Wastewater Disposal Facility in Colorado
Kyle Ferrar, MPH

Groundwater Threats in Colorado

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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


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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

Figure 4. Colorado gas produced by year (MCF)
Figure 4. Colorado gas produced by year (MCF)
Figure 5. Colorado oil produced by year (barrels)
Figure 5. Colorado oil produced by year (barrels)

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!).
Ted Auch, PhD

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

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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

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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

Ohio Class II Injection Wells and Earthquakes
Ohio Class II Injection Wells and Earthquakes

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.

Monroe (SWIW # 29) Class II Injection Well, Ashtabula County, Ohio, (41.82003269, -80.54454287) with an astounding 637,021 barrels (24,525,309 gallons) of fracking waste having been processed between Q3-2010 and Q1-2016.

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.
Download Map Data (Zip File)
Photo courtesy of Brian van der Brug | LA Times
Kyle Ferrar, MPH

More Oil Field Wastewater Pits Found in California!

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Who’s in charge here?
By Kyle Ferrar, Western Program Coordinator

FracTracker Alliance recently worked with Clean Water Action to map an update to last year’s report* on the use of unlined, above ground oil and gas waste disposal pits, also known as sumps.

Read 2016 CWA Report

The new report identifies additional oil field wastewater pits and details how California regulators continue to allow these facilities to degrade groundwater, surface waters, and air quality. Other oil and gas production states do not permit or allow these type of operations due to the many documented cases of water contamination. A report published in 2011 identified unlined pits and other surface spills as the largest threat to groundwater quality. The sites are ultimately sacrifice zones, where the contamination from produced water and drilling mud solid wastes leaves a lasting fingerprint.

Central Coast & New Central Valley Pit Data

Ca Central Coast oil field wastewater pits

Figure 1. Central Coast wastewater pits

New data has been released by the Central Coast Regional Water Quality Control Board, identifying the locations of 44 active wastewater facilities and 5 inactive facilities in the California counties of Monterey, Santa Barbara, and San Luis Obispo. The number of pits at each facility is not disclosed, but satellite imagery shows multiple pits at some facilities. The locations of the majority of central coast pits are shown in the map in Figure 1, to the right.

In the web map below (Figure 2), the most updated data shows the number of pits at “active” facilities (those currently operating), shown in red and green, and inactive pits, shown in yellow and orange. The number of pits at each facility in the central valley are shown by the size of the graduated circles. Pit count data for the central coast facilities was not reported, therefore all facilities are shown with a small marker.

Figure 2. Interactive map of California oil field wastewater pits

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Exploring the new central coast data shows that the operators with the most facilities include Greka Oil & Gas Inc. (14), E & B Natural Resources (10), ERG Operating Company, LLC (6), and Chevron (5). As shown in the table below, the majority of central coast pits are located in Santa Barbara County.

Table 1. Summaries by County

Site Counts by Activity and County
Facility Counts Pit Counts
County Active Inactive Active Inactive
Santa Barbara 35 2 Unknown Unknown
Monterey 9 0 Unknown 0
San Luis Obispo 0 3 0 Unknown
Kern 161 191 673 347
Fresno 8 5 31 14
Tulare 6 1 28 1
Kings 5 0 14 0
San Benito 0 4 0 5
Grand Total 224 206 746 367

Wastewater Pit Regulations

Way back in 1988, the U.S. EPA recognized that the federal regulations governing disposal practices of wastewater are inadequate to protect public health, but has yet to take action (NRDC 2015). There is little chance the U.S. EPA will enact regulations focused on pits. In certain cases, if wastewaters spill or are discharged to surface waters the operations will fall under the jurisdiction of the Clean Water Act and will require a National Pollutant Discharge Elimination System (NPDES) permit. Since the objective of the pit is to contain the wastewater to keep it away from surface waters, pits and the wastewater facilities in California that manage them do not require federal oversight. For now the responsibility to protect health and environment has been left to the states.

Most states have responded and have strict regulations for wastewater management. For the few states that allow unlined pits, the main use is storage of wastewater rather than as an dedicated method of disposal. The majority of high production states have banned or ended the use of unlined pits, including Texas, North Dakota, Pennsylvania, Ohio, and New Mexico, Texas (Heberger & Donnelly 2015). An effective liner will prevent percolation of wastewaters into groundwater. The goal of California oil field wastewater pits is quite the opposite.

For California, percolation is the goal and a viable disposal option.

Therefore other regulations that require monitoring of liquid levels in the pits are moot. In fact there is no evidence of regulation requiring spill reporting in California whatsoever (Kuwayama et al. 2015).

Numerous other extraction states throughout the country have phased out the use of open pits entirely, including those with liners due to the common occurrence of liner failures. The list includes those new players in the shale boom using hydraulic fracturing techniques such as North Dakota, Ohio, Pennsylvania, Wyoming, and Colorado. Rather than using the pits as storage, these states’ regulatory agencies favor instead the protections of closed systems of liquid storage. Wastewaters are stored in large tanks, often the same tanks used to store the fresh water used in the hydraulic fracturing process.

Because hydraulic fracturing in California uses much less water, it should be much easier to manage the flowback fluids and other wastewaters. According to the CCST report, 60% of the produced water from hydraulic fracturing operations was disposed to these unlined pits. Regardless of extraction technique, oil extraction in California produces 15 times the amount of wastewater. In total, an estimated 40% of all produced water was discharged to unlined “percolation” pits. As the 3rd largest oil producing state in the country, this equates to a massive waste stream of about 130 billion gallons/year (Grinberg 2014).

Regulatory Action

The facilities’ permits identify waste discharge requirements (WDRs) that allow for the discharge of oil field wastewater to the “ground surface, into natural drainage channels, or into unlined surface impoundments.” Using the Race Track Hill and Fee 34 Facilities as an example, the WDRS place criteria limits on total dissolved solids (TDS), chlorides, and boron. If you disregard all the other toxic constituents not monitored, the allowable concentration limits set for these three wastewater constituents would be reasonable for a discharge permit on the east coast, where a receiving body of water could provide the volume necessary for dilution. When the wastewater is applied directly to the ground or into a pit, the evaporative loss of water results in elevated concentrations of these contaminants.

Even with these very lax regulations, a number of facilities are in violation of the few restrictions required in their permits. Cease and desist orders have been several operators, most notably to Valley Water Management’s Race Track Hill and Fee 34 Facilities. According to the Regional Water Board documents, the Fee 34 disregarded salinity limitations and other regulations. As a result the Regional Water Board found soil and groundwater contamination that “threatens or creates a condition of pollution in surface and groundwater, and may result in the degradation of water quality.” Reports show that 6 domestic supply and 12 agricultural supply wells are located within 1 mile of the Fee 34 facility. At the Race Track Hill Facility the wastewater is continuously sprayed over several acre fields in a small watershed of the Cottonwood Creek. During a rain, the salt and boron loadings that have accumulated in the soil over the past 60 years of spraying can create increased salt and boron loading in the Kern River and groundwater. This would be a violation of the Clean Water Act (CVRWQCB 2015).

As shown in Table 2, below, the majority of facilities are currently operating without a permit whatsoever (61.2%). Of the 72 facilities that bothered to get permits, 32 (44.4%) received the permit prior to 1975, before the Tulare Basin Plan was implemented to preserve water quality. Of the 183 active facilities in the Central Valley, only 15 facilities have received Cease and Desist (11% of permitted) or Cleanup and Abatement Orders (6% of unpermitted). Only 3 of the 41 active Central Coast facilities operate with a permit (7.3%).

These types of WDR permits that allow pollutants to concentrate in the soil and the groundwater and degrade air quality. Chemicals that pose a public health risk are not being monitored. But at this point, these facilities are not only sites of legacy contamination, but growing threats to groundwater security. Operators say that closing the pits will mean certain doom for oil extraction in California, and recent letters from operators make pleas to DOGGR, that their very livelihood depends on using the pits as dumping grounds. The pits are the cheapest and least regulated mode of disposal.

