 days per year. Examples include campgrounds, restaurants and gas stations. In addition, drinking water systems associated with agricultural migrant labor camps, as defined by the Ohio Department of Agriculture, are regulated even though they may not meet the minimum number of people or service connections.

Meanwhile 60-89% of PWS’s in the shadow of Ohio’s permitted Utica wells are of the TNC variety. Even larger percentages of these PWS’s are either Groundwater or Purchased Groundwater types. Most of the PWS’s within the range gradient we looked at are privately owned, with only handful owned by federal or state agencies (Table 6).

Above: Example Class II salt water disposal (SWD) wells in Ohio

Of the 24 hydrologic unit codes (HUCs)/watersheds that contain Class II SWD wells, the lion’s share of PWS’s within the shadow of injection wells are the Tuscarawas, Mahoning, and Walhonding (Table 3). Even the Cuyahoga River, which feeds directly in the Great Lakes, is home to up to 138 PWS’s within 5 miles of Class II SWD wells. Conversely, only 13 HUCs currently contain Ohio’s Utica wells. Like Class II-affected HUCs, we see that the Mahoning, Tuscarawas, and Cuyahoga PSW’s contain most of the PWSs of interest (Table 7).

Conclusion

Watershed security/resilience concerns are growing in Eastern Ohio. Residential and agricultural water demands are increasingly coming into conflict with the drilling industry’s growing freshwater demand. Additionally, as oil and gas drilling uses more water, we will see more brine produced (Figures 1 and 2).

This, in turn, will create more demand – on top of an already exponential trend (Figure 3) – for Ohio’s existing Class II wells from across Northern Appalachia, stretching from Southeast Ohio and West Virginia to North Central Pennsylvania.

An understanding of the links between watershed security, O&G freshwater demand, brine production, and frack waste disposal is even more critical in areas like Southeast Ohio’s Muskingum River Watershed (Figure 4).

A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz, E. 2015

Figure 4. A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz and Auch 2015

This is a region of the state where we have seen new water withdrawal agreements like the one below between the Muskingum River Watershed Conservancy District (MWCD) and Antero described in last week’s Caldwell Journal-Leader, Noble County, Ohio:

The [MWCD], which oversees 10 lakes in east central Ohio, approved a second short-term water sale from Seneca Lake last week. The deal, with Antero Resources, Inc., could net the district up to $9,000 a day over about a three month period, and allows Antero to draw up to 1.5 million gallons of water a day during the months of August, September and October for a total of 135 million gallons; less than one percent of the lake’s estimated volume of 14.2 billion gallons. Antero plans to use the water in its fracking operations in the area and will pay $6 per 1000 gallons drawn.

Consol Energy's Cowgill Road Impoundment, Sarahsville, Wills Creek, Noble County, Ohio, 39.8212, -81.4061

Consol Energy’s Cowgill Road Impoundment, Sarahsville, Wills Creek, Muskingum River Watershed, Noble County, Ohio, 39.8212, -81.4061

This agreement will mean an increase in new Class II SWD permits and/or discussion about converting Ohio’s thousands of other Class II wells into SWD wells. What does this change means for communities that have already seen the industry extract the equivalent of nearly 14% – and even 25-80% in several counties – of residential water from their watersheds, only to inject it 6,000+ feet into the state’s geology is unknown? (Figure 5)

It is critical that we establish and frequently revisit the spatial relationship between oil and gas infrastructure the water supplies of Appalachian Ohio. The state of national politics, federal agency oversight and administrations, growing concerns around climate change, and the fact that Southeast Ohio is experiencing more intense and infrequent precipitation events are testaments to that fact. We will be tracking these changes to Ohio’s landscape as they develop. Stay tuned.

Kleese Disposal Class II Salt Water Disposal Well, Trumbull County, Shenango/Mahoning River, 41.244, -80.641, 3,548,104 Barrels of Waste Disposed Between 2010 and Q3-2016

Kleese Disposal Class II Salt Water Disposal well from the sky, Trumbull County, Shenango/Mahoning River, 41.244, -80.641. Data suggest 3,548,104 barrels of waste have been disposed of there between 2010 and Q3-2016.


Supplemental Tables

Public Water and Class II Wells

Table 1. Number of Ohio public water supplies and population served at several intervals from Class II Injection wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 13 1,992 153 (±120) 446
<1 66 60,539 917 (±4,702) 37,456
<2 198 278,402 1,406 (±4,374) 37,456
<3 426 681,969 1,601(±8,187) 148,000
<4 681 1,086,463 1,596 (±8,284) 148,000
<5 960 1,450,865 1,511 (±7,529) 148,000

 

Table 2. Ohio public water supplies by system type, source, and ownership at several intervals from Class II Injection wells

 

Well Distance (Miles)

System Type† Source†† Ownership
 

NTNC

 

TNC

 

C

 

G

 

GP

 

S

 

SP

 

Private

 

Local

 

Fed

 

State

0.5 3 9 1 13 13
<1 11 47 8 65 1 61 5
<2 30 118 50 177 16 5 164 34
<3 76 245 105 385 32 8 351 75
<4 122 392 167 628 40 12 574 106 1
<5 162 564 234 878 30 32 19 823 135 1 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

Table 3. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from Class II Injection wells

 

HUC Name

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula-Chagrin, 799 1 5 18 18 22
Black-Rocky, 859 1 1 2 2 9
Cuyahoga, 832 1 8 20 92 92 138
Grand, 811 12 30 71 71 81
Hocking, 1081 4 18 18 22
Licking, 1010 1 2 17 17 29
Little Muskingum-Middle Island, 1062 1 2 2 6
Lower Maumee, 856 2 2 4
Lower Scioto, 1091 6 6 9
Mahoning, 831 9 17 48 129 129 161
Mohican, 919 1 3 3 4
Muskingum, 1006 1 3 15 15 33
Raccoon-Symmes, 1128 1
Sandusky, 862 3 19 19 27
Shenango, 815 1 2 6 10 10 11
St. Mary’s, 934 3 5 5 7
Tiffin, 837 4 4 7
Tuscarawas, 889 1 9 76 147 147 213
Upper Ohio, 901 3 15 15 23
Upper Ohio-Shade, 1120 4 8 8 9
Upper Ohio-Wheeling, 984 1 1 4 4 5
Upper Scioto, 959 5 13 13 23
Walhonding, 906 1 11 26 69 69 101
Wills, 1009 2 3 12 12 14

 

Table 4. Ohio public water supplies by county at several intervals from Class II Injection wells

 

County

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 4 9 16 19 22
Athens 1 2 2 3
Auglaize 3 5 5 7
Belmont 1 4 5 6
Carroll 2 9 20
Columbiana 1 2 6 13 20 32
Coshocton 7 8 10 13
Crawford 1
Cuyahoga 1
Delaware 1
Fairfield 4
Franklin 1 3 7
Fulton 2 4 8
Gallia 1
Geauga 8 19 33 60 71
Guernsey 2 4 10 11 11
Harrison 1 1
Henry 2 3 3
Henry 2 3
Hocking 3 10 11 13
Holmes 1 11 34 25 38 47
Jefferson 1 3 3 5
Knox 2 6 8 9
Lake 1 4 7 17 18
Licking 1 2 10 14 26
Lorain 1 4
Mahoning 3 4 13 25 37 48
Medina 1 1 1 2 5
Meigs 4 5 6 7
Morgan 1 1 1 6 17
Morrow 3 8 11 11
Muskingum 3 8 15
Noble 1 2 2 3
Perry 5 6 8
Pickaway 2 3 7 10
Portage 3 12 41 62 90 113
Seneca 1 12 17 21
Stark 1 4 20 52 121 161
Summit 2 12 26 51
Trumbull 3 7 24 32 45 61
Tuscarawas 6 10 22 24 26
Washington 1 2 4 9
Wayne 1 1 9 18 24 54
Wyandot 2 2 2 3

