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

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

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

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

Pruitt’s Past as AG

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

A Focus on Environmental Issues

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

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

Potential Conflicts of Interest

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

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

Induced-Seismicity and Wastewater Disposal

OK Map of Recent Earthquakes for Pruitt article

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

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

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

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

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

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

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

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

Pruitt not at fault?

Photo Credit: JIM BECKEL/The Oklahoman

Earthquake damage. Photo Credit: Jim Beckel/The Oklahoman

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

Historical AG Influence

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

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

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

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

A Mission at Risk

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


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

Oklahoma and Kansas Class II Injection Wells and Earthquakes

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

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

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

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

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

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

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

Induced Seismicity Past, Present, and Future


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

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

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


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

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


The September, 2016, Pawnee County Earthquake

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

Oklahoma and Kansas Class II injection wells and geologic faults

View map fullscreenHow FracTracker maps work

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

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

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

Class II Salt Water Disposal (SWD) Injection Well Volumes

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

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

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Oklahoma statistics for 2011 to 2015 (Table 1):

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


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

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

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Kansas statistics for 2015 (Table 1):

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

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



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

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

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


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

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

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


FracTracker Induced Seismicity Infographic (print quality)

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

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


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

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

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

By Ted Auch, PhD – Great Lakes Program Coordinator

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

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

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

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

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

The Class II Landscape in Ohio

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

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

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

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

Figures 4 and 5

Freshwater Demand and Brine Production

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

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

Ohio Class II injection well disposal and freshwater demand

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

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

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


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

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

Figures 7 and 8

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

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

Images From Across Ohio

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


  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.
Oil wastewater pit

Wastewater Pits Still Allowed in California

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. Facility” width=”800″ height=”500″>
Map 4. To view the legend and map full screen, click here.


  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.
Injection wells in OH for disposing of oil and gas wastewater

Threats to Ohio’s Water Security

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)


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

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

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.

Class II Oil and Gas Wastewater Injection and Seismic Hazards in CA

By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance Shake Ground Cover

In collaboration with the environmental advocacy groups Earthworks, Center for Biological Diversity, and Clean Water Action, The FracTracker Alliance has completed a proximity analysis of the locations of California’s Class II oil and gas wastewater injection wells to “recently” active fault zones in California. The results of the analysis can be found in the On Shaky Ground report, available for download at

Production of oil and natural gas results in a large and growing waste stream. Using current projections for oil development, the report projects a potential 9 trillion gallons of wastewater over the lifetime of the Monterey shale. In California the majority of wastewater is injected deep underground for disposal in wells deemed Class II wastewater injection.  The connection between seismic activity and underground injections of fluid has been well established, but with the current surge of shale resource development the occurrence of earthquakes in typically seismically inactive regions has increased, including a recent event in Ohio covered by the LA Times.   While both hydraulic fracturing and wastewater injection wells have been linked to the induction of seismic activity, the impacts of underground injection wells used for disposal are better documented and linked to larger magnitude earthquakes.

Therefore, while hydraulic fracturing of oil and gas wells has also been documented to induce seismic activity, the focus of this report is underground injection of waste fluids.

Active CA Faults

A spatial overview of the wastewater injection activity in California and recently active faults can be viewed in Figure 1, below.

Figure 1. California’s Faults and Wastewater Injection Wells. With this and all maps on this page, click on the arrows in the upper right hand corner of the map to view it fullscreen and to see the legend and more details.

The focus of the On Shaky Ground report outlines the relationship between does a thorough job reviewing the literature that shows how the underground injection of fluids induces seismic activity.  The proximity analysis of wastewater injection wells, conducted by The FracTracker Alliance, provides insight into the spatial distribution of the injection wells.  In addition, the report M7.8 earthquake along the San Andreas fault could cause 1,800 fatalities and nearly $213 billion in economic damages.2  To complement the report and provide further information on the potential impacts of earthquakes in California, FracTracker created the maps in Figure 2 and Figure 3.

Shaking Assessments

Figure 2 presents shaking amplification and shaking hazards assessments. The dataset is generated from seismic evaluations.  When there is an earthquake, the ground will amplify the seismic activity in certain ways.  The amount of amplification is typically dependent on distance to the earthquake event and the material that comprises the Earth’s crust.  Softer materials, such as areas of San Francisco built on landfills, will typically shake more than areas comprised of bedrock at the surface.  The type of shaking, whether it is low frequency or high frequency will also present varying hazards for different types of structures.  Low frequency shaking is more hazardous to larger buildings and infrastructure, whereas high frequency events can be more damaging to smaller structure such as single family houses.  Various assessments have been conducted throughout the state, the majority by the California Geological Survey and the United States Geological Survey.

Figure 2. California Earthquake Shaking Amplification and Class II Injection Wells

Landslide Hazards

Below, Figure 3. Southern California Landslide and Hazard Zones expands upon the map included in the On Shaky Ground report; during an earthquake liquefaction of soil and landslides represent some of the greatest hazards.  Liquefaction refers to the solid earth becoming “liquid-like”, whereas water-saturated, unconsolidated sediments are transformed into a substance that acts like a liquid, often in an earthquake. By undermining the foundations of infrastructure and buildings, liquefaction can cause serious damage. The highest hazard areas shown by the liquefaction hazard maps are concentrated in regions of man-made landfill, especially fill that was placed many decades ago in areas that were once submerged bay floor. Such areas along the Bay margins are found in San Francisco, Oakland and Alameda Island, as well as other places around San Francisco Bay. Other potentially hazardous areas include those along some of the larger streams, which produce the loose young soils that are particularly susceptible to liquefaction.  Liquefaction risks have been estimated by USGS and CGS specifically for the East Bay, multiple fault-slip scenarios for Santa Clara and for all the Bay Area in separate assessments.  There are not regional liquefaction risk estimate maps available outside of the bay area, although the CGS has identified regions of liquefaction and landslide hazards zones for the metropolitan areas surrounding the Bay Area and Los Angeles.  These maps outline the areas where liquefaction and landslides have occurred in the past and can be expected given a standard set of conservative assumptions, therefore there exist certain zoning codes and building requirements for infrastructure.

Figure 3. California Liquefaction/Landslide Hazards and Class II Injection Wells

Press Contacts

For more information about this report, please reach out to one of the following media contacts:

Alan Septoff
(202) 887-1872 x105
Patrick Sullivan
Center for Biological Diversity
(415) 632-5316
Andrew Grinberg
Clean Water Action
(415) 369-9172


  1. Arbelaez, J., Wolf, S., Grinberg, A. 2014. On Shaky Ground. Earthworks, Center for Biological Diversity, Clean Water Action. Available at
  2. Jones, L.M. et al. 2008. The Shakeout Scenario. USGS Open File Report 2008-1150. U.S. Department of the Interior, U.S. Geological Survey.



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