Table 2. Facility Status Summaries

Facility Status
Activity Permitted Permitted; Cease & Desist Order Unpermitted Unpermitted; Cleanup & Abatement Order Grand Total
Active 75 9 137 6 227
Inactive 20 2 184 3 209
Grand Total 92 11 321 9 433

New Mexico Case Study

Much like the groundwater impacts documented by California’s Central Valley Regional Water Quality Control Board, other states have been forced to deal with this issue. The difference is that other states have actually shut down the polluting facilities. In California, cease and desist orders have been met with criticism and pleas by operators, stating that the very livelihood of the oil and gas industry in California depends on wastewater disposal in pits. The same was said in other states such as New Mexico when these crude and antiquated practices were ended. Figure 3 below shows the locations of wastewater pits in New Mexico and the areas where groundwater was contaminated as a result of the pits.
The New Mexico oil and gas industry predicted in August 2008 that fewer drillers would sink wells in New Mexico, at least in part because of the new pit rule. Pro-industry (oil and gas) state representatives were concerned that new drilling techniques coupled with the pit rules could lead to an industry exodus from New Mexico, hoping that the Governor “would step in to help protect an important state revenue source.” But the state’s average rig count from June — when the pit rule took effect — through December 2008 was 7% higher than it was over the same period in the previous year. Development of oil and gas reserves is independent of such regulation. Read the FracTracker coverage of groundwater contamination in New Mexico, here!

Figure 3. Legacy map of cases where pits contaminated groundwater in New Mexico

View Map Fullscreen | How Our Maps Work

References & Resources

* In case you missed it, the 2014 report on wastewater pits can be found here (Grinberg, A. 2014). FracTracker’s previous coverage of the issue can be found here.

** Feature image of Central Valley oil field wastewater pits courtesy of Brian van der Brug | LA Times

  1. Grindberg, A. 2016. UPDATE ON OIL AND GAS WASTEWATER DISPOSAL IN CALIFORNIA: California Still Allowing Illegal Oil Industry Wastewater Dumping Clean Water Action. Accessed 2/15/16.
  2. Grinberg, A. 2014. In the Pits, Oil and Gas Wastewater Disposal into Open Unlined Pits and the Threat to California’s Water and Air. Clean Water Action. Accessed 12/5/14.
  3. NRDC. 2015. Groups File Notice of Intent to Sue EPA Over Dangerous Drilling and Fracking Waste. NRDC. Accessed 10/1/15.
  4. Heberger, M. Donnelly, K. 2015. Oil, Food, and Water: Challenges and Opportunities for California Agriculture. Pacific Institute. Accessed 2/1/16.
  5. Kuwayama et al. 2015. Pits versus Tanks: Risks and Mitigation Options for On-site Storage of Wastewater from Shale Gas and Tight Oil Development. Resources for the Future. Accessed 2/1/16.
  6. CVRWQCB. 2015. Cease and Desist Order R5-2015-0093. CVRWQCB. Accessed 2/1/16.
Download Pit Map Data (Zip)
Oil wastewater pit
Kyle Ferrar, MPH

Wastewater Pits Still Allowed in California

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By Kyle Ferrar, Western Program Coordinator

Above-ground, unlined, open-air sumps/ponds

It is hard to believe, but disposing of hazardous oil and gas wastewaters in unlined, open-air pits – also known as sumps or ponds – is still a common practice in California. It is also permitted in other states such as Texas and West Virginia. Because these ponds are unlined and not enclosed, they contribute to degraded air quality, are a hazard for terrestrial animals and birds, and threaten groundwater quality. A 2014 report by Clean Water Action, entitled In the Pits provides a thorough summary of the issue in California. Since the report was released, new data has been made available by the Central Valley Regional Water Quality Review Board identifying additional locations of wastewater pits.

With the increase of oil and gas development in unconventional reservoirs, such as the Monterey Shale Play in California, the size of the resultant waste stream of drill cuttings, produced brines, and wastewater has skyrocketed. Operators now drill larger, deeper wells, requiring larger volumes of liquid required for enhanced oil recovery methods, such as steam injection, and stimulations such as hydraulic fracturing and acidizing. While California is the 4th largest oil-producing state, it is 2nd only to Texas in wastewater production. This boom of unconventional development, which may still in its infancy in California, has resulted in an annual waste stream of over 130 billion gallons across the state, 80 billion (62%) from Kern County alone.1

Results of the state mandated California Council on Science and Technology Report found that more than half of the California oil industries waste water is “disposed” in pits.2 As outlined by Clean Water Action, the massive waste-stream resulting from drilling, stimulation, and production is one of the most significant and threatening aspects of oil and gas operations in terms of potential impacts to public health and environmental resources.

Wastewater Facility Details

Last February, the LA Times reported on the pits, identifying a total of 933 in California.3 The most recent data from the Regional Water Quality Control Board of the Central Valley shows:

  • A total of 1,088 pits at 381 different facilities
  • 719 pits are listed as “Active.” 369 are “Idle.”
  • 444/939 (47.3%) ponds do not list a permit.
  • 462 pits are operated by Valley Water Management Corporation.

In Table 1, below, the counts of Active and Idle facilities and pits are broken down further to show the numbers of sites that are operating with or without permits. The same has been done for the operator with the most pits in Table 2, because Valley Wastewater operates nearly 9 times as many pits as the second largest operator, E & B Natural Resources Management Corporation. These two operators, along with California Resources Elk Hills LLC, all operate the same number of facilities (28). The other top 20 operators in Kern County are listed in Table 3, below.

Table 1. Wastewater Pit and Facility Counts by Category
Counts Active Idle
Facilities 180 201
Unpermitted Facilities 102 179
Facility Permitted prior to 1985 37 11
Individual Pits 719 369
Unpermitted Individual Pits 187 257
Pit Permitted prior to 1985 252 63

 

Table 2. Valley Water Wastewater Pit and Facility Counts by Category
Counts Active Inactive
Facilities 21 7
Unpermitted Facilities 2 2
Facility Permitted prior to 1985 9 1
Individual Pits 356 78
Unpermitted Individual Pits 5 9
Pit Permitted prior to 1985 166 35

 

Table 3. Top 20 Operators by Facility Count, with Pond Counts.
Rank Operator Pond Count Facility Count
1 Valley Water Management Company 462 28
2 E & B Natural Resources Management Corporation 53 28
3 California Resources Elk Hills, LLC 31 28
4 Aera Energy LLC 67 25
5 California Resources Corporation 31 23
6 Chevron U.S.A. Inc. 40 14
7 Pyramid Oil Company 21 12
8 Macpherson Oil Company 14 9
9 Schafer, Jim & Peggy 8 8
10 Crimson Resource Management 20 6
11 Bellaire Oil Company 11 6
12 Howard Caywood 11 6
13 LINN Energy 10 6
14 Seneca Resources Corporation 9 6
15 Holmes Western Oil Corporation 6 6
16 Hathaway, LLC 22 5
17 Central Resources, Inc. 15 5
18 Griffin Resources, LLC 13 5
19 KB Oil & Gas 8 5
20 Petro Resources, Inc. 6 5

Maps of the Pit Locations and Details

 

The following maps use the Water Authority data to show the locations details of the wastewater pits. The first map shows the number of pits housed at each facility. Larger markers represent more pits. Zoom in closer using the [+] to see the activity status of the facilities. Click the link below the map to open a new webpage. View the names of the facility operators by turning on the layer in the “Layers” menu at the top of the page. The second and third maps show the activity and permit status of each facility. The fourth map allows you to view both activity status and permit status simultaneously by toggling the layers on and off (Open the map in its own webpage, then use the layers menu at the top of the screen to change views).

Map 1. Facility Pit Counts with the top 10 operators identified as well as facility status

Map 1. To view the legend and map full screen, click here.

Map 2. Facility Activity Status

Map 2. To view the legend and map full screen, click here.

Map 3. Facility Permit Status

Map 3. To view the legend and map full screen, click here.

Map 4. Facilityhttps://maps.fractracker.org/lembed/?appid=7385605f018e437691731c94bb589f0a” width=”800″ height=”500″>
Map 4. To view the legend and map full screen, click here.