Public Water and Hydraulically Fractured Wells

Table 5. The number of Ohio public water supplies and population served at several intervals from hydraulically fractured Utica Wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 18 2,010 112 (±72) 31
<1 64 17,879 279 (±456) 2,598
<2 235 116,682 497 (±1,237) 8,728
<3 433 257,292 594 (±2,086) 29,787
<4 572 380,939 666 (±2,404) 29,787
<5 699 496,740 711 (±2,862) 47,348

 

Table 6. Ohio public water supplies by system type, source, and ownership at several intervals from hydraulically fractured Utica Wells

 

Well Distance (Miles)

System Type† Source†† Ownership
 

NTNC

 

TNC

 

C

 

G

 

GP

 

S

 

SP

 

Private

 

Local

 

Fed

 

State

0.5 1 16 1 17 1 18
<1 9 45 10 59 3 1 1 58 6
<2 50 137 48 216 6 3 10 206 29
<3 83 265 85 400 14 5 14 381 51 1
<4 109 352 111 534 16 7 15 504 67 1
<5 141 421 137 652 19 9 18 621 77 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

 

Table 7. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from hydraulically fractured Utica wells

 

HUC Name

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Black-Rocky, 859 1 4 4 4
Cuyahoga, 832 2 12 31 54 82
Grand, 811 1 15 18 23
Licking, 1010 2 2 3 3
Little Muskingum-Middle Island, 1062 2 5 10 11 11
Mahoning, 831 2 5 48 105 142 175
Muskingum, 1006 3 7 9 11
Shenango, 815 2 5 10 13 14
Tuscarawas, 889 8 28 87 140 178 220
Upper Ohio, 901 7 20 45 66 72 73
Upper Ohio-Wheeling, 984 1 13 23 27 28
Walhonding, 906 10 15 34 47
Wills, 1009 2 3 5 7 8

 

 

Table 8. Ohio public water supplies by county at several intervals from hydraulically fractured Utica wells

 

County

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 1 1
Belmont 1 2 7 14 15 16
Carroll 6 20 36 43 43 43
Columbiana 4 15 45 72 80 81
Coshocton 7 10 10
Geauga 14 20 25
Guernsey 1 1 2 4 5
Harrison 2 6 16 16 16 16
Holmes 5 13 31 43
Jefferson 2 3 11 22 25 25
Knox 1 1 2 2
Licking 1 1 1 1
Mahoning 2 10 32 44 55
Medina 1 4 5 7
Monroe 2 4 6 6 6
Muskingum 1 1 1 2 3
Noble 2 2 2 2
Portage 2 8 25 49 84
Stark 2 5 40 85 110 122
Summit 6 10
Trumbull 3 23 36 53 65
Tuscarawas 1 2 15 22 28 43
Washington 3 10 12 13
Wayne 5 5 7 21

Footnote

  1. Community (C) = serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. Examples include cities, mobile home parks and nursing homes; Non-Transient, Non-Community (NTNC) = serve at least 25 of the same persons over six months per year. Examples include schools, hospitals and factories.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Power Plants & Other Facilities Now on Ohio Oil & Gas Map

Over the last few months we’ve been busy working on some updates to our Ohio Oil & Gas Map. Check out what we’ve added recently and explore the map below!

New: Power Plants & ATEX Pipeline

We now have the locations of eight of the credible natural gas power plants proposed in Ohio, along with the jobs they cite during construction and operations. We also now have a complete inventory of 118 existing power plants, including 25 natural gas facilities. Together, these plants would produce 7,660 megawatts, around 957 per facility.

Six of these plants are either in the heart of Ohio’s Utica Shale or within several miles of the 1,200+ mile Appalachia-to-Texas (ATEX) pipeline. ATEX was installed to transport 190,000 barrels per day (BPD) of natural gas liquids (NGLs) from the Marcellus and Utica region to the Texas and Louisiana Gulf Goast refinery corridor. The 360 mile segment of this pipeline that runs from Pennsylvania to south central Jackson County, Indiana is also now shown on the Ohio Oil & Gas Map.

Late Permitting Increases

Cumulative and Monthly Ohio Utica Hydraulic Fracturing Well Permits

Figure 1. Cumulative and monthly hydraulic fracturing well permits in Ohio’s Utica Shale

While many shale plays across the United States are experiencing a period of contraction (with low gas prices often cited as the primary reason), drilling activity in Ohio’s Utica Shale has been experiencing a slow and steady expansion. The region has seen more than 2,700 permitted wells as of the end of January 2017. Incidentally, roughly 59% of these wells are producing either oil or gas as of Q3-2016. For more information on that subject, explore our production map.

The permitting trajectory hit a low of 13-16 permits per month between February and January of 2016. Since the presidential election in November, however, permitting rates have more than doubled (Figure 1).

Ohio Oil & Gas Map

Ohio sits on the western edge of both the Utica and Marcellus Shale formations, but conditions are such that the Marcellus Shale is all but being ignored in Ohio. Explore our updated map of OH drilling activity and related facilities below:


View map fullscreen | How FracTracker maps work

Map Layers

The map above is made up of various datasets, from the location of permits to compressor stations. These “map layers” make up the legend. Below we describe each layer on the map, as well as the data source and date range.


Horizontal Marcellus Permits, Laterals
There have been 40+ permits issued for horizontal wells in Ohio’s Marcellus Shale.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present


Horizontal Utica Permits
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time Ohio is home to 2,160+ permitted Utica Wells with the wells broken out by status. Additionally this layer contains depth, water usage, sand usage, HCl, and Gelling Agent percentage for 249 wells based on data provided to FracFocus. Finally, we have incorporated production in various units from individual industry press releases and the ODNR annual report.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present


Horizontal Utica Permits actual and straight line laterals
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time we have straight line laterals for all drilled, drilling, and producing wells as well as actual PLAT laterals for 341 of the wells.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present


High Volume Hydraulic Fracturing Gathering Lines
All gathering lines servicing Ohio’s inventory of High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015


High Volume Hydraulic Fracturing Well Pads
The well-pads of all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015


High Volume Hydraulic Fracturing Well Pad’s Limits Of Disturbance (LOD)
Limits Of Disturbance (LOD) for all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) well-pads.

Source: Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015


Compressor Stations and Cracking Facilities
Boundaries of several confirmed High Volume Hydraulic Fracturing (HVHF) servicing cracking and compressor station facilities.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015


Ohio Active Class II Injection Wells
This data speaks to the state’s “Active” Class II Injection wells able to accept hydraulic fracturing waste. There are 240+ Active Wells with 51 having yet to receive waste from hydraulic fracturing. For more on Ohio’s Class II Inventory in depth refer to our recent Ohio Fracking Waste Transport & Disposal Network article.

Source:   Ohio Department of Natural Resources
Date Range:  Historical to October, 2015


Earthquakes of >2.0 Magnitude
This data speaks to the state’s 258 earthquakes with current updates from the Ohio Seismic Network and historical quakes – all >2.0 magnitude. These data come from the department’s inventory. Additionally, we present Ohio earthquakes with <2.0 magnitude courtesy of Environment Canada’s Search the Earthquake Database platform.

Source: Ohio Department of Natural Resources, Division of Geological Survey, The Ohio Seismic Network
Date Range:  Historical to Present

AG Pruitt testifies before a congressional committee on issues surrounding energy and the environment

“Polluting Pruitt:” A Wolf to Guard the Hen House?

