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Overhead view of injection well

The Hidden Inefficiencies and Environmental Costs of Fracking in Ohio

Ohio continues to increase fracked gas production, facilitated by access to freshwater and lax radioactive waste disposal requirements.

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Map: Ohio Quarterly Utica Oil and Gas Production along with Quarterly Wastewater Disposal

Well Volumes

A little under a year ago, FracTracker released a map and associated analysis, “A Disturbing Tale of Diminishing Returns in Ohio,” with respect to Utica oil and gas production, highlighting the increasing volume of waste injected in wastewater disposal wells, and trends in lateral length in fracked wells from 2010 to 2018. In this article, I’ll provide an update on Ohio’s Utica oil and gas production in 2018 and 2019, the demands on freshwater, and waste disposal. After looking at the data, I recommend that we holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste in order to minimize negative externalities.

Recently, I’ve been inspired by the works of Colin Woodward[1] and Marvin Harris, who outline the struggle between liberty and the common good. They relate this to the role that commodities and increasing resource intensity play in maintaining or enhancing living standards. This quote from Harris’s “Cannibals and Kings” struck me as the 122 words that most effectively illustrate the impacts of the fracking boom that started more than a decade ago in Central Appalachia:

“Regardless of its immediate cause, intensification is always counterproductive. In the absence of technological change, it leads inevitably to the depletion of the environment and the lowering of the efficiency of production since the increased effort sooner or later must be applied to more remote, less reliable, and less bountiful animals, plants, soils, minerals, and sources of energy. Declining efficiency in turn leads to low living standards – precisely the opposite of the desired result. But this process does not simply end with everybody getting less food, shelter, and other necessities in return for more work. As living standards decline, successful cultures invent new and more efficient means of production which sooner or later again lead to the depletion of the natural environment.” From Chapter 1, page 5 of Marvin Harris’ “Cannibals and Kings: The Origins of Cultures, 1977

In reflecting on Harris’s quote as it pertains to fracking, I thought it was high time I updated several of our most critical data sets. The maps and data I present here speak to intensification and the fact that the industry is increasingly leaning on cheap water withdrawals, landscape impacts, and waste disposal methods to avoid addressing their increasingly gluttonous ways. To this point, the relationship between intensification and resource utilization is not just the purview of activists, academics, and journalists anymore; industry collaborators like IHS Markit admitting as much in their latest analysis pointing to the fact that oil and gas operators “will have to drill substantially more wells just to maintain current production levels and even more to grow production”. Insert Red Queen Hypothesis analogy here!

Oil and Gas Production in Ohio

The four updated data sets presented here are: 1) oil, gas, and wastewater production, 2) surface and groundwater withdrawal rates for the fracking industry, 3) freshwater usage by individual Ohio fracked wells, and 3) wastewater disposal well (also referred to as Class II injection wells) rates.

Below are the most important developments from these data updates as it pertains to intensification and what we can expect to see in the future, with or without the ethane cracker plants being trumpeted throughout Appalachia.

From a production standpoint, total oil production has increased by 30%, while natural gas production has increased by 50% year over year between the last time we updated this data and Q2-2019 (Table 1).

According to the data we’ve compiled, the rate of growth for wastewater production has exceeded oil and is nearly equal to natural gas at 48% from 2017 to 2018.  On average the 2,398 fracked wells we have compiled data for are producing 27% more wastewater per well now than they did at the end of 2017.

————–2017————– ————–2019————–
Oil (million barrels) Gas (million Mcf) Brine (million barrels) Oil (million barrels) Gas (million Mcf) Brine (million barrels)
Max 0.51 12.92 0.23 0.62 17.57 0.32
Total 83.14 5,768.47 76.01 108.15 8,679.12 112.28
Mean 0.40 2.79 0.37 0.45 3.62 0.47

Table 1. Summary statistics for 2,398  fracked wells in Ohio from a production perspective from 2017 to Q2 2019.

 

Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.

Figure 1. Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.

The increasing amount of resources and number of wells necessary to achieve marginal increases in oil and gas production is a critical factor to considered when assessing industry viability and other long-term implications. As an example, in Ohio’s Utica Shale, we see that total production is increasing, but as IHS Markit admits, this is only possibly by increasing the total number of producing wells at a faster rate. As is evidenced in Figure 1, somewhere around the Winter of 2017-2018, the production rate per well began to flatline and since then it has begun to decrease.