References

  1. USGS. 2014. Oil, Gas, and Groundwater Quality in California – a discussion of issues relevant to monitoring the effects of well stimulation at regional scales.. California Water Science Center. Accessed 10/1/15.
  2. CCST. 2015. Well Stimulation in California. California Council on Science and Technology. Accessed 9/1/15.
  3. Cart, Julie. 2/26/15. Hundreds of illicit oil wastewater pits found in Kern County . Los Angeles Times. Accessed 9/1/15.
Ted Auch, PhD

The Curious Case of the Shrinking Utica Shale Play

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Oil, Gas, and Brine Oh My!
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

It was just three years ago that the Ohio Geological Survey (OGS) and Department of Natural Resources (DNR) were proposing – and expanding – their bullish stance on the potential Utica Shale oil and gas production “play.” Back in April 2012 both agencies continue[d] to redraw their best guess, although as the Ohio Geological Survey’s Chief Larry Wickstrom cautioned, “It doesn’t mean anywhere you go in the core area that you will have a really successful well.”

What we found is that the OGS projections have not held up to their substantial claims. And here is why…

Background

The Geological Survey eventually parsed the Utica play into pieces:

  • a large oil component encompassing much of the central part of the state,
  • natural gas liquids from Ashtabula on the Pennsylvania border southwest to Muskingum, Guernsey, and Noble Counties, and
  • natural gas counties, primarily, along the Ohio River from Columbiana on the Pennsylvania-West Virginia border to Washington County in the Southeast quarter of the state.
Columbus Dispatch Utica Shale "play" map

Columbus Dispatch Utica Shale “play” map

Fast forward to the first quarter of 2015 and we have a very healthy dataset to begin to model and validate/refute these projections. Back in 2009 Wickstrom & Co. only had 53 Utica Shale laterals, while today Ohio is host to 962 laterals from which to draw our conclusions. The preponderance of producing wells are operated by Chesapeake (463), Gulfport (118), Antero Resources (62), Eclipse Resources (41), American Energy Utica (36), Consol (35), and R.E. Gas Development (34), with an additional 13 LLCs and 10 publicly traded companies accounting for the remaining 173 producing laterals. A further difference between the following analysis and the OGS one is that we looked at total production and how much oil and gas was produced on a per-day basis.

Analysis

Using an interpolative geostatistical technique known as Empirical Bayesian Kriging and the 962 lateral dataset, we modeled total and per day oil, gas, and brine production for Ohio’s Utica Shale between 2011 and Q1-2015 to determine if the aforementioned map redrawing holds up, is out-of-date, and/or is overly optimistic as is generally the case with initial O&G “moving target” projections.

Days of Activity & Brine Production

The most active regions of the Utica Shale for well pad activity has been much of Muskingum County and its border with Guernsey and Noble counties; laterals are in production every 1 in 2.1-3.4 days. Conversely, the least active wells have been drilled along the Harrison-Belmont border and the intersection between Harrison, Tuscarawas, and Guernsey counties.

Brine is a form of liquid drilling waste characterized by high salt loads and total dissolved solids. The laterals that have produced the most brine to date are located in a large section of Monroe County and at the intersection of Belmont, Monroe, and Noble counties, with total brine production amounting to 23,292 barrels or 734,000-978,000 gallons (Fig. 1).

Total Ohio Utica Shale Production Days 2011 to Q1-2015

Total Ohio Utica Shale Oil Production 2011 to Q1-2015

Total Ohio Utica Shale Gas Production 2011 to Q1-2015

Total Ohio Utica Shale Brine Production 2011 to Q1-2015

Figure 1. Total Ohio Utica Shale Oil, Gas, and Brine Production 2011 to Q1-2015

This area is also one of the top three regions of the state with respect to Class II Injection volumes; the other two high-brine production regions are Morrow and Portage counties to the west and southwest, respectively (Fig. 2).

Layout & Volume (2010 to Q1-2015, Gallons) of Ohio’s Active Class II Injection Wells

Figure 2. Layout & Volume (2010 to Q1-2015, Gallons) of Ohio’s Active Class II Injection Wells

However, on a per-day basis we are seeing quite a few inefficient laterals across the state, including Devon Energy’s Eichelberger and Richman Farms laterals in Ashland and Medina counties. Ashland and Medina are producing 230-270 barrels (8,453-9,923 gallons) of brine per day. In Carroll County, one of Chesapeake’s Trushell laterals tops the list for brine production at 1,843 barrels (67,730 gallons) per day. One of Gulfport’s Bolton laterals in Belmont County and EdgeMarc’s Merlin 10PPH in Washington County are generating 1,100-1,200 barrels (40,425-44,100 gallons) of brine per day.

Oil & Gas Production

Since the last time we modeled production the oil hotspots have shrunk. They have also become more discrete and migrated southward – all of this in contrast to the model proposed by the OGS in 2012. The areas of greatest productivity (i.e., >26,000 barrels of oil) are not the central part of the state, but rather Tuscarawas, Harrison, Guernsey, and Noble counties (Fig. 1). The intersection of Harrison, Tuscarawas, and Guernsey counties is where oil productivity per-day is highest – in the range of 300-630+ barrels (Fig. 3). The areas that the OGS proposed had the highest oil potential have produced <600 barrels total or <12 barrels per day.

Per Day Ohio Utica Shale Oil Production 2011 to Q1-2015

Per Day Ohio Utica Shale Gas Production 2011 to Q1-2015

Per Day Ohio Utica Shale Brine Production 2011 to Q1-2015

Figure 3. Per-Day Ohio Utica Shale Oil, Gas, and Brine Production 2011 to Q1-2015

The OGS natural gas region has proven to be another area of extremely low oil productivity.

Natural gas productivity in the Utica Shale is far less extensive than the OGS projected back in 2012. High gas production is restricted to discreet areas of Belmont and Monroe counties to the tune of 947,000-4.1 million Mcf to date – or 5,300-18,100 Mcf per day. While the OGS projected natural gas and natural gas liquid potential all the way from Medina to Fairfield and Perry counties, we found a precipitous drop-off in productivity in these counties to <1,028 Mcf per day (<155,000 Mcf total from 2011 to Q1-2015) or a mere 6-11% of the Belmont-Monroe sweet spot.

Conclusion: A Shrinking Utica Shale Play

Simply put, the OGS 2012 estimates:

  • Have not held up,
  • Are behind the times and unreliable with respect to citizens looking to guestimate potential royalties,
  • Were far too simplistic,
  • Mapped high-yield sections of the “play” as continuous when in fact productive zones are small and discrete,
  • Did not differentiate between per day and total productivity, and
  • Did not address brine waste.

These issues should be addressed by the OGS and ODNR on a more transparent and frequent basis. Combine this analysis with the disappointing returns Ohio’s 17 publicly traded drilling firms are delivering and one might conclude that the structural Utica Shale bubble is about to burst. However, we know that when all else fails these same firms can just “lever up,” like their Rocky Mountain brethren, to maintain or marginally increase production and shareholder happiness. Will these Red Queens of the O&G industry stay ahead of the Big Bank and Private Equity hounds on their trail?

Digging into Waste Data
Matt Kelso, BA

Pennsylvania’s Drilling Waste Distributed to Eight States

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By Matt Kelso, Manager of Data & Technology

According to data published by the Pennsylvania Department of Environmental Protection (DEP), Pennsylvania’s unconventional oil and gas waste that was generated in the first half of 2015 found its way to treatment facilities, disposal wells, and landfills in eight different states. While the majority of the waste stayed in-state, neighboring Ohio, New York, and West Virginia all received significant quantities of both solid and liquid waste, and additional disposals were made in the non-contiguous states of Michigan, Texas, Utah, and Idaho.


Waste generated by Pennsylvania’s unconventional oil and gas wells was disposed of in a variety of ways and over a large geographic area. Click on a facility to learn more, or zoom in to access waste generated by individual wells. Click here to access the full screen map with a legend and additional controls.

Unconventional drillers in the state are now required to report production data monthly, rather than in six month increments, but waste quantities generated by the wells is still supposed to be reported biannually. However, a small number of operators have been reporting waste monthly, as well, and those figures have been included in this analysis, after spot-checking for duplication. Each record includes data on how the waste was processed and where it was shipped, so we were able to map the receiving facilities as well, and aggregate their waste totals.

Types of Waste

Waste generated by unconventional wells in Pennsylvania from January to June 2015.

Waste generated by unconventional wells in Pennsylvania from January to June 2015 by type.