Guest article by Dakota Raynes, Co-Organizer of Stop Fracking Payne County (OK)

President Trump recently tapped Oklahoma Attorney General Scott Pruitt to head the Environmental Protection Agency (EPA), even though Pruitt is a self-proclaimed “leading advocate against the EPA’s activist agenda.” Pruitt is currently opposing investigation of Exxon Mobile’s handling of climate-change science based on the belief that climate change science is not yet settled and “debate should be encouraged in classrooms, public forums, and the halls of Congress.” Senate confirmation hearings regarding Pruitt’s nomination are currently ongoing – many questions have focused on Pruitt’s legacy as AG of OK and what that tells us about actions he might take as head of the EPA.

Pruitt’s Past as AG

Elected in 2010, Pruitt’s six-year tenure illuminates the full extent of the troubling stances he takes. For instance, he has fought against the overturn of DOMA, same-sex marriage rights, granting legal status to undocumented immigrants, the Affordable Care Act, access to safe and affordable birth control and abortions, and Dodd-Frank Wall Street reform. These actions demonstrate Pruitt’s inability to accept or implement procedures, policies, and programs supported by a majority of US residents, members of the nations’ highest courts, and even his own colleagues.

A Focus on Environmental Issues

More specifically related to environmental issues, he has openly criticized the EPA in congressional hearings and op-ed pieces. Due to his belief that the EPA frequently abuses its authority, Pruitt’s office has filed 14 antiregulatory lawsuits against the EPA. Investigative reporters uncovered that in 13 of these cases co-litigators included companies that had contributed significant amounts of money to Pruitt and/or Pruitt-affiliated political action committees (PACs). He also routinely joins lawsuits against other states. For example, Pruitt and five other Attorneys General challenged a California law banning the sale of eggs laid by hens living in cramped conditions, but a US District Judge ruled they lacked legal standing because they were representing the economic interests of a few industrial egg producers rather than the interests of their broader constituents.

Several such lawsuits are still pending, which legal experts and others claim presents a conflict of interest should Pruitt become the new Director of the EPA. When asked specifically about this issue during Senate confirmation hearings, Pruitt refused to recuse himself from the lawsuits, saying he would leave such a decision up to the EPA’s legal counsel team. Notably, across the course of his six-years as AG, Pruitt’s office has distributed more than 700 news releases announcing the office’s actions, his speeches and public appearances, and efforts to challenge federal regulations. More than 50 of these releases promoted the office’s efforts to sue the EPA, but not once has a release described actions the office has taken to enforce environmental laws or to hold violators accountable for their actions.

Potential Conflicts of Interest

In OK, Pruitt has made many choices, that when viewed together, strongly suggest that his loyalties reside with the industries that have donated hundreds of thousands of dollars to his election campaigns rather than with the people he is sworn to protect. Here is a short list of the most troubling examples:

  • Pruitt’s predecessor had filed suit against Tyson, Cargill, and a number of other poultry producers in OK due to inappropriate disposal of an estimated 300,000 tons of animal waste per year, which was causing toxic algae blooms along the Illinois River. But shortly after his election, Pruitt dropped the case, citing a need for more research. Some have questioned whether his decision was impacted by the fact that the poultry industry had donated at least $40,000 to his campaign that year.
  • He also quickly dismantled the Attorney General’s in-house environmental protection unit, a team of four attorneys and a criminal investigator, and replaced it with the state’s first “federalism unit,” which was created to litigate against overreach by the federal government, mostly the EPA. Pruitt has repeatedly made it clear that he believes states should handle environmental issues, regardless of the fact that environmental issues frequently cause problems that cross geopolitical boundaries such as state lines (OK’s induced seismicity issue1 is a key example, more information about induced seismicity can be found here).
  • In 2013, he created a coalition of 9 Attorneys General, major energy CEOs, and their lawyers and brought them all to OK for a strategizing session regarding how to stop government and citizen responses to the ills of the oil and gas industry; it was an all-expenses paid event funded by Mercatus, a right-wing think tank favored by the Koch brothers.
    1. Notably, the energy industry is Pruitt’s second largest campaign contributor. When he came up for re-election in 2013, he chose Harold Hamm (CEO of Continental Resources, one of the largest oil companies in OK) to co-chair his campaign. Shortly after winning reelection in 2014, Pruitt joined forces with key industry players including Oklahoma Gas and Electric and the Domestic Energy Producers Alliance (chaired by Hamm) to file several antiregulatory lawsuits, which include attempts to block the Clean Power Plan and Waters of the US rule.
    2. Pruitt has also served as leader of the Republican Association of Attorneys General, which has collected at least $4.2 million in donations from fossil-fuel related companies since 2013.
  • Recently, local investigative reporters discovered that Pruitt’s office failed to follow a state law requiring state agencies to disclose spending on outside attorneys. Their examination illuminated that Pruitt has spent more than $1 million on legal fees since FY2012 – a total that does not include costs directly related to lawsuits against the EPA or the Affordable Care Act.

Induced-Seismicity and Wastewater Disposal

OK Map of Recent Earthquakes for Pruitt article

Map of Oklahoma Class II Injection Wells and Volumes 2011 to 2015 (Barrels). Click image to explore a full screen, dynamic map.

Oklahoma recently became the earthquake capital of the world due to a phenomenon referred to as injection-induced seismicity. While OK has not historically been known as a seismically active area, thousands of tremors have shaken the state since the shale gas boom began.

Several researchers have used geospatial analysis to demonstrate how these quakes are caused by the high-pressure injection of oil and gas industry wastes such as the flowback and produced water created by the unconventional oil and gas production process known as hydraulic fracturing. The map above shows where injection wells (tan dots) are located and where earthquakes (green dots) occurred from 2011-2015.

Oklahomans have been harmed by the implicitly pro-fracking stance Pruitt has taken, as evidenced by his lack of action regarding induced seismicity – as well as air, water, and soil contamination due to oil and gas industry activities. Several people, including Johnson Bridgewater (Director of OK Chapter of the Sierra Club) have noted that:

There are various places where the attorney general’s office could have stepped in to fix this overall problem…Its job is to protect citizens. Other states were proactive and took these issues on…[yet] Pruitt has been completely silent in the face of a major environmental problem for the state and its taxpayers.

Specifically, the AG’s office could have responded to the legal question of whether the state could limit or ban transport of fracking-related wastewater, sent by other states for disposal in underground injection wells in OK.

He also did nothing to address the phenomenally low earthquake insurance claim approval rate; after the 5.8M quake shook Pawnee in September of 2016, 274 earthquake damage claims were filed but only 4 paid out. Estimates of statewide approval rates generally suggest that approximately 1% of claimants receive funds to aid repairs.

Lastly, there are a number of class action lawsuits against a variety of industry actors regarding earthquake damages, yet Pruitt’s office has not entered any of these as an intervenor even though AGs in other states have done so.

Pruitt not at fault?

Photo Credit: JIM BECKEL/The Oklahoman

Earthquake damage. Photo Credit: Jim Beckel/The Oklahoman

Pruitt was recently called out by investigative reporters who used open-records requests to reveal that letters, briefs, and lawsuits that he submitted were written in whole or in part by leading energy firms such as Devon (another of OK’s largest oil and gas companies). Pruitt’s response was that he had done nothing wrong, nothing even potentially problematic. Rather, he said, of course he was working closely with industry and isn’t that what he should be doing. Some would argue that as AG what he should be doing is working closely with the people of Oklahoma, especially those whose homes, lives, and livelihoods have crumbled under the weight of attempting to repair earthquake damage due to industry activities.