Water demands for oil and gas production in Ohio

Since last we updated the industry’s water withdrawal rates, the Ohio Department of Natural Resources (ODNR) has begun to report groundwater rates in addition to surface water. The former now account for nine sites in seven counties, but amount to a fraction of reported withdrawals to date (around 00.01% per year in 2017 and 2018). The more disturbing developments with respect to intensification are:

1) Since we last updated this data, 59 new withdrawal sites have come online. There are currently 569 sites in total in ODNR’s database. This amounts to a nearly 12% increase in the total number of sites since 2017. With this additional inventory, the average withdrawal rate across all sites has increased by 13% (Table 2).

2) Since 2010, the demand for freshwater to be used in fracking has increased by 15.6% or 693 million gallons per year (Figure 2).

3) We expect to see an inflection point when water production will increase to accommodate the petrochemical buildout with cracker plants in Dilles Bottom, OH; Beaver County, PA; and elsewhere. In 2018 alone, the oil and gas industry pulled 4.69 billion gallons of water from the Ohio River Valley. Since 2010, the industry has permanently removed 22.96 billion gallons of freshwater from the Ohio River Valley. It would take the entire population of Ohio five years to use the 2018 rate in their homes.[2]

As we and others have mentioned in the past, this trend is largely due to the bargain basement price at which we sell water to the oil and gas sector throughout Appalachia.[3] To increase their nominal production returns, companies construct longer laterals with orders of magnitude more water, sand, and chemicals.  At this rate, the fracking industry’s freshwater demand will have doubled to around 8.8-.9.5 billion gallons per year by around 2023.  Figure 3 demonstrates that average fracked lateral length continues to increase to the tune of +15.7-21.2% (+1,564-2,107 feet) per quarter per lateral. This trend alone is more than 2.5 times the rate of growth in oil production and roughly 24% greater than the rate of growth in natural gas production (See Table 1).

4. The verdict is even more concerning than it was a couple years ago with respect to water demand increasing by 30% per quarter per well or an average of 4.73 million gallons (Figure 4). The last time we did this analysis >1.5 years ago demand was rising by 25% per quarter or 3.84 million gallons. At that point I wouldn’t have guessed that this exponential rate of water demand would have increased but that is exactly what has happened. Very immediate conversations must start taking place in Columbus and at the region’s primary distributor of freshwater, The Muskingum Watershed Conservancy District (MWCD), as to why this is happening and how to push back against the unsustainable trend.

2017 2018
Sites 510 569
Maximum (billion gallons) 1.059 1.661
Sum (billion gallons) 18.267 22.957
Mean (billion gallons) 0.358 0.404

Table 2. Summary of fracking water demands throughout Ohio in 2017 when we last updated this data as well as how those rates changed in 2018.

Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (Million Gallons Per Year).

Figure 2. Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (million gallons per year).

Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (Feet).

Figure 3. Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (feet).

Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (Million Gallons).

Figure 4. Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (million gallons).

 

Waste Disposal

When it comes to fracking wastewater disposal, the picture is equally disturbing. Average disposal rates across Ohio’s 220+ wastewater disposal wells increased by 12.1% between Q3-2018 and Q3-2019 (Table 3). Interestingly, this change nearly identically mirrors the change in water withdrawals during the same period. What goes down– freshwater – eventually comes back up.

Across all of Ohio’s wastewater disposal wells, total volumes increased by nearly 22% between 2018 and the second half of 2019. However, the more disturbing trend is the increasing focus on the top 20 most active wastewater disposal wells, which saw  an annual increase of 17-18%. These wells account for nearly 50% of all waste and the concern here is that many of the pending wastewater disposal well permits are located on these sites, within close proximity, and/or are proposed by the same operators that operate the top 20.

When we plot cumulative and average disposal rates per well, we see a continued exponential increase. If we look back at the last time, we conducted this analysis, the only positive we see in the data is that at that time, average rates of disposal per well were set to double by the Fall of 2020. However, that trend has tapered off slightly — rates are now set to double by 2022.

Each wastewater disposal well is seeing demand for its services increase by 2.42 to 2.94 million gallons of wastewater per quarter (Figure 5). Put another way, Ohio’s wastewater disposal wells are rapidly approaching their capacity, if they haven’t already.  Hence why the oil and gas industry has been frantically submitting proposals for additional waste disposal wells. If these wells materialize, it means that Ohio will continue to be relied on as the primary waste receptacle for the fracking industry throughout Appalachia.

Variable ——————-All Wells——————- ——————-Top 20——————-
To Q3-2018 To Q3-2019 % Change To Q3-2018 To Q3-2019 % Change
Number of Wells 223 243 +9.0 ——- ——- ——-
Max (MMbbl) 1.12 1.20 +7.1 ——- ——- ——-
Sum (MMbbl) 203.19 247.05 +21.6 101.43 119.31 +17.6
Average (MMbbl) 0.91 1.02 +12.1 5.07 5.97 +17.8

Table 3. Summary Statistics for Ohio’s Wastewater Disposal Wells (millions of barrels (MMbbl)).