There are eight types of waste detailed in the Pennsylvania data, including:

  • Basic Sediment (Barrels) – Impurities that accompany the desired product
  • Drill Cuttings (Tons) – Broken bits of rock produced during the drilling process
  • Flowback Fracturing Sand (Tons) – Sand used to prop open cracks made during hydraulic fracturing that return to the surface
  • Fracing Fluid Waste (Barrels) – Fluid pumped into the well for hydraulic fracturing that returns to the surface. This includes chemicals that were added to the well.
  • Produced Fluid (Barrels) – Naturally occurring brines encountered during drilling that contain various contaminants, which are often toxic or radioactive
  • Servicing Fluid (Barrels) – Various other fluids used in the drilling process
  • Spent Lubricant (Barrels) – Oils used in engines as lubricants
  • General O&G Waste (Tons) – Solid waste types other than drill cuttings or fracturing sand

For the sake of simplicity, this analysis will at times aggregate the waste types into two categories, with all types reporting in tons as solid waste, while those listed in 42 gallon barrels will be considered liquid waste.

Waste Disposal

Waste disposal method for unconventional wells in PA, January to June 2015

Waste disposal method for unconventional wells in PA, January to June 2015

This PA waste gets disposed of in a variety of ways. About 93 percent of all solid waste ends up in landfills. 29 of the 58 operators reporting waste during this cycle reported drill cuttings. In a separate report, the DEP has records for unconventional wells drilled by 28 different operators during the same time frame, so these results seem reasonable, since drill cuttings are generated during the drilling process, whereas other types of waste are produced throughout the life cycle of the well.

Statewide, there over 596,000 tons of drill cuttings produced during a period which saw 422 wells spudded, an average of 1,412 tons of cuttings per well. Not all operators generated the same amount of cuttings per well, however. Vantage Energy reports 3,089 tons of cuttings per well, while Hilcorp Energy manages to average just 119 tons over 23 wells drilled in the six month period. It is worth noting that some wells that were spudded just prior to the reporting period likely still generated drill cuttings during the six months in question, and some wells spudded during the cycle will continue to produce cuttings into the next one.

In terms of liquid waste, nearly two thirds of the amount reported is reused for purposes other than road spreading. This is, unfortunately, a dead end in terms of being able to follow the waste stream in the data, as there are no facilities associated with the 13.8 million barrels of waste that falls into this category. 225,000 barrels are specified as being reused for hydraulic fracturing, while the remainder is simply destined for, “Reuse without processing at a permitted facility.”

The amount used for road spreading, 147 barrels, is relatively small, and all of this waste is reported as going to private roads in Greene County. The total amount of liquid waste produced in the six month period is almost 879 million gallons, or enough to fill 1,331 Olympic-sized swimming pools.

PA Waste Receiving Facilities

Altogether, we know where roughly 7 million of the nearly 21 million barrels of reported liquid waste wound up, as well as 640,000 of the 647,000 tons of solid waste. The top ten destinations for each waste type are as follows:

Top 10 reported recipients of unconventional O&G waste produced in PA during the first half of 2015.

Top 10 reported recipients of unconventional O&G waste produced in PA during the first half of 2015.

Six of the top destinations for liquid waste were located in-state, while seven of the top ten facilities for solid waste stayed in Pennsylvania. The only facility to appear on both lists is Patriot Water Treatment in Warren, Ohio.

Landfill disposal of drill cuttings
FracTracker Alliance

Landfill Disposal of WV Oil and Gas Waste – A Report Review

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By Bill Hughes, WV Community Liaison

As oil and gas drilling increases in West Virginia, the resulting waste stream must also be managed. House Bill 107 required the Secretary of the West Virginia Department of Environmental Protection to investigate the risks associated with landfill disposal of solid drilling waste. On July 1, 2015, a massive report was issued that details the investigation and its results: Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

While I must commend the State for looking into this important issue, much more needs to be done, and I have serious concerns about the validity of several aspects of this study. Since the report is almost 200 pages long, I will summarize its findings and my critiques below.

Summary of Waste Disposal Concerns in Report

The page numbers that I reference below refer to the page numbers found within the PDF version of the full study.

  1. Marcellus shale cuttings are radioactive: pgs. 17, 139, 142, 154
  2. We do not know if there is a long term problem: pg. 19
  3. About 30 million tons of waste in next few decades: pg. 176
  4. Landfill liners leak: pg. 20
  5. Owning & operating their own landfill would be expensive & risky for gas companies: pgs. 186-7
  6. Toxicity and biotic risk from drill cuttings is uncharted territory: pg. 78
  7. Landfill leachate is toxic to plants & invertebrates: pgs. 16, 95, 97
  8. Other landfills also have radioactive waste: pgs. 14-15
  9. We have no idea if this will get worse: pgs. 96, 154
  10. If all systems at landfills work as designed, leachate might not affect ground water: pg. 41

Introduction

WV Field Visits 2013

Drilling rig behind a wastewater pond in West Virginia

Any formal report comprised of 195 pages generated by a reputable school like Marshall University with additional input from Glenville State College – supported by over 2,300 pages of semi-raw data and graphs and charts and tables – requires some serious investigation prior to making comprehensive and final conclusions. However, some initial observations are needed to provide independent perspective and to help reflect on how sections of this report might be interpreted.

The overarching perspective that must be kept in mind is that the complete study was first limited by exactly what the legislature told the WV Department of Environmental Protection DEP to do. Secondly, the DEP then added other research guidelines and determined exactly what needed to be in the study and what did not belong. There were also budget and time constraints. The most constricting factor was the large body of existing data possessed by the DEP that was provided to the researchers and report writers. Because of the time restrictions, only a small amount of additional raw data could be added.

And most importantly, similar to the WVU Water Research Institute (WVU WRI) report from two years ago, it must be kept in mind that these types of studies, initiated by those elected to our well-lobbied legislature and funded and overseen by a state agency, do not occur in a political power vacuum. It was surely anticipated that the completed report might have the ability to affect the growing natural gas industry – which is supported by most in the political administration. Therefore, we must be cautious here. The presence and influence of political and economic factors need to be considered. Also, for universities to receive research contracts and government paid study requests, the focus must include keeping the customer satisfied.

My comments below on the report’s methods and findings are organized into three broad and overlapping categories:

  • GOOD  –  positive aspects, good suggestions, important observations
  • GENERAL  –  general comments
  • FLAW  –  problems, flaws, limitations
  • MOVING FORWARD  – my suggestions & recommendations

I. Water Quality: EPA Test Protocols & Datasets

Marcellus Shale (at the surface)

Marcellus Shale (at the surface)

GENERAL  It is obvious that a very smart and well-trained set of researchers put a lot of long, detailed thought into analyzing all of the available data. There must be tens of thousands of data points. Meticulous attention was put into how to assemble all of the existing years’ worth of leachate chemical and radiological information.

GOOD  There is an elaborate and detailed discussion of how to best analyze everything and how to utilize the best statistical methods and generate a uniform and integrated report. This was made difficult with non-uniform time intervals, some non-detect values, and some missing items. The researchers used a credible process, explaining how they applied the various appropriate statistical analysis methods to all the data. They provided some trends and observations and draw some conclusions.

FLAW 1  The most glaring flaw and the greatest limitation pertaining to the data sets is the nature of the very data set, which was provided to the researchers from the DEP. It is to the commendable credit of the DEP that the leachate at landfills receiving black shale drill cuttings from the Marcellus and other shale formations were, from the beginning, required to start bi-monthly testing of leachate samples at landfills that were burying drill waste products. And in general, when compared to on-site disposal as done for conventional wells, it was initially a good requirement to have the drill cuttings put into some type of landfill; that way we could keep track of where the drill cuttings are located when there are future problems.

To the best of my knowledge, until the states in the Marcellus region started allowing massive quantities of black shale waste material to be put into local landfills, we have never knowingly deposited large quantities of known radioactive industrial waste products into generic municipal waste landfills. The various waste products and drill cuttings of Marcellus black shales have been known for decades by geologists and radiochemists to be radioactive. We know better than to depose of hazardous radioactive waste in an improper way. Therefore, it is very understandable that we might not know how to best solve the problems of this particular waste product. This was and still is new territory.