Historical AG Influence

It is important to remember, though, that what’s happening with Pruitt is not isolated. Rather, as several long-time reporters have noted, increased attention to developing beneficial relationships with AGs is a result of historical processes.

About 20 years ago more than 40 state AGs banded together to challenge the tobacco industry, which led to a historic $206 billion settlement decision. Later, Microsoft, the pharmaceutical industry, and the financial services industry each faced similar multistate challenges regarding the legality or illegality of particular business practices.

As some AGs began hiring outside law firms to investigate and sue corporations, industry leaders realized that AGs’ actions were far more powerful and immediate than those of legislative bodies. So, they began a heretofore unprecedented campaign to massively increase their influence at this level.

Several people have critiqued the ways in which such actions undermine democratic processes, prompt troubling questions about ethics, and negatively impact attorney generals’ abilities to fulfill their duties to the state and its residents.

A Mission at Risk

Those of us on the frontlines here in OK have seen just how powerful such coalitions can be, how much sway they can have on local and state officials, how they destabilize people’s faith and trust in the systems that are supposed to protect them, and how coalitions undercut people’s hope and desire to be civically engaged. The mission of the US Environmental Protection Agency is to protect human health and the environment. If confirmed to lead the EPA, it is very likely Pruitt will prioritize his relationships with industry over the health and welfare of the people and environment he’s directed to protect.

Footnotes

  1. To learn more about induced seismicity read an exclusive FracTracker two-part series from former VTSO researcher Ariel Conn: Part I and Part II. Additionally, the USGS has created an Induced Earthquakes landing page as part of their Earthquake Hazards Program.

Hypothetical Impacts of Unconventional Drilling In Allegheny County

With tens of thousands of wells scattered across the countryside, Southwestern Pennsylvania is no stranger to oil and gas development. New, industrial scale extraction methods are already well entrenched, with over 3,600 of these unconventional wells drilled so far in that part of the state, mostly from the well known Marcellus Shale formation.

Southwestern Pennsylvania is also home to the Pittsburgh Metropolitan Area, a seven county region with over 2.3 million people. Just over half of this population is in Allegheny County, where unconventional drilling has become more common in recent years, along with all of its associated impacts. In the following interactive story map, the FracTracker Alliance takes a look at current impacts in more urban and suburban environments, plus projects what future impacts could look like, based on leasing activity.

hypothetical impacts map

By Matt Kelso, Manager of Data & Technology

You Are Here feature image

You Are Here!

Oklahoma and Kansas Class II Injection Wells and Earthquakes

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance
In collaboration with Caleb Gallemore, Assistant Professor in International Affairs, Lafayette University

The September 3rd magnitude 5.8 earthquake in Pawnee, Oklahoma, is the most violent example of induced seismicity, or “man-made” earthquakes, in U.S. history, causing Oklahoma governor Mary Fallin to declare a state of emergency. This was followed by a magnitude 4.5 earthquake on November 1st prompting the Oklahoma Corporation Commission (OCC) and U.S. EPA to put restrictions on injection wells within a 10-mile radius of the Pawnee quake.

And then on Sunday, November 6th, a magnitude 5.0 earthquake shook central Oklahoma about a mile west of the Cushing Hub, the largest commercial crude oil storage center in North America capable of storing 54 million barrels of crude. This is the equivalent of 2.8 times the U.S. daily oil refinery capacity and 3.1 times the daily oil refinery capacity of all of North America. This massive hub in the North American oil landscape also happens to be the southern terminus of the controversial Keystone pipeline complex, which would transport 590,000 barrel per day over more than 2,000 miles (Fig. 1). Furthermore, this quake demonstrated the growing connectivity between Class II injection well associated induced seismicity and oil transport/storage in the heart of the US version of Saudi Arabia’s Ghawar Oil Fields. This increasing connectivity between O&G waste, production, and processing (i.e., Hydrocarbon Industrial Complex) will eventually impact the wallets of every American.

North American Oil Refinery Capacity, Pipelines, and Cushing, OK

Figure 1. The Keystone Pipeline would transport 590,000 bpd over more than 2,000 miles.

This latest earthquake caused Cushing schools to close. Magellan Midstream Partners, the major pipeline and storage facility operator in the region, also shut down in order to “check the integrity of our assets.” Compounding concerns about induced seismicity, the Cushing Hub is the primary price settlement point for West Texas Intermediate that, along with Brent Crude, determines the global price of crude oil and by association what Americans pay for fuel at the pump, at their homes, and in their businesses.

Given the significant increase in seismic activity across the U.S. Great Plains, along with the potential environmental, public health, and economic risks at stake, we thought it was time to compile an inventory of Class II injection well volumes. Because growing evidence points to the relationship between induced seismicity and oil and gas waste disposal, our initial analysis focuses on Oklahoma and Kansas. The maps and the associated data downloads in this article represent the first time Class II injection well volumes have been compiled in a searchable and interactive fashion for any state outside Ohio (where FracTracker has compiled class II volumes since 2010). Oklahoma and Kansas Class II injection well data are available to the public, albeit in disparate formats and diffuse locations. Our synthesis makes this data easier to navigate for concerned citizens, policy makers, and journalists.

Induced Seismicity Past, Present, and Future

inducedseismicity_figure

Figure 2. Central U.S. earthquakes 1973-August 15, 2015 according to the U.S. Geological Survey (Note: Based on our analysis this exponential increasing earthquakes has been accompanied by a 300 feet per quarter increase in the average depth of earthquakes across Oklahoma, Kansas, and Texas).

Oklahoma, along with Arkansas, Kansas, Ohio, and Texas, is at the top of the induced seismicity list, specifically with regard to quakes in excess of magnitude 4.0. However, as the USGS and Virginia Tech Seismological Observatory (VTSO)[1] have recently documented, an average of only 21 earthquakes of magnitude 3.0 or greater occurred in the Central/Eastern US between 1973 and 2008. This trend jumped to an average of 99 between 2009 and 2013. In 2014 there were a staggering 659 quakes. The exponential increase in induced seismic events can be seen in Figure 2 from a recent USGS publication titled “High-rate injection is associated with the increase in U.S. mid-continent seismicity,” where the authors note:

“An unprecedented increase in earthquakes in the U.S. mid-continent began in 2009. Many of these earthquakes have been documented as induced by wastewater injection…We find that the entire increase in earthquake rate is associated with fluid injection wells. High-rate injection wells (>300,000 barrels per month) are much more likely to be associated with earthquakes than lower-rate wells.”

hydraulic-fracturing-freshwater-demand

Figure 3. Average freshwater demand per hydraulically fractured well across four U.S. shale plays and the annual percent increase in each of those plays.

This trend suggests that induced seismicity is the new normal and will likely increase given that: 1) freshwater demand per hydraulically fractured well is rising all over the country, from 11-15% per year in the Marcellus and Bakken to 20-22% in the Denver and Midland formations, 2) the amount of produced brine wastewater parallels these increases almost 1-to-1, and 3) the unconventional oil and gas industry is using more and more water as they begin to explore the periphery of primary shale plays or in less productive secondary and tertiary plays (Fig. 3).

Oklahoma

The September, 2016, Pawnee County Earthquake

This first map focuses on the September, 2016 Pawnee, OK Magnitude 5.8 earthquake that many people believe was caused by injecting high volume hydraulic fracturing (HVHF) waste into class II injection wells in Oklahoma and Kansas. This map includes all Oklahoma and Kansas Class II injection wells as well as Oklahoma’s primary geologic faults and fractures.