Average Fracking Waste Disposal across all of Ohio’s Class II Injection Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (Million Barrels).

Figure 5. Average Fracking Waste Disposal across all of Ohio’s Wastewater Disposal Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (million barrels).

Using the Pennsylvania natural gas data merged with the Ohio wastewater data, we were able to put a finer point on how much wastewater would be produced with a 100,000 barrel ethane cracker like the one PTT Global Chemical has proposed for Dilles Bottom, Ohio. The following are our best estimate calculations assuming 1 barrel of condensate is 20-40% ethane. These calculations required that we take some liberties with the merge of the ratio of gas to wastewater in Ohio with the ratio of gas to condensate in Pennsylvania:

  1. For 2,064 producing Ohio fracked wells, the ratio of gas to wastewater is 64.76 thousand cubic feet (Mcf) of gas produced per barrel of wastewater.
  2. Assuming 40% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 320.08 Mcf of gas per barrel of ethane condensate. For 100,000 barrels of ethane needed per cracker per day, that would result in 494,285 barrels (20.76 million gallons) of brine per day.
  3. Assuming 20% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 640.15 Mcf per barrel of ethane condensate = For 100,000 barrels of ethane needed per cracker per day that would result in 988,571 barrels/41.52 million gallons of wastewater per day.

But wait, here is the real stunner:

  1. The 40% assumption result is 3.81 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 5.37 times the daily rates of brine taken in by the top 20 wells (Note: the top 20 wastewater disposal wells account for 71% of all wastewater  waste taken in by all of the state’s disposal wells).
  2. The 20% assumption result is 7.62 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 10.74 times the daily rates of wastewater taken in by the top 20 wells.

Therefore, we estimate the fracked wells supplying the proposed PTTGC ethane cracker will generate between 20.76 million and 41.52 million gallons of wastewater per day. That is 3.8 to 7.6 times the amount of wastewater currently received by Ohio’s wastewater disposal wells.

What does this means in terms of truck traffic? We can assume that  at least 80% of the trucks that transport wastewater are the short/baby bottle trucks which haul 110 barrels per trip. This means that our wastewater estimates would require between 4,493 and 8,987 truck trips per day, respectively. The pressures this amount of traffic will put on Appalachian roads and communities will be hard to measure and given the current state of state and federal politics and/or oversight it will be even harder to measure the impact inevitable spills and accidents will have on the region’s waterways.

Conclusion

There is no reason to believe these trends will not persist and become more intractable as the industry increasingly leans on cheap waste disposal and water as a crutch. The fracking industry will continue to present shareholders with the illusion of a robust business model, even in the face of rapid resource depletion and precipitous production declines on a per well basis.

I am going to go out on a limb and guess that unless we more holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste, there will be no other supply-side signal that we could send that would cause the oil and gas industry to change its ways. Until we reach that point, we will continue to compile data sets like the ones described above and included in the map below, because as Supreme Court Justice Louis Brandeis once said, “Sunlight is the best disinfectant!”

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison

[1] Colin Woodward’s “American Character: A history of the epic struggle between individual liberty and the common good” is a must read on the topic of resource utilization and expropriation.

[2] https://pubs.er.usgs.gov/publication/cir1441

[3] In Ohio the major purveyor of water for the fracking industry is the Muskingum Watershed Conservancy District (MCWD) and as we’ve pointed out in the past they sell water for roughly $4.50 to $6.50 per thousand gallons. Meanwhile across The Ohio River the average price of water for fracking industry in West Virginia in the nine primary counties where fracking occurs is roughly $8.38 per thousand gallons.

Data Downloads

Quarterly oil, gas, brine, and days in production for 2,390+ Unconventional Utica/Point Pleasant Wells in Ohio from 2010 to Q2-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/Production_To_Q2_2019_WithExcel.zip

Ohio Hydraulic Fracturing Freshwater and Groundwater Withdrawals from 2010 to 2018

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_WaterWithdrawals_2010_2018_WithExcel.zip

Lateral length (Feet) for 3,200+ Fracked Utica/Point Pleasant Wells in Ohio up to and including wells permitted in December, 2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/01/OH_Utica_December_2019_StatePlane_Laterals.zip

Freshwater Use for 2,700+ Unconventional Wells in Ohio from Q3-2011 to Q3-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_FracFocus_December_2019_WithExcel.zip

Quarterly Volume Disposal (Barrels) for 220+ Ohio Class II Salt Water Disposal Wells from 2010 to Q4-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_ClassII_Loc_Vols_10_Q4_2019_WithExcel.zi

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Fracking in Pennsylvania: Not Worth It

Despite the ever-increasing heaps of violations and drilling waste, Pennsylvania’s fracked wells continue to produce an excess supply of gas, driving prices down. To cut their losses, the oil and gas industry is turning towards increased exports and petrochemical production. Continuing to expand fracking in Pennsylvania will only increase risks to the public and to the climate, all for what may amount to another boom and bust cycle that is largely unprofitable to investors.