FLAW 2  All of the years of leachate test samples were processed for radioactivity using what is called the clean drinking water test protocols, also referred to as the EPA 900 series. Three years ago, given the unfamiliarity of regulatory agencies with the uniqueness of this waste problem, we chose the wrong test protocol for assessing leachate samples. We speculated that the commonly used and familiar clean drinking water test procedure would work. So now we have a massive set of test results all derived from using the wrong test protocol for the radiologicals. Fortunately, all of the chemistry test results should still be reasonably useful and accurate.

At first, three years ago, this was understandable and possibly not an intentional error. Now it is widely known by hydrogeologists and radiochemists, however, that the plain EPA 900 series of test methods for determining the radioactivity of contaminated liquids do not work on liquids with high TDS — Total Dissolved Solids. Method 900.0 is designed for samples with low dissolved solid like finished drinking water supplies.

Despite this major and significant limitation, the effort by Marshall University still has some utility. For example, doing comparisons between and among the various landfills accepting drill waste might provide some interesting observations and correlations. It is clearly known now, however, that the protocols that were used for all samples from the start when testing for gross alpha, gross beta and radium-226 and radium-228 in leachate, can only result in very inaccurate, under-reported data. Therefore, it is not possible to draw any valid conclusions on several very important topics, including:

  • surface water quality,
  • potential ground water contamination,
  • exposure levels at landfills and public health implications,
  • and policy and regulations considerations.

Labs certified to test for radiological compounds and elements are very familiar with the 900 series of EPA test procedures. These protocols are intended to be used on clean drinking water. They are not intended to be used on “sludgy” waters or liquids contaminated with high dissolved solids like all the many liquid wastes from black shale operations like flowback and produced water and brines and leachate. The required lab process for sample size, preparation, and testing will guarantee that the results will be incorrect.

In no place in the final 195 page report have I seen any discussion of which EPA test protocol was used for the newer samples and why was it used. It has also not yet been seen in the 2,300+ pages of supportive statistical and analytical results, either. The fact that the wrong protocol was used three years ago is very understandable. However, this conventional EPA 900 series was still being used on the additional very recent (done in fall of 2014 and spring of 2015) samples that were included in the final report. The researchers, without any justification or discussion or explanations continued to use the wrong test protocol.

The clean drinking water procedures should have been used along with the 901.1M (gamma spec) process, for comparison. It is understandable for the new data to be consistent and comparable with the very large existing dataset that a case could be made for using the incorrect protocol and the proper one also. There should have been a detailed discussion of what and why any test method was being used, however. That discussion is usually one of the first topics investigated and explained in the Methods section. Having that type of discussion and justification seems to represent a basic science method and accepted research process – and that omission is a serious flaw.

MOVING FORWARD  We all know that if we want to bake an appetizing and attractive cake we must use the correct measuring cups for the ingredients. If we want to take our child’s temperature we need an accurate thermometer. When our doctor helps us understand our blood test results, we all want to be confident the right test was used at the lab. The proper test instrument, recently calibrated and designed for the specific sample, is crucial to get useable test results from which conclusions can be drawn and policy enacted.

It seems that the best suggestion so far to test high TDS liquids similar to leachate would be to use what is referred to as Gamma-ray Spectrometry with a high purity germanium instrument with at least a 21-day hold period (30 days are better), while the sample is sealed then counted for at least 16 hours. Many of the old leachate test results indicate high uncertainties that might be attributed to short hold times and short counting times. This procedure is referred to as the 901.1 M (modified). If the sample is sealed, the sample will reach about 99% equilibrium after 30 days. Radon 222 (a gas) must not be allowed to escape.

The potential environmental impacts to water quality section of this report seems to demonstrate that if you do not want to find out something, there are always justifiable options to avoid some inconvenient facts. Given the very narrow scope as defined, some the Marshall University folks did not seem to have the option to stray into important scientific foundational assumptions and, for the most part, just had to work with the stale data sets given to them. All of which, as we have known for close to a year now, have used the wrong test protocol. Therefore we have incorrect results of limited value.

II. Marcellus is Radioactive

GOOD 1  Of course, geologists have known that the Marcellus Shale is radioactive for many decades, but also for decades there has been great reluctance by the natural gas exploration and production companies to acknowledge this fact to the public. And finally we now have a public report that clearly and unambiguously states that Marcellus shale is radioactive. Interestingly enough, it was not much more than a year ago that some on the WV House of Delegates Judiciary Committee, seemed to be echoing the industry’s intentional deception by declaring that:

…it was only dirt and rock…

So this report represents progress and provides a very valuable contribution to beginning to recognize some of the potential problems with shale wastes and their disposal challenges.

GOOD 2  Another very important advance is that finally after eight years of drilling here in Wetzel County, we now have a test sample from near the horizontal bore. The WVU WRI study researchers were never given access to any samples taken from the horizontal bore material itself, however. That was, of course, what they were supposed to have been allowed to do, but they were only given access to study material from the vertical section of the well bore. This report describes how we are getting closer to actually testing good samples of the black shale. It seems that we have gotten closer – but let’s see how close.

Page 11 describes that only three Antero wells in Doddridge County were chosen as the place to try to obtain samples from the horizontal bore. Considering that over 1,000 deviated/horizontal wells or wells with laterals have been drilled in the past few years, that number represents a very small fraction of wells drilled: less than .3%. Even if a high quality sample could have been obtained it might be a challenge to extrapolate test results to the waste being produced from the other wells in WV. These limitations are completely ignored in the report, however. Given the available documentation from the DEP, this seems to be a serious flaw that compromises the reliability of the entire report.

III. Samples From Vertical vs. Horizontal Well Bores

FLAW  The actual samples tested from at least two of the three wells used in the study do not seem to be from the horizontal bore material. The sample from the third well might have come from the horizontal bore, but just barely. There is no way to know for sure. I will try to show this within the below chart using information provided by Antero to DEP Office of Oil & Gas. This information is in state records on Antero’s well plats, which become part of the well work application and also part of the final permit.

Table 1. Details about the samples taken from three Antero wells in Doddridge County, WV – and my concerns about the sampling process*

Antero well ID API # Sample’s drilling depth Marcellus depth** Horizontal bore length** Comments / Issues
Morton 1H 47-017-06559 6,856 ft. 7,900 TVD*** 10,600 ft. ~1,044 ft. short of reaching Marcellus formation
McGee 2H 47-017-06622 6,506 ft. 6,900 TVD 8,652 ft. ~394 ft. short of reaching Marcellus
Wentz1 H 47-017-06476 8,119 ft. 7,900 TVD 8,300 ft. Just drilled into Marcellus by 219 ft.
* Original chart found on page 11 of report
** Based on information from Antero’s well plat
*** TVD = Total Vertical Depth

Antero is an active driller in Doddridge County. If any company knows where to find the Marcellus formation it is that company. Well plats are very detailed, technical documents provided to the DEP by the operator regarding the well location, watershed, and leased acres and property boundaries. We need to trust that the information on those plats is accurate and has been reviewed and approved by the permitting agency. Those plats also give the depth of the Marcellus and the length and heading of the lateral or horizontal bore. The Marshall University report gives the drilling depth when the sample was taken on the surface. Using these available well plat records from the DEP it appears that at two of the wells the sample (and its test results included in the report) came from material produced when the experienced drilling operator was not yet into the shale formation.

On the third well, Wentz 1H, the numbers seem to indicate that the sample was taken when the driller said that they were just barely within the shale layer – by 219 feet. Since the drill cuttings take some time to return to the surface from over 7,000 feet down, drilling just a few hundred feet would not at all guarantee that the returned cuttings were totally from the black shale. The processing of the drill cuttings at the shaker table and separator and centrifuge and the mixing in the tubs all cast some doubt on whether the sample, wherever it was taken from, was truly from the horizontal bore material.

On page 11 there is a clear and unambiguous statement:

Three representative sets of drill cuttings from the horizontal drilling activities within the Marcellus Shale formation were collected.