Oklahoma and Kansas Class II injection wells and geologic faults


View map fullscreenHow FracTracker maps work

Pawnee, Oklahoma 5.8 magnitude earthquake, September, 2016 & Active Class II Injection Wells

Figure 4. The September, 2016 Pawnee, Oklahoma 5.8M earthquake, neighboring active Class II injection wells, underlying geologic faults and fractures.

Of note on this map is the geological connectivity across Oklahoma resulting from the state’s 129 faults and fractures. Also present are several high volume wells including Territory Resources LLC’s Oldham #5 (1.45 miles from the epicenter, injecting 257 million gallons between 2011 and 2014) and Doyle #5 wells (0.36 miles from the epicenter, injecting 61 million gallons between 2011 and 2015), Staghorn Energy LLC’s Hudgins #1 well (1.43 miles from the epicenter, injecting 11 million gallons between 2011 and 2015 into the Red Fork formation), and Cooke Co Production Co.’s Laird #3-35 well (1.41 miles from the epicenter, injecting 6.5 million gallons between 2011 and 2015). Figure 4 shows a closeup view of these wells relative to the location of the Pawnee quake.

Class II Salt Water Disposal (SWD) Injection Well Volumes

This second map includes annual volumes of disposed wastewater across 10,297 Class II injection wells in Oklahoma between 2011 and 2015 (Note: 2015 volumes also include monthly totals). Additionally, we have included Oklahoma’s geologic faults and fractures for context given the recent uptick in Oklahoma and Kansas’ induced seismicity activity.

Annual volumes of class II injection wells disposal in Oklahoma (2011-2015)


View map fullscreenHow FracTracker maps work | Download map data

Oklahoma statistics for 2011 to 2015 (Table 1):

  1. Maximum volume to date (for a single Class II injection well): 105,979,598 barrels, or 4,080,214,523 gallons (68,003,574 gallons per month), for the New Dominion, LLC “Chambers #1” well in Oklahoma County.
  2. Total Volume to Date: 10,655,395,179 barrels or 410,232,714,392 gallons (6,837,211,907 gallons per month).
  3. Mean volume to date across the 10,927 Class II injection wells: approximately 975,144 barrels per well or 37,543,044 gallons (625,717 gallons per month).
  4. This map also includes 632 Class II wells injecting waste into the Arbuckle Formation which is believed to be the primary geological formation responsible for the 5.0 magnitude last week in Cushing.

Kansas

Below is an inventory of monthly oil and gas waste volumes (barrels) disposed across 4,555 Class II injection wells in Kansas between 2011 and 2015. This map will be updated in the Spring of 2017 to include 2016 volumes. A preponderance of this data comes from 2015 with a scattering of volume reports across Kansas between 2011 and 2014.

Monthly Class II injection wells volumes in Kansas (2011-2015)


View map fullscreenHow FracTracker maps work | Download map data

Kansas statistics for 2015 (Table 1):

  1. Maximum volume to date (for a single Class II injection well): 9,016,471 barrels, or 347,134,134 gallons (28,927,845 gallons per month), for the Sinclair Prairie Oil Co. “H.J. Vohs #8” well in Rooks County. This is a well that was initially permitted and completed between 1949 and 1950.
  2. Total Volume to date: 1,060,123,330 barrels or 40,814,748,205 gallons (3,401,229,017 gallons per month).
  3. Mean volume to date across the 4,555 Class II injection wells: approximately 232,738 barrels per well or 8,960,413 gallons (746,701 gallons per month).

Table 1. Summary of Class II SWD Injection Well Volumes across Kansas and Oklahoma

 

 

Sum Average Maximum
No. of Class II
SWD Wells
Barrels Sum To Date Per Year Sum To Date Per Year
Kansas* 4,555 1.06 BB 232,738 9.02 MB
Oklahoma** 10,927 10.66 BB 975,143 195,029 105.98 MB 21.20 MB

* Wells in the counties of Barton (279 wells), Ellis (397 wells), Rooks (220 wells), Russell (199 wells), and Ness (187 wells) account for 29% of Kansas’ active Class II wells.

** Wells in the counties of Carter (1,792 wells), Creek (946 wells), Pontotoc (684 wells), Seminole (476 wells), and Stephens (1,302 wells) account for 48% of Oklahoma’s active Class II wells.

Conclusion

If the U.S. EPA’s Underground Injection Control (UIC) estimates are to be believed, the above Class II volumes account for 19.3% of the “over 2 billion gallons of brine…injected in the United States every day,” and if the connectivity between injection well associated induced seismicity and oil transport/storage continues to grow, this issue will likely impact the lives of every American.

Given how critical the Cushing Hub is to US energy security and price stability one could easily argue that a major accident there could result in a sudden disruption to fuel supplies and an exponential increase in “prices at the pump” that would make the 240% late 1970s Energy Crisis spike look like a mere blip on the radar. The days of $4.15 per gallon prices the country experienced in the summer of 2008 would again become a reality.

In sum, the risks posed by Class II injection wells and are not just a problem for insurance companies and residents of rural Oklahomans and Kansans, induced seismic activity is a potential threat to our nation’s security and economy.

Downloads

FracTracker Induced Seismicity Infographic (print quality)

Oklahoma Class II SWD Injection Well Annual Volumes 2011 to 2015 (Barrels)

Kansas Class II SWD Injection Well Monthly Volumes 2011 to 2015 (Barrels)

Footnotes

[1] To learn more about Induced Seismicity read an exclusive FracTracker two-part series from former VTSO researcher Ariel Conn: Part I and Part II. Additionally, the USGS has created an Induced Earthquakes landing page as part of their Earthquake Hazards Program.

Wastewater Disposal Facility in Colorado

Groundwater Threats in Colorado

FracTracker has been increasingly looking at oil and gas drilling in Colorado, and we’re finding some interesting and concerning issues to highlight. Firstly, operators in Colorado are not required to report volumes of water use or freshwater sources. Additionally, this analysis looked at how wastewater in Colorado is injected, and found that the majority is injected into Class II disposal wells (85%) while recycling wastewater is not common. Open-air pits for evaporation and percolation of wastewater is still a common practice. Colorado has at least 340 zones granted aquifer exemptions from the Clean Water Act for injecting wastewater into groundwater. The analysis also found that Weld County produces the most oil and gas in the state, while Rio Blanco and Las Animas counties produce more wastewater. And finally, Rio Blanco injects the most wastewater of all Colorado counties. Learn more about groundwater threats in Colorado below:

Introduction

Working directly with communities in Weld County, Colorado the FracTracker Alliance has identified issues concerning oil and gas exploration and production in Colorado that are of particular concern to community stakeholder groups. The issues include air quality degradation, environmental justice concerns for communities most impacted by oil and gas extraction, and leasing of federal mineral estates. Analysis of data for Colorado’s Front Range has identified areas where setback regulations are not followed or are inadequate to provide sufficient protections for individuals and communities and our analysis of floodplains shows where oil and gas operations pose a significant risk to watersheds. In this article we focus on the specific threat to groundwater resources as a result of particular waste disposal methods, namely underground injection and land application in disposal pits and sumps. We also focus on the sources of the immense amount of water necessary for fracking and other extraction processes.

Groundwater Threats

Numerous threats to groundwater are associated with oil and gas drilling, including hydraulic fracturing. Research from other regions shows that the majority of groundwater contamination events actually occur from on-site spills and poor management and disposal of wastes. Disposal and storage sites and spill events can allow the liquid and solid wastes to leach and seep into groundwater sources. There have been many groundwater contamination events documented to have occurred in this manner. For example, in 2013, flooding in Colorado inundated a main center of the state’s drilling industry causing over 37,380 gallons of oil to be spilled from ruptured pipelines and damaged storage tanks that were located in flood-prone areas. There are serious concerns that the oil-laced floodwaters have permanently contaminated groundwater, soil, and rivers.