Let’s take a look at gas production, waste, newly drilled wells, and violations in Pennsylvania in the past year to understand just how precarious the fracking industry is.

Production

Fracked hydrocarbon production continues to rise in Pennsylvania, resulting in an increase in waste production, violations, greenhouse gas emissions, and public health concerns. There are three types of hydrocarbons produced from wells in Pennsylvania: gas, condensate, and oil. Gas is composed mostly of methane, the most basic of the hydrocarbons, but in some parts of Pennsylvania, there can be significant quantities of ethane, propane, and other so-called “natural gas liquids” (NGLs) mixed in. Each of these NGLs are actually gaseous at atmospheric conditions, but operators try to separate these with a combination of pressure and low temperatures, converting them to a liquid phase. Some of these NGLs can be separated on-site, and this is typically referred to as condensate. Fracked wells in Pennsylvania also produce a relatively tiny amount of oil.

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For those of you wondering why we are looking at the November, 2018 through October, 2019 time frame, this is simply a reflection of the available data. In this 12-month period, 9,858 fracked Pennsylvania wells, classified as “unconventional,” reported producing 6.68 trillion cubic feet of gas (Tcf), 4.89 million barrels of condensate, and just over 70,000 barrels of oil.

By means of comparison, Pennsylvania consumed about 1.46 Tcf of gas across all sectors in 2018, of which just 253 billion cubic feet (Bcf) was used in the homes of Pennsylvania’s 12.8 million residents. In fact, the amount of gas produced in Pennsylvania exceeds residential consumption in the entire United States by almost 1.7 Tcf. However, less than 17% of all gas consumed in Pennsylvania is for residential use, with nearly 28% being used for industrial purposes (including petrochemical development), and more than 35% used to generate electricity.

Fracked Gas Production and Consumption in Pennsylvania from 2013 through 2018

Figure 1. Fracked gas production compared to all fracked gas consumption and residential gas consumption in Pennsylvania from 2013 through 2018. Data from ref. Energy Information Administration.

 

While gas production has expansive hotspots in the northeastern and southwestern portions of the state, the liquid production comes from a much more limited geography. Eighty percent of all condensate production came from Washington County, while 87% of all fracked oil came from wells in Mercer County.

Because the definition of condensate has been somewhat controversial in the past (while the oil export ban was still in effect), I asked the Department of Environmental Protection (DEP) for the definition, and was told that if hydrocarbons come out of the well as a liquid, they should be reported as oil. If they are gaseous but condense to a liquid at standard temperature and pressure (60 degrees Fahrenheit and pressure 14.7 PSIA) on-site, then it is to be reported as condensate. Any NGLs that remain gaseous but are removed from the gas supply further downstream are reported as gas in this report. For this reason, it is not really possible to use the production report to find specific amounts of NGLs produced in the state, but it certainly exceeds condensate production by an appreciable margin.

The one-year volume withdrawal of gas from unconventional wells in Pennsylvania is equal to the volume of 3.2 Mount Everests

The volume of gas withdrawn from fracked wells in Pennsylvania in just one year is equal to the volume of 3.2 Mount Everests!

 

Waste

Hydrocarbons aren’t the only thing that come out of the ground when operators drill and frack wells in Pennsylvania. Drillers also report a staggering amount of waste products, including more than 65 million barrels (2.7 billion gallons) of liquid waste and 1.2 million tons of solid waste in the 12-month period.

Waste facilities have significant issues such as inducing earthquakes, toxic leachate, and radioactive sediments in streambeds.

Waste Type Liquid Waste (Barrels) Solid Waste (Tons)
Basic Sediment 63
Brine Co-Product 247
Drill Cuttings 1,094,208
Drilling Fluid Waste 1,439,338 11,378
Filter Socks 143
Other Oil & Gas Wastes 2,236,750 6,387
Produced Fluid 61,376,465 41,165
Servicing Fluid 17,196 3,250
Soil Contaminated by Oil & Gas Related Spills 25,505
Spent Lubricant Waste 1,104
Synthetic Liner Materials 21,051
Unused Fracturing Fluid Waste 7,077 1,593
Waste Water Treatment Sludge 35,151
Grand Total 65,078,240 1,239,831

Figure 2. Oil and gas waste generated by fracked wells as reported by drillers from November 1, 2018 through October 31, 2019. Data from ref: PA DEP.