A successful attempt to get three such samples might have then allowed an appropriate waste characterization to be done as needed to accomplish the five required research topics listed in the report’s cover letter. Only an accurate chemical and radiological waste characterization would have allowed scientifically justifiable conclusions to be formulated and then allow for accurate legislation and regulations. It does not seem that West Virginia yet has the required scientific data upon which to confidently formulate laws and regulations to protect public health with regard to shale waste disposal.

Would it not seem prudent – if one wanted a good, representative sample – to make absolutely sure that the operator was, in fact, drilling in the black shale and that the cuttings returning to the surface were, in fact, from the Marcellus bore? That approach would have been eminently defensible and easily accomplished by just waiting for drilling to progress into the lateral bore far enough that the drill cuttings returning to the surface were in fact from the black shale. There might be plausible explanations for this apparent inconsistency or error. Of course, it might be speculated that the Antero-provided information on the well plats is incorrect and not intended to be accurate, or perhaps the driller is not really sure yet where the Marcellus layer starts. There may be many other possible scenarios of explanations. Time will tell.

IV. Research Observations Review

Landfill disposal of drill cuttings

Landfill disposal of drill cuttings

GOOD There are a number of recommendations and suggestions in the study on landfills and leachate related conditions. It seems that a number of these proposals are very accurate and should be implemented. For example:

The report clearly restates that drill cuttings are known to contain radioactive compounds. Since all landfill liners will eventually leak, and since landfills already have ground water test wells for monitoring for potential ground water contamination due to leaking liners, then the well samples should be tested for radiological isotopes. Good idea. They are not required to do that now, but this recommendation should be implemented immediately (pgs. 17 and 21).

GOOD The report recommends that the Publicly Owned Treatment Works (POTW) or in the case of Wetzel County, the on-site wastewater treatment plants, should also test their effluent for radioactive isotopes. This is very important since there is no way to efficiently filter out many of the radioactive isotopes. Such contaminants will pass through traditional wastewater treatment plants.

It is also very useful that the report recommends that all the National Pollution Discharge Elimination System (NPDES) limits at the POTWs be reviewed and required to take into consideration the significantly more challenging chemical and radiological makeup of the shale waste products.

V. Economic Considerations on an Industry Supported Mono-Fill

The legislature asked that the DEP evaluate the feasibility of the natural gas industry to build, own, or operate its own landfill solely for the disposal of the known radioactive waste. This request seems to be a very reasonable approach, since for decades we have only put known radioactive waste products into dedicated landfills that are exclusively and specifically designed for the long term storage of the special waste material.

The discussion of the economic considerations is extremely complete and detailed. They are given in Appendix I and take into consideration a very thorough economic feasibility study of such a proposed endeavor. This section seems to have been compiled by a very talented professional team.

FLAW  However, some of the basic assumptions are a bit askew. For example:

The initial Abstract of the financial analysis states that two new landfills would be needed because we do not want to have the well operators to drive any further than they do now. Interesting. This seems to be not too different than a homeowner while in search for privacy and quiet, builds a home far out into the country and then expects the public sewage lines to be extended miles to his new home so he would not have to incur the cost of a septic system. Homebuilders in rural settings should know they will have to incur expenses for their waste disposal needs. Should gas companies expect that communities to provide cheap waste disposal for them?

More than 15 pages later, the most important aspect is clearly stated that, “…the most salient benefit of establishing a separate landfill sited specifically to receive (radioactive) drill cuttings would be the preservation of existing disposal capacity of existing fills for future waste disposal”. Meaning for my (our) grandchildren. See page 175.

Comprehensive and sound financial details later explain that having the natural gas operators build, operate, and eventually close their own radioactive waste depository landfill would involve a lot of their capital and involve some risk to them. It is stated that their money would be better used drilling more wells. The conclusion then seems to be that, all around, it is simply cheaper and less risky for the gas industry to put all their waste products into our Municipal Waste Landfills, and later residents should incur the costs and risk to build another land fill for their household garbage when needed.

VI. Report Omissions

  1. Within the report section dealing with the leachate test results, it is casually mentioned that not only do the landfills receiving shale waste materials have radioactive contaminated leachate, but the other tested landfills do, as well. However, rather than raising a very red flag and expressing concern over a problem that no one has looked into, the report implies we should not worry about any radioactive waste because it might be in all landfills (pg. 139).
  2. Nowhere within the radiological discussion is there any mention of what might be called speciation of radioactive isotopes. The report does state that the test for both gross alpha and gross beta, are considered a “scanning procedure.” The speciation process is sort of a slice and dice procedure, showing exactly what isotopes are responsible for the activity that is being indicated. This process, however, does not seem to have been done on the landfill leachate test samples. The general scanning process cannot do that. Appendix H, pages 141-142, contains detailed facts on radiation dose, risk, and exposure. This might have been a good place to also discuss the proper EPA testing protocols, used or not used, and why.
  3. A short discussion of the DEP-required landfill entrance radiation monitors is included on page 146. The installed monitors are the goalpost type. Trucks drive between them at the entrance and when they cross the scales. It seems that the report should have emphasized that that type of monitor will primarily only detect high-energy gamma radiation. However what is omitted on page 144 is that the primary form of decay for radium-226 is releasing alpha particles. The report is ambiguous in saying the decay products of radium-226 include both alpha particles and some gamma radiation, but radium-266 is not a strong gamma emitter. It is very unlikely that a normal steel enclosed roll-off box would ever trip the alarm setting with a load of drill cuttings. However those monitors are still useful since they will detect the high-energy gamma radiation from a truck carrying a lot of medical waste (pg. 17).
  4. It is stated on page 144 that the greatest health risk due to the presence of radium-226 is the fact that its daughter product is radon-222. Radium-226 has a half-life of 1,600 years, compared to radon’s 3.8 days. This difference might seem to imply that radon is less of a concern. Given the multitude of radium-226 going into our landfills means that we will be producing radon for a very long time.

VII. Resource Referenced in Article

Examination of Leachate, Drill Cuttings and Related Environmental, Economic and Technical Aspects Associated with Solid Waste Facilities in West Virginia, by Marshall University.

Injection wells in OH for disposing of oil and gas wastewater
Ted Auch, PhD

Threats to Ohio’s Water Security

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Ohio waterways face headwinds in the form of hydraulic fracturing water demand and waste disposal

By Ted Auch, PhD – Great Lakes Program Coordinator, and Elliott Kurtz, GIS Intern and University of Michigan Graduate Student

In just 44 of its 88 counties, Ohio houses 1,134 wells – including those producing oil and natural gas and Class II injection wells into which the industry’s waste is disposed. Last month we wrote about Ohio’s disturbing fracking waste disposal trend and the disproportionate influence of neighboring states. (Prior to that Ariel Conn at Virginia Tech outlined the relationship between Class II Injection Wells and induced seismicity on FracTracker.) This time around, we are digging deeper into how water demand is related to Class II disposal trends.

Ohio’s Utica oil and gas wells are using 7 million gallons of freshwater – or 2.4-2.8 million more than the average well cited by the US EPA.1 Below we explore the inter-county differences of the water used in these oil and gas wells, and how demand compares to residential water demand and wastewater production.

Please refer to Table 1 at the end of this article regarding the following findings.

Utica Shale Freshwater Demand

Data indicate that there may be serious threats to Ohio’s water security on the horizon due to the oil and gas industry.

OH Water Use

The counties of Guernsey and Monroe are next up with water demand and waste water generation at rates of 14.6 and 10.3 million gallons per year. However, the 11.4 million gallons of freshwater demand and fracking waste produced by these two counties 114 Utica and Class II wells still accounts for roughly 81% of residential water demand.

The wells within the six-county region including Meigs, Washington, Athens, and Belmont along the Ohio River use 73 million gallons of water and generate 51 million gallons of wastewater per year, while the hydraulic fracturing industry’s water-use footprint ranges between 48 and 17% of residential demand in Coshocton and Athens, respectively. Class II Injection well disposal accounts for a lion’s share of this footprint in all but Belmont County, with injection well activities equaling 77 to 100% of the industry’s water footprint (see Figure 1 for county locations and water stress).