Waste Management

In Colorado, wastes are managed several ways. If the wastewater is not recycled and used again in other production processes such as hydraulic fracturing, drilling fluids disposal must follow one of three rules:

  1. Treated at commercial facilities and discharged to surface water,
  2. Injected in Class II injection wells, or
  3. Stored and applied to the land and disposal pits at centralized exploration and production waste management facilities.

Additionally the wastes can be dried and buried in additional drilling pits, with restrictions for crop land. For oily wastes, those containing crude oil, condensate or other “hydrocarbon-containing exploration and production waste,” there are additional land application restrictions that mostly require prior removal of free oil. These various sites and facilities are mapped below, along with aquifer exemptions and other map layers related to water quality.

Figure 1. Interactive map of groundwater threats in Colorado


View Map Fullscreen | How Our Maps Work

Injection Wells

In 2015, Colorado injected a total of 649,370,514 barrels of oil and gas wastewater back into the ground. That is 27,273,561,588 gallons, which would fill over 41,000 Olympic sized swimming pools. Injected into the ground in deep formations, this water is forever removed from the water cycle.

Allowable injection fluids include a variety of things you do not want to drink:

  • Produced Water
  • Drilling Fluids
  • Spent Well Treatment or Stimulation Fluids
  • Pigging (Pipeline Cleaning) Wastes
  • Rig Wash
  • Gas Plant Wastes such as:
    • Amine
    • Cooling Tower Blowdown
    • Tank Bottoms

This means that federal exemptions to Underground Injection Control (UIC) regulations for oil and gas exploration and production have nothing to do with environmental chemistry and risk, and only consider fluid source.

Why the concern?

Why are we concerned about these wastes? To quote the regulation, “it is possible for an exempt waste and a non-exempt hazardous waste to be chemically very similar” (RCRA). Since oil and gas development is considered part of the United State’s strategic energy policy, the entire industry is exempt from many federal regulations, such as the Safe Drinking Water Act (SDWA), which protects underground sources of drinking water (USDW).

The Colorado Oil and Gas Conservation Commission has primacy over the UIC permits and the Colorado Department of Public Health and Environment (CDPHE) administers the environmental protection laws related to air quality, waste discharge to surface water, and commercial disposal facilities. Under the UIC program, operators are legally allowed to inject wastewater containing heavy metals, hydrocarbons, radioactive elements, and other toxic and carcinogenic chemicals into groundwater aquifers.

The State of CO Injection Wells

According to the COGCC production reports for the year 2015, there are 9,591 active injection wells with volumes reported to the regulatory agency. Additionally, there are of course distinctions within the UIC rules for different types of injection wells, although the COGCC does not provide comprehensive data to distinguish between these types.

Injecting into the same geological formation or “zone” as producing wells is typically considered EOR, although some of the injected water will ultimately remain in the ground. Injecting into a producing formation is an immediate qualification for receiving an aquifer exemption.

EOR operations require considerably more energy and resources than conventional wells, and therefore have a higher water carbon footprint. If the wastewater is “recycled” as hydraulic fracturing fluid, the injections are exempt from all UIC regulations regardless. These are two options for the elimination of produced wastewater, although much of it will return to the surface in the future along with other formation waters. When the produced waters reach a certain level of salinity the fluid can no longer be used in enhanced recovery or stimulation, so final disposal of wastewater is typically necessary. These liquid wastes may then go to UIC Class II Disposal Wells.

Class II Injection Wells

The wells injecting into non-producing formations are therefore disposal wells, since they are not “enhancing production.” Of the almost 10,000 active injection wells in Colorado there are OVER 670 class II disposal well facilities; 402 facilities are listed as currently active. These facilities may or may not host multiple wells. By filtering the COGCC production and injection well database by target formation, we find that there are over 1,070 wells injecting into non-producing formations. These disposal wells injected at least 66,193,874 barrels (2,780,142,708 gallons) of wastewater in 2015 alone.

Where is the waste going?

A simple life-cycle assessment of wastewater in Colorado shows that the majority of produced water is injected back underground into class II disposal and EOR wells. The percentage of injected produced waters has been increasing since 2012, and in 2015 85% of the total volume of produced water in 2015 was injected.

If we assume that all the volume injected was produced wastewater, this still leaves 60 million barrels of produced water unaccounted for. Some of this volume may have been recycled and used for hydraulic fracturing, but this is rarely the case. Other options for disposal include commercial oilfield wastewater disposal facilities (COWDF) that use wastewater sumps (pits) for evaporation and percolation, as well as land application, to dilute the solid and liquid wastes by mixing them into soil.

Centralized Exploration and Production Waste Management Facilities

Photo by COGCC

Figure 2. Chevron Wastewater Land Application and Pit “Disposal” Facility. Photo by COGCC

According to the COGCC, there are 40 active and 71 total “centralized exploration and production waste management facilities” in Colorado. These facilities, mapped in Figure 1 above, are mostly open-air pits used for storage or disposal, or land-application sites.

As can be seen in the Figure 2 to the right, land application sites are little more than farms that don’t grow anything, where wastewater is mixed with soil. Groundwater monitoring wells around these sites measure the levels of some contaminants. Inspection reports show that sampling of the wastewater is not usually – if ever – conducted. The only regulatory requirement is that oil is not visibly noticeable as a sheen on the wastewater fluids in impoundments, such as the one in Figure 3 below, operated by Linn Operating Inc., which is covered in an oily sheen.

In most other hydrocarbon producing states, open-air pits or sumps are not allowed for a variety of reasons. At FracTracker, we have covered this issue in other states, as well. In New Mexico, for example, the regulatory agency outlawed the use of pits after finding cased where 369 pits were documented to have contaminated groundwater. California is another state that still uses above ground pits for disposal. At sites in California, plumes of contaminants are being monitored as they spread from the facilities into surrounding regions of groundwater. Additionally, these wastewater pit disposal sites present hazards for birds and wildlife. There have been a number of papers documenting bird deaths in pits, and the risk for migratory bird species is of high concern. Other states like California are struggling with the issue of closing these types of open-air pit facilities. Closing these facilities means that more wastewater will be injected in Class II disposal wells.

Linnoilypit

Figure 3. Linn energy oily wastewater disposal pit

Production and Injection Volumes

The data published by the COGCC for well production and injection volumes shows some unique trends. An analysis of injection and production well volumes shows Class II Injection is tightly connected to exploration and production activities. This finding is not surprising. Class II injection wells are considered a support operation for the production wells, and therefore should be expected to be similarly related. Wastewater injection wells are needed where oil and gas extraction is occurring, particularly during the exploration and drilling phases.

Looking at the graphs in Figures 4-6 below, it is obvious that injection volumes have been consistently tied to production of wastewater. It is also clear that the trend since 2012 shows that an increasingly larger percentage of wastewater is being injected each year. This trend follows the sharp increase in high volume hydraulic fracturing activity that occurred in 2012. During this boom in exploration and drilling activity, recycling of flowback for additional hydraulic fracturing activities most likely accounts for some of the discrepancy in accounting for the fact that 200% more wastewater was produced than was injected in 2012.

When Figure 4 (below) is compared to the graphs in Figures 5 and 6 (further below) it is also interesting to note that produced water volumes in 2015 are at a 5-year low as of 2015, while production volumes of both natural gas and oil are at a 5-year high. Wastewater volumes are linked to production volumes, but there are many other factors, including geological conditions and types of extraction technologies being used, that have a massive affect on wastewater volumes.

