Photo courtesy of Brian van der Brug | LA Times

More Oil Field Wastewater Pits Found in California!

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.

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

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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.

2013 American Industrial Hygiene Association Fall Conference

By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance

FracTracker was recently in attendance at the American Industrial Hygiene Association annual conference, held in Miami, FL, September 28-October 1st.  The FracTracker Alliance’s Kyle Ferrar participated in the workshop “Natural GAS EXTRACTION – Rising Energy Demands Mandate a Multi-Perspective Approach.”  The workshop was moderated by Dr. Mark Roberts, and in addition to the FracTracker Alliance, there was a presentation by NIOSH Senior Industrial Hygienist Eric Esswein and the well-versed chemist, engineer, and industry associate/consultant  John Ely.  The workshop was well-attended (sold out).

In case you missed it, FracTracker’s annotated presentation is posted here:  Ferrar_AIHA Presentation_9.29.13.

Keeping Track of Hydraulic Fracturing in California

By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance

Environmental regulations in California are considered conservative by most state standards. To name a few practices, the state has developed an air quality review board that conducts independent toxicological assessments on a level competitive with the U.S. EPA, and the state instituted the U.S.’s first green house gas cap and trade program. But most recently the California Department of Conservation’s Division of Oil, Gas and Geothermal Resources (DOGGR) has been criticized in the media for its lack of monitoring of hydraulic fracturing activity. DOGGR has been responsive to criticism and preemptive of legislative action and has begun a full review of all well-sites in California to identify which wells have been hydraulically fractured and plan to monitor future hydraulic fracturing. Additionally they have maintained historical records of all wells drilled, plugged, and abandoned in the state in web-accessible databases, which include data for oil and gas, geothermal, and injection wells, as well as other types of support wells such as pressure maintenance, steam flood etc.. The data is also viewable in map format on the DOGGR’s online mapping system (DOMS).

To understand what is missing from the DOGGR dataset, it was compared to the dataset extracted from by SkyTruth. The map “Hydraulic Fracturing in California” compares these two datasets, which can be viewed individually or together as one dataset with duplicates removed. It is interesting to note the SkyTruth dataset categorizes 237 wells as hydraulically fractured that DOGGR does not, and identifies three wells (API #’s 11112215, 23727206, and 10120788) not identified in the DOGGR database. For the some of these 237 wells, DOGGR identifies them as new, which means they were recently drilled and hydraulically fractured and DOGGR will be updating their database. Many are identified as active oil and gas wells., while the rest are identified as well types other than oil and gas. Also the SkyTruth dataset from FracFocus data contains additional information about each well-site, which DOGGR does not provide. This includes volumes of water used for hydraulic fracturing and the fracture date, both of which are vital pieces of monitoring information.

The California State Legislature is currently reviewing California Senate Bill 4 (CA SB 4) written by Sen. Fran Pavley (D-Agoura Hills), which would put in place a regulatory structure for permitting and monitoring hydraulic fracturing and other activity.  A caveat for acidification is also included that would require companies to obtain a specific permit from the state before acidizing a well.  The bill has received criticism from both industry and environmentalists.  While it does not call for a moratorium or regulate what chemicals are used, it is the first legislation that requires a full disclosure of all hydraulic fracturing fluid additives, including those considered proprietary.  This is the last of at least seven bills on the issue, the majority of which have been turned down by lawmakers. The most conservative bills (Assemblywoman Mitchell; D-Culver City) proposed moratoriums on hydraulic fracturing in the state. Earlier this year lawmakers approved a bill (Sen. Pavley; D-Agoura Hills) that would direct the state to complete and independent scientific risk assessment of hydraulic fracturing. The bill directs permitters to deny permits if the study is not finished by January 1, 2015, and also requires public notice before drilling as well as disclosure of chemicals (besides those considered proprietary). In May, a bill (Sen. Wold; D-Davis) was passed requiring drillers to file a $100,000 indemnity bond for each well, with an optional blanket indemnity bond of $5 million for operators with over 20 wells. Another bill (Jackson; D-Santa Barbara) that would require monitoring of both transportation and disposal of wastewater was tabled until next year.

Although hydraulic fracturing has been conducted in California for over a decade, it was not monitored or regulated, and the majority of Californians were not aware of it. Industry groups have portrayed the lack of attention as a testament to its environmental neutrality, but Californians living smack dab in the middle of the drilling tend to tell a different story. The issue is now receiving attention because hydraulic fracturing is such a hotbed topic of contention, along with the potential future of the billions of barrels of oil in the Monterey Shale. The unconventional extraction technology necessary to recover the oil from these deep shale formations is state of the art, which means it is not tried and true. The methods include a combination of high tech approaches, such as horizontal drilling, high volume hydraulic fracturing, and acidification to name a few. Realize: if this technology existed for the last 60 years, the Monterey Shale would already have been developed long ago, along with the rest of the U.S. deep shale formations.

FracTracker Alliance’s *NEW* California Shale Viewer

By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance

The FracTracker Alliance has just recently opened a new office based out of Berkeley, California. As a first step in addressing the unique issues of oil and gas extraction in the Golden State, FracTracker has queried the data that is published by the state’s regulatory agencies, and has translated those datasets into various maps that highlight specific issues. As a first step in this process, FracTracker transcribed the well-site data that is publicly available from the California Department of Conservation’s (DOC) Division of Oil, Gas and Geothermal Resources (DOGGR).

This first phase of analysis is presented in FracMapper on the California page, here. FracTracker has translated the entire DOGGR database into a map layer that can be viewed on the California Shale Viewer map, here. The California Shale Viewer will be continuously updated to map the expanding oil and gas development as it occurs. Featured map layers on the California Shale Viewer focus on hydraulic fracturing in the state of California. The hydraulic fracturing well-site data comes from two sources. First, the layer “CA Hydraulically Fractured Wells Identified by DOGGR” portrays the maps identified by regulatory agency as having been hydraulically fractured. The DOGGR is aware that their dataset is not complete in terms of identifying all wells that have been hydraulically fractured. The second source of data is from our friends at SkyTruth, and provided in the layer “CA Hydraulically Fractured Wells Identified by SkyTruth”. Using a crowd-source platform, SkyTruth has generated a dataset based on the information reported to refuses to provide aggregated datasets of their well-site data. These hydraulically fractured well-sites can be viewed as a individual datasets in the California Shale Viewer, or as a combined layer in the map “California Hydraulically Fractured and Conventional Oil and Gas Wells” map, where you are also able to view the dataset of wells FracFocus identifies as hydraulically fractured, but DOGGR does not.

More information concerning the many different types of wells drilled in California and the status of these wells (whether they are planned, active, idle or plugged) can be found in the “Well Type” map and “Well Status” map, also available on the FracTracker California page.