Primary Southeast Ohio Counties experiencing Utica Shale and Class II water stress

Figure 1. Primary Southeast Ohio counties experiencing Utica Shale and Class II water stress

The next eight-county cohort is spread across the state from the border of Pennsylvania and the Ohio River to interior Appalachia and Central Ohio. Residential water demand there equals 428 million gallons, while the eight county’s 92 Utica and 90 Class II wells have accounted for 15 million gallons of water demand and disposal. Again the injection well component of the industry accounts for 5.8% of the their 7.7% footprint relative to residential demand. The range is nearly 10% in Vinton and 5.3% in Jefferson County.

The next cohort includes twelve counties that essentially surround Ohio’s Utica Shale region from Stark and Mahoning in the Northeast to Pickaway, Hocking, and Gallia along the southwestern perimeter of “the play.” These counties’ residents consume 405 million gallons of water and generate 329 million gallons of wastewater annually. Meanwhile the industry’s 69 Class II wells account for 53 million gallons – a 2.8% water footprint.

Finally, the 11 counties with the smallest Utica/Class II footprint are not suprisingly located along Lake Erie, as well as the Michigan and Indiana border, with water demand and wastewater production equalling nearly 117 billion gallons per year. Meanwhile the region’s 3 Utica and 18 Class II wells have utilized 59 million gallons. These figures equate to a water footprint of roughly 00.15%, more aligned with the 1% of total annual water use and consumption for the hydraulic fracturing industry cited by the US EPA this past June.

Future Concerns and Projections

Industry will see their share of the region’s hydrology increase in the coming months and years given that injection well volumes and Utica Shale demand is increasing by 1.04 million gallons and 405-410 million gallons per quarter per well, respectively. The number of people living in these 42 counties is declining by 0.6% per year, however, 1.4% in the 10 counties that have seen the highest percentage of their water resources allocated to Utica and Class II operations. Additionally, hydraulic fracturing permitting is increasing by 14% each year.2

Table 1. Residential, Utica Shale, and Class II Injection well water footprint across forty-two Ohio Counties (Note: All volumes are in millions of gallons)

Table1

Footnotes & Resources

1. In their recent “Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources” (Note: Ohio’s hydraulically fractured wells are using 6% reused water vs. the 18% cited by the EPA).

2. Auch, W E, McClaugherty, C, Gallemore, C, Berghoff, D, Genshock, E, Kurtz, E, & Jurjus, R. (2015). Ramification of current and future production, resource utilization, and land-use change in the Ohio Utica Shale Basin. Paper presented at the National Environmental Monitoring Conference, Chicago, IL.

Northeast Ohio Class II injection wells taken via FracTracker's mobile app, May 2015
Ted Auch, PhD

OH Class II Injection Wells – Waste Disposal and Industry Water Demand

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By Ted Auch, PhD – Great Lakes Program Coordinator

Waste Trends in Ohio

Map of Class II Injection Volumes and Utica Shale Freshwater Demand in Ohio

Map of Class II Injection Volumes and Utica Shale Freshwater Demand in Ohio. Explore dynamic map

It has been nearly 2 years since last we looked at the injection well landscape in Ohio. Are existing disposals wells receiving just as much waste as before? Have new injection wells been added to the list of those permitted to receive oil and gas waste? Let’s take a look.

Waste disposal is an issue that causes quite a bit of consternation even amongst those that are pro-fracking. The disposal of fracking waste into injection wells has exposed many “hidden geologic faults” across the US as a result of induced seismicity, and it has been linked recently with increases in earthquake activity in states like Arkansas, Kansas, Texas, and Ohio. Here in OH there is growing evidence – from Ashtabula to Washington counties – that injection well volumes and quarterly rates of change are related to upticks in seismic activity.

Origins of Fracking Waste

Furthermore, as part of this analysis we wanted to understand the ratio of Ohio’s Class II waste that has come from within Ohio and the proportion of waste originating from neighboring states such as West Virginia and Pennsylvania. Out of 960 Utica laterals and 245+ Class II wells, the results speak to the fact that a preponderance of the waste is coming from outside Ohio with out-of-state shale development accounting for ≈90% of the state’s hydraulic fracturing brine stream to-date. However, more recently the tables have turned with in-state waste increasing by 4,202 barrels per quarter per well (BPQPW). Out-of-state waste is only increasing by 1,112 BPQPW. Such a change stands in sharp contrast to our August 2013 analysis that spoke to 471 and 723 BPQPW rates of change for In- and Out-Of-State, respectively.

Brine Production

Ohio Class II Injection Well trends In- and Out-Of-State, Cumulatively, and on Per Well basis (n = 248).

Figure 1. Ohio Class II Injection Well trends In- and Out-Of-State, Cumulatively, and on Per Well basis (n = 248).

For every gallon of freshwater used in the fracking process here in Ohio the industry is generating .03 gallons of brine (On average, Ohio’s 758 Utica wells use 6.88 million gallons of freshwater and produce 225,883 gallons of brine per well).

Back in August of 2013 the rate at which brine volumes were increasing was approaching 150,000 BPQPW (Learn more, Fig 5), however, that number has nearly doubled to +279,586 BPQPW (Note: 1 barrel of brine equals 32-42 gallons). Furthermore, Ohio’s Class II Injection wells are averaging 37,301 BPQPW (1.6 MGs) per quarter over the last year vs. 12,926 barrels BPQPW – all of this between the initiation of frack waste injection in 2010 and our last analysis up to and including Q2-2013. Finally, between Q3-2010 and Q1-2015 the exponential increase in injection activity has resulted in a total of 81.7 million barrels (2.6-3.4 billion gallons) of waste disposed of here in Ohio. From a dollars and cents perspective this waste has generated $2.5 million in revenue for the state or 00.01% of the average state budget (Note: 2.5% of ODNR’s annual budget).

Freshwater Demand Growing

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

Figure 2. Ohio Class II Injection Well disposal as a function of freshwater demand by the shale industry in Ohio between Q3-2010 and Q1-2015.

The relationship between brine (waste) produced and freshwater needed by the hydraulic fracturing industry is an interesting one; average freshwater demand during the fracking process accounts for 87% of the trend in brine disposal here in Ohio (Fig. 2). The more water used, the more waste produced. Additionally, the demand for OH freshwater is growing to the tune of 405-410,000 gallons PQPW, 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.

Where will all this waste go? I’ll give you two guesses, and the first one doesn’t count given that in the last month the ODNR has issued 7 new injection well permits with 9 pending according to the Center For Health and Environmental Justice’s Teresa Mills.

Landfill disposal of drill cuttings
FracTracker Alliance

Has radioactivity risk from oil and gas activity been underrated?

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Reviewing a Pennsylvania TENORM Study

By Juliana Henao, Communications Intern

Technologically-enhanced, naturally-occurring radioactive materials, also known as TENORM, are produced when radionuclides deep in the earth are brought to the surface by human activity such as oil and gas drilling. The radioactive materials, which include uranium (U), thorium (th), potassium-40 (K-40) and their decay products, occur naturally in the environment. These materials are known to dissolve in produced water, or brine, from the hydraulic fracturing process (e.g. fracking), can be found in drilling muds, and can accumulate in drilling equipment over time.

According to the EPA, ~30% of domestic oil and gas wells produce TENORM. Surveys have shown that 90% of the wells show some TENORM concentrations, while others have nothing at all. However, with increasing natural gas exploration and production in Pennsylvania’s Marcellus Shale, there is a parallel increase in TENORM. According to Dr. Marvin Resnikoff, an international expert on radiation, drilling companies and geologists locate the Marcellus Shale layer by way of its higher level of radiation.

Bringing more of this TENORM to the surface has the potential to greatly impact public health and the environment. Since 2013, the Pennsylvania Department of Environmental Protection (PA DEP) has been gathering raw data on TENORM associated with oil and gas activity in the state. The study was initiated due to the volume of waste containing high TENORM concentrations in the state’s landfills, something that is largely unregulated at the state and federal level.  In January 2015, the PA DEP released a report that outlined their findings and conclusions, including potential exposures, TENORM disposal practices, and possible environmental impacts.

Radioactivity Study Overview

Drilling mud being collected on the well pad

This review touches on the samples tested, the findings, and the conclusions drawn after analysis. The main areas of concern included potential exposure to workers, members of the public, and the environment.