CO wastewater Volumes by year

Figure 4. Colorado wastewater volumes by year (barrels)

The graphs in Figures 5 and 6 below show different trends. Gas production in Colorado has remained relatively constant over the last five years with a sharp increase in 2015, while oil production volumes have been continually increasing, with the largest increase of 49% from 2014 to 2015, and 46% the year prior.

Figures 5-6

Colorado’s Front Range, specifically Weld County, is increasing oil production at a fast rate. New multi-well well-pads are being permitted in neighborhoods and urban and suburban communities without consideration for even elementary schools. Weld County currently has 2,169 new wells permitted within the county. The figure is higher than the next 9 counties combined. The other top three counties with the most well permits are 2. Garfield (1,130) and 3. Rio Blanco (189), for perspective. Additionally, 74% of pending permits for new wells are located in Weld County.

How Counties Compare

The top 10 counties for oil production are very similar to the top 10 counties for both produced and injected volumes, although there are some inconsistencies (Table 1). For example, Las Animas County produces the second largest amount of produced wastewater, but is not in the top 10 of oil producing counties. This is because the majority of wells in Las Animas County produce natural gas. Natural gas wells do not typically produce as much wastewater as oil wells. The counties and areas with the most oil and gas production are also the regions with the most injection and surface waste disposal, and therefore surface water and groundwater degradation.

Table 1. Top 10 CO counties for gas production, oil production, wastewater production, and injection volumes in 2015.

Gas Production Oil Production Wastewater Production Injection Volumes
Rank County Gas1 County Oil2 County Water2 County Water2
1 Weld 568,919,168 Weld 112,898,400 Rio Blanco 113,132,037 Rio Blanco 138,502,742
2 Garfield 556,855,359 Rio Blanco 4,412,578 Las Animas 45,868,907 Weld 50,360,796
3 La Plata 322,029,940 Gardield 1,744,900 Weld 37,665,571 Garfield 29,022,147
4 Las Animas 78,947,042 Araahoe 1,661,204 Garfield 34,704,673 La Plata 23,211,646
5 Rio Blanco 57,284,876 Lincoln 1,194,435 Washington 25,075,998 Washington 15,105,886
6 Mesa 32,200,936 Cheyenne 1,192,162 La Plata 23,352,861 Las Animas 13,706,555
7 Yuma 25,960,947 Adams 664,530 Cheyenne 9,326,944 Cheyenne 10,309,413
8 Archuleta 13,648,006 Moffat 419,893 Moffat 7,712,323 Logan 5,930,937
9 Moffat 13,610,219 Washington 413,603 Logan 5,606,828 Mesa 5,611,075
10 Gunnison 4,805,541 Jackson 407,537 Morgan 4,197,849 La Plata 4,992,391
1. Units are in MCF = Thousand cubic feet of natural gas;
2. Units are in Barrels

Aquifer Exemptions

Operators are given permission by the U.S. EPA to inject wastewater into groundwater aquifers in certain locations where groundwater formations are particularly degraded or when operators are granted aquifer exemptions. Aquifer exemptions are not regions where the groundwater is not suitable for use as drinking water. Quite the contrary, as any aquifer with groundwaters above a 10,000 ppm total dissolved solids (TDS) threshold are fast-tracked for injection permits. When the TDS is below 10,000 ppm operators can apply for an exemption from SDWA (safe drinking water act) for USDWs (underground sources of drinking water), which otherwise protects these groundwater sources. An exemption can be granted for any of the following three reasons. The formation is:

  • hydrocarbon producing,
  • too deep to economically access, or
  • too “contaminated” to economically treat.

Since the first requirement is enough to satisfy an exemption, most class II wells are located within oil and gas fields. Other considerations include approval of mineral owners’ permissions within ¼ mile of the well. On the map above, you can see the ¼ mile buffers around active injection wells. If you live in Colorado, and suspect you live within the ¼ mile buffer of an injection well, you can input an address into the search field in the top-right corner of the map to fly to that location.

Sources of Water

The economic driver for increasing wastewater recycling is mostly influenced by two factors. First, states with many class II disposal wells, like Colorado, have much lower costs for wastewater disposal than states like Pennsylvania, for example. Additionally, the cost of water in drought-stricken states makes re-use more economically advantageous.

These two factors are not weighted evenly, though. On the Colorado front range, water scarcity should make recycling and reuse of treated wastewater a common practice. The stress of sourcing fresh water has not yet become a finanacial restraint for exploration and production. Water scarcity is an issue, but not enough to motivate operators to recycle. According to an article by Small, Xochitl T (2015) “Geologic factors that impact cost, such as water quality and availability of disposal methods, have a greater impact on decisions to recycle wastewater from hydraulic fracturing than water scarcity.” As long as it is cheaper to permit new injection wells and contaminate potential USDW’s than to treat the wastewater, recycling practices will be largely ignored. Even in Colorado’s arid Front Range where the demand for freshwater frequently outpaces supply, recycling is still not common.

Fresh Water Use

The majority of water used for hydraulic fracturing is freshwater, and much of it is supplied from municipal water systems. There are several proposals for engineering projects in Colorado to redirect flows from rivers to the specific municipalities that are selling water to oil and gas operators. These projects will divert more water from the already stressed watersheds, and permanently remove it from the water cycle.

The Windy Gap Firming Project, for example, plans to dam the Upper Colorado River to divert almost 10 billion gallons to six Front Range cities including Loveland, Longmont, and Greeley. These three cities have sold water to operators for fracking operations. Greeley in particular began selling 1,500 acre-feet (500 million gallons) to operators in 2011 and that has only increased . The same thing is happening in Fort Lupton, Frederick, Firestone, and in other communities. Additionally, the Northern Integrated Supply Project proposes to drain an additional 40,000 acre feet/year (13 billion gallons) out of the Cache la Poudre River northwest of Fort Collins. The Seaman Reservoir Project by the City of Greeley on the North Fork of the Cache la Poudre River proposes to drain several thousand acre feet of water out of the North Fork and the main stem of the Cache la Poudre. And finally, the Flaming Gorge Pipeline would take up to 250,000 acre feet/year (81 billion gallons) out of the Green and Colorado Rivers systems, among others.

Other Water Sources

Unfortunately, not much more is known about sources and amounts of water for used for fracking or other oil and gas development operations. Such a data gap seems ridiculous considering the strain on freshwater sources in eastern Colorado and the Front Range, but regulators do not require operators to obtain permits or even report the sources of water they use. Legislative efforts to require such reporting were unsuccessful in 2012.

Now that development and fracking operations are continuously moving into urban and residential areas and neighborhoods, sourcing water will be as easy as going to the nearest fire hydrant. Allowing oil and gas operators to use municipal water sources raises concerns of conflicts of interest and governmental corruption considering public water systems are subsidized by local taxpayers, not well sites.

Conclusions

In Colorado, exploration and drilling for oil and natural gas continues to increase at a fast pace, while the increase in oil production is quite staggering. As this trend continues, the waste stream will continue to grow with production. This means more Class II injection wells and other treatment and disposal options will be necessary.

While other states are working to end the practices that have a track record of surface water and groundwater contamination, Colorado is issuing new permits. Colorado has issued 7 permits for CEPWMF’s in 2016 alone, some of them renewals. While there aren’t any eco-friendly methods of dealing with all the wastewater, the use of pits and land application presents high risk for shallow groundwater aquifers. In addition, sacrificing deep groundwater aquifers with aquifer exemptions is not a sustainable solution. These are important considerations beyond the obvious contribution of carbon dioxide and methane to the issue of climate change when considering the many reasons why hydrocarbon fuels need to be eliminated in favor of clean energy alternatives.


