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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

View Map Fullscreen | How Our Maps Work | Download Map Data (Zip File)

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.
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. 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.