The samples gathered by the DEP came from 38 well sites, conventional and unconventional, by testing solids, liquids, ambient air, soils, and natural gas near oil and gas activity in Pennsylvania. All samples contained TENORM or were in some way impacted by TENORM due to oil and gas operations. The samples were mainly tested for radioactive isotopes, specifically radium, through radiological surveys.

The PA DEP concluded in the cases of well sites, wastewater treatment plants (POTW), centralized wastewater treatment plants, zero liquid discharge plants, landfills, natural gas in underground storage, natural gas fired power plants, compressor stations, natural gas processing plants, radon dosimetry (the calculation and assessment of the radiation dose received by the human body), and oil and gas brine-treated roads that there is little potential for internal radiation exposure to workers and members of the public. In spite of this, each section of the report typically concluded with: however, there is a potential for radiological environmental impacts…

Examples of these findings include:

  • There is little potential for radiological exposure to workers and members of the public from handling and temporary storage of produced water on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of produced water from unconventional natural gas well sites and from spills that could occur from the transportation of this fluid.
  • There is little potential for radiological exposure to workers and members of the public from sediment-impacted soil at landfills that accepted O&G waste for disposal.  However, there may be a radiological environmental impact to soil from the sediments from landfill leachate treatment facilities that treat leachate from landfills that accept O&G waste for disposal.
  • Radium 226 was detected within the hydraulic fracturing fluid ranging from 64.0-21,000 pCi/L. Radium-228 was also detected ranging from 4.5-1,640 pCi/L. The hydraulic fracturing fluid was made up of a combination of fresh water, produced water, and reuse flowback fluid. There is little potential impact for radiological exposure to workers and members of the public from handling and temporary storage of flowback fluid on natural gas well sites. However, there is a potential for radiological environmental impacts from spills of flowback fluid on natural gas well sites and from spills that could occur from the transport of this fluid.
  • Nine influent and seven effluent leachate samples were collected at the nine selected landfills.  Radium was detected in all of the leachate samples. Radium-226 concentrations were detected in produced water samples ranging from 40.5 – 26,600 pCi/L. Radium-228 concentrations were also detected ranging from 26.0 – 1,900 pCi/L. The Ra-226 activity in unconventional well site produced water is approximately 20 times greater than that observed in conventional well site produced water. The ratio of Ra-226 to Ra-228 in unconventional well site produced water is approximately eight times greater than that found in conventional well site produced water.  (Sections 3.3.4 and 3.6.3) (PA DEP TENORM study report section 9.0)

According to Melody Fleck from Moshannon Group- Sierra Club Executive Committee:

While the report comprehensively covers the processes from drilling to end users, the number of samples collected and analyzed are very sparse for a state-wide study. Just to give an idea, only 8 well sites were sampled during the flowback phase and of the 8 only 4 had enough volume to analyze. Of 14 drill mud samples collected, only 5 were analyzed as liquids, and alpha & beta analysis was only done on one sample.

Obtaining the proper sample size is often a major barrier for field studies. Additional research needs to be conducted with a larger sample size and more rigorous exposure monitoring to determine specific risk metrics for workers and the public.

Current Handling of TENORM

From drilling to distribution, there are many topics of concern associated with TENORM; however, we will focus on the current treatment of TENORM waste, the release of data, and the transparency of this issue.

On a federal level, there are no specific regulations governing many aspects of TENORM, such as sludge or solids containing TENORM from water treatment plants. Additionally, if concentrations of U or Th make up less than .05% by weight, they are seen as an “unimportant quantity” and are exempt from NRE regulation. Currently, 13 states regulate TENORM with varying degrees of standards. Hazardous waste facilities in each state can choose to accept TENORM materials as long as they don’t exceed certain concentrations.

Today, about 12 of PA’s 50 landfills accept such radioactive waste from oil and gas activity at a 1:50 dilution ratio (related to their other intake sources). Under RCRA’s Land Disposal Restrictions, “dilution is prohibited as treatment for both listed and characterized wastes.”

According to the DEP report, hydraulic fracturing produces an enormous stream of waste by-products. Safe disposal of this waste has not yet been devised. A few of the conclusions concerning TENORM disposal and treatment in the report listed some areas of concern, identified below:

  1. Filter cake [1] and its radiological environmental impact if spilled, and
  2. The amount of radioactive waste entering the landfills in PA, which reached 430,317 tons in the first 10 months of 2014.

In unison with the conclusions were recommendations, where the report “recommends considering limiting radioactive effluent discharge from landfills, and adding radium-226 and radium-228 to annual sample analysis of leachate from landfills.” Additionally, the report states that if something such as filter cake spills, it will bring into question the safety of long-term disposal and suggest a protocol revision.

Public Health Concerns

The report identified two places where there is a higher than average radioactive exposure risk for workers and community members of the public: specifically at centralized wastewater treatment plants and zero liquid discharge plants that treat oil and gas wastewater. An additional unknown is whether there is a potential inhalation or ingestion hazard from fixed alpha and beta surface radioactivity if materials are disturbed. As a general precaution, they recommend the evaluation of worker’s use of protective equipment under certain circumstances.

Although research has not come to a consensus regarding a safe level of radiation exposure, it should not be assumed that any exposure is safe. Past research has evaluated two types of radiation exposure: stochastic and non-stochastic, both of which have their own risks and are known to be harmful to the human body. The EPA has defined stochastic effects as those associated with long-term, low level exposure to radiation, while non-stochastic effects are associated with short-term, high-level exposure. From past scientific research, radiation is known to cause cancer and alter DNA, causing genetic mutations that can occur from both stochastic and non-stochastic exposure. Radiation sickness is also common, which involves nausea, weakness, damage to the central nervous system, and diminished organ function. Exposure levels set by the EPA and other regulatory agencies fall at 100 millirem (mrem) per year to avoid acute health effects. As a point of reference, medical X-rays deliver less than 10 mrem, and yearly background exposure can be about 300 mrem.

In the report, Radiological Dose and Risk Assessment of Landfill Disposal of TENORM in North Dakota, Argonne National Laboratory researchers suggest that the exposure to workers be limited and monitored. In many of their studies, they found the doses exceed the 100 mrem/year level in the workers when the appropriate attire is not worn during working hours, which raised some concern.

The DEP deems certain radiation levels “allowable”, but it should be noted that allowable doses are set by federal agencies and may be arbitrary. Based on the PA DEP’s report, consumers of produced gas can get up to 17.8% of their yearly radiation allowance, while POTW workers could get up to 36.3% of their yearly allowable dose. According to the Nuclear Information and Resource Service, radiation bio-accumulates in ecosystems and in the body, which introduces a serious confounder in understanding the risk posed by a dose of 17.8% per year.

Transparency of Radiation Risk

The DEP has been gathering data for their TENORM report since 2012. In July of 2014, Delaware Riverkeeper Network filed a Right-to Know request to obtain the information that the DEP had collected in order for their expert to analyze the raw data. The department refused to release the information, insisting that “the release of preliminary invalidated data, including sample locations, could likely result in a substantial and demonstrable risk of physical harm, pose a security risk and lead to erroneous and/or misleading characterizations of the levels and effects of the radioactive risks.” Essentially, the DEP was equating the risks of radioactive material to the risks of releasing raw data — two incomparable risks. DRN appealed, claiming that they simply sought the raw information, which is presumed public unless exempt, and would have no risk on the public. PA DEP was ordered to release their records to DRN within 30 days.

Conclusion

One observation that you could take from this report is the lack of regulatory advancement. The study is filled with suggestions, like:

  • Radium should be added to the PA spill protocol to ensure cleanups are adequately characterized,
  • A limited potential was found for recreationists on roads with oil and gas brine from conventional natural gas wells–further study should be conducted, and
  • More testing is needed to identify areas of contamination and any area should be cleaned up.

Intent doesn’t make the changes; action does. Will any regulations change, at least in Pennsylvania where radioactive materials are returning to the surface on a daily basis? There seems to be no urgency when it comes to regulating TENORM and its many issues at the state level. Are workers, citizens, and the environment truly being protected or will we wait for a disaster to spur action?

Footnotes:

[1] This is the residue deposited on a permeable medium when a slurry, such as a drilling fluid, is forced against the medium under pressure. Filtrate is the liquid that passes through the medium, leaving the cake on the medium.