By Kyle Ferrar, Western Program Coordinator & Kirk Jalbert, Manager of Community Based Research & Engagement, FracTracker Alliance

Cover photo by COGCC

Koontz Class II Injection Well, Trumbull County, Ohio, (41.22806065, -80.87669281) with 260,278 barrels (10,020,704 gallons) of fracking waste having been processed between Q3-2010 and Q3-2012 (Note: Q1-2016 volumes have yet to be reported!).

OH Class II Injection Wells – Waste Disposal Trends and Images From Around Ohio

By Ted Auch, PhD – Great Lakes Program Coordinator

Hydraulic Fracturing "Fracking" at a well-pad outside Barnesville, Ohio operated by Halliburton

Hydraulic Fracturing “Fracking” at a well-pad outside Barnesville, Ohio operated by Halliburton

The industrial practice of disposing of oil and gas drilling waste into Class II injection wells causes a lot of strife for people on both sides of the fracking debate. This process has exposed many “hidden [geologic] faults” across the US as a result of induced seismicity. It has been linked in recent months and years with increases in earthquake activity in states like Arkansas, Kansas, Texas, and Ohio.

Locally, there is growing evidence in counties – from Ashtabula to Washington – that Ohio Class II injection well volumes and quarterly rates of change are related to upticks in seismic activity (Figs. 1-3). But exactly how much waste are these sites receiving, and where is it coming from? Since it has been a little over a year since last we looked at the injection well landscape here in Ohio, we decided to revisit the issue here.

Figures 1-3. Ohio Class II Injection Well disposal during Q3-2010, Q2-2012, and Q2-2015

The Class II Landscape in Ohio

In Ohio 245+ Class II Salt Water Disposal (SWD) Disposal Wells are permitted to accept unconventional oil and gas waste. Their disposal capacity and number of wells served is by far the most of any state across the Marcellus and Utica Shale plays.

Ohio’s Class II Injection wells have accepted an average of 22,750 barrels per quarter per well (BPQPW) (662,632 gallons) of oil and gas wastewater over the last year. In comparison, our last analysis uncovered a higher quarterly average (29,571 BPQPW) between the initiation of frack waste injection in 2010 and Q2-2015 (Fig. 4). This shift is likely due to the significant decrease in overall drilling activity from 2012 to 2015. Between Q3-2010 and Q1-2016, however, OH’s Class II injection wells saw an exponential increase in injection activity.  In total, 109.4 million barrels (3.8-4.6 billion gallons) of waste was disposed in Ohio. From a financial perspective this waste has generated $3.4 million in revenue for the state or 00.014% of the average state budget (Note: 2.5% of ODNR’s annual budget).

The more important point is that even in slow times (i.e., Q2-2015 to the present) the trend continues to migrate from the bottom-left to the top-right, with each of Ohio’s Class II injection wells seeing quarterly demand increases of 972 BPQPW (34,017-40,821 gallons). This means that the total volume coming into our Class II Wells is increasing at a rate of 8.2-9.8 MGs per year, or the equivalent to the water demand of several high volume hydraulically fractured wells.

With respect to the source of this waste, the story isn’t as clear as we had once thought. Slightly more than half the waste came from out-of-state during the first two years for which we have data, but this statistic plummeted to as low as 32% in the last year-to-date (Fig. 5). This change is likely do to the high levels of brine being produced in Ohio as the industry migrates towards the perimeter of the Utica Shale.

Figures 4 and 5

Freshwater Demand and Brine Production

Map of Ohio Utica Brine Production and Class II Injection Well Disposal

View map fullscreen | How FracTracker maps work | Download map data | Related OH Shale Gas Viewer

Ohio Class II injection well disposal and freshwater demand

Figure 6. Ohio Class II Injection Well disposal as a function of freshwater demand by the shale industry in Ohio between Q3-2010 and Q1-2015

To gain a more comprehensive understanding of what’s going on with Class II wastewater disposal in Ohio, it’s important to look into the relationship between brine and freshwater demand by the hydraulic fracturing industry. The average freshwater demand during the fracking process, accounts for 87% of the trend in brine disposal in Ohio (Fig. 6).

As we mentioned, demand for freshwater is growing to the tune of 405-410,000 gallons PQPW in Ohio, which means brine production is growing by roughly 12,000 gallons PQPW. This says nothing for the 450,000 gallons of freshwater PQPW increase in West Virginia and their likely demand for injection sites that can accommodate their 13,500 gallons PQPW increase.

Conclusion

Essentially, the seismic center of Ohio has migrated eastward in recent years; originally it was focused on Western counties like Shelby, Logan, Auglaize, Darke, and Miami on the Indiana border, but it has recently moved to injection well hotbed counties like Ashtabula, Trumbull, and Washington along the Pennsylvania and West Virginia borders. This growth in “induced seismicity” resulting from the uptick in frack waste disposal puts Ohio in the company of Oklahoma, Arkansas, Colorado, Kansas, New Mexico, and Texas. Each of those states have reported ≥4.0 magnitude “man-made” quakes since 2008. Between 1973 and 2008 an average of 21 earthquakes of ≥M3 were reported in the Central/Eastern US. This number jumped to 99 between 2009 and 2013, with 659 of M3+ in 2014 alone according to the USGS and Virginia Tech Seismological Observatory (VTSO). This “hockey stick moment” is exemplified in the below figure from a recent USGS publication (Fig. 7). Figure 8 illustrates the spatial relationship between recent seismic activity and Class II Injection well volumes here in Ohio. The USGS even went so far as to declare the following:

An unprecedented increase in earthquakes in the U.S. mid-continent began in 2009. Many of these earthquakes have been documented as induced by wastewater injection…We find that the entire increase in earthquake rate is associated with fluid injection wells. High-rate injection wells (>300,000 barrels per month) are much more likely to be associated with earthquakes than lower-rate wells.
– From USGS Report High-rate injection is associated with the increase in U.S. mid-continent seismicity

Figures 7 and 8

The sentiment here in Ohio regarding Class II Injection wells is best summed up by Dr. Ray Beiersdorfer, Distinguished Professor of Geology, Youngstown State University and his wife geologist Susie Beiersdorfer who jointly submitted the following quote regarding the North Star (SWIW #10) Class II Injection Well in Mahoning County, which processed 555,030 barrels (21,368,655 gallons) of fracking waste between Q4-2010 and Q4-2011[1].

The operator, D&L, and the ODNR denied the correlation in space and time between the injection of toxic fracking fluids into the well and earthquakes for over eight months in 2011. The well was shut down on December 30 and the largest seismic event, a 4.0 happened at 3:04 p.m. on December 31, 2011. Though the rules say that a “shut-in” well must be plugged after 60 days, this well is still “open” after 1656 days (July 12, 2016). This well must be plugged [and abandoned] to prevent further risks to the health and safety of the Youngstown community… According to Rick Simmers, the only thing holding this up is bankruptcy procedures. It was drilled into a fault, triggered over five hundred earthquakes, including a Magnitude 4.0 that caused damage to homes. [It is likely] that any other use of this well would trigger additional hazardous earthquakes.

Images From Across Ohio

Click on the images below to explore visual documentation and volumes disposed (as of Q1-2016) into Class II Injection wells in Ohio.

Footnote

  1. This is the infamous Lupo well which was linked to 109 tremors in Youngstown by researchers at the Lamont-Doherty Earth Observatory at Columbia University back in the Summer of 2013. The owner of the well Ben W. Lupo was subsequently charged with violating the Clean water Act.