Some of the waste is probably best described as sludge, and several of the categories allow for reporting in barrels or tons. Almost all of the waste was in the well bore at one time or another, although there are some site-related materials that need to be disposed of, including filter socks which separate liquid and solid waste, soils contaminated by spills, spent lubricant, liners, and unused frack fluid waste.

Where does all of this waste go? We worked with Earthworks earlier this year to take a deep dive into the data, focusing on these facilities that receive waste from Pennsylvania’s oil and gas wells. While the majority of the waste is dealt with in-state, a significant quantity crosses state lines to landfills and injection wells in neighboring states, and sometimes as far away as Idaho.

Please see the report, Pennsylvania Oil & Gas Waste for more details.

 

Drilled Wells

Oil and gas operators have started the drilling process for 616 fracking wells in 2019, which appear on the Pennsylvania DEP spud report. This is less than one third of the 2011 peak of 1,956 fracked wells, and 2019 is the fifth consecutive year with fewer than 1,000 wells drilled. This has the effect of making industry projections relying on 1,500 or more drilled wells per year seem rather dubious.

 

Fracked Unconventional Wells Drilled per Year in Pennsylvania from 2005 through 2019

Figure 3. Unconventional (fracked) wells drilled from 2005 through December 23, 2019, showing totals by regional office. Data from ref: PA DEP.

 

Oil and gas wells in Pennsylvania fall under the jurisdiction of three different regional offices. By looking at Figure 2, it becomes apparent that the North Central Regional Office (blue line) was a huge driver of the 2009 to 2014 drilling boom, before falling back to a similar drilling rate of the Southwest Regional Office.

The slowdown in drilling for gas in recent years is related to the lack of demand for the product. In turn, this drives prices down, a phenomenon that industry refers to as a “price glut.” The situation it is forcing major players in the regions such as Range Resources to reduce their holdings in Appalachia, and some, such as Chevron, are pulling out entirely.

Violations

Disturbingly, 2019 was the fifth straight year that the number of violations issued by DEP will exceed the total number of wells drilled.

Unconventional fracked wells drilled and violations issued from 2005 through 2019

Figure 4. Unconventional (fracked) drilled wells and issued violations from 2005 through December 2019. Data from ref: DEP.

 

Violations related to unconventional drilling are a bit unwieldy to summarize. The 13,833 incidents reported in Pennsylvania fall into 359 different categories, representing the specific regulations in which the drilling operator fell short of expectations. The industry likes to dismiss many of these as being administrative matters, and indeed, the DEP does categorize the violations as either “Administrative” or “Environmental, Health & Safety”. However, 9,998 (72%) of the violations through December 3, 2019, are in the latter category, and even some of the ones that are categorized as administrative seem like they ought to be in environmental, health, and safety. For example, let’s look at the 15 most frequent infractions:

Violation Code Incidents Category
SWMA301 – Failure to properly store, transport, process or dispose of a residual waste. 767 Environmental Health & Safety
CSL 402(b) – POTENTIAL POLLUTION – Conducting an activity regulated by a permit issued pursuant to Section 402 of The Clean Streams Law to prevent the potential of pollution to waters of the Commonwealth without a permit or contrary to a permit issued under that authority by the Department. 613 Environmental Health & Safety
102.4 – Failure to minimize accelerated erosion, implement E&S plan, maintain E&S controls. Failure to stabilize site until total site restoration under OGA Sec 206(c)(d) 595 Environmental Health & Safety
SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP. 540 Environmental Health & Safety
601.101 – O&G Act 223-General. Used only when a specific O&G Act code cannot be used 469 Administrative
402CSL – Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution. 362 Environmental Health & Safety
78.54* – Failure to properly control or dispose of industrial or residual waste to prevent pollution of the waters of the Commonwealth. 339 Environmental Health & Safety
401 CSL – Discharge of pollutional material to waters of Commonwealth. 299 Environmental Health & Safety
102.4(b)1 – EROSION AND SEDIMENT CONTROL REQUIREMENTS – Person conducting earth disturbance activity failed to implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation. 285 Environmental Health & Safety
102.5(m)4 – PERMIT REQUIREMENTS – GENERAL PERMITS – Person failed to comply with the terms and conditions of the E & S Control General Permit. 283 Environmental Health & Safety
78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances. 256 Administrative
78a53 – EROSION AND SEDIMENT CONTROL AND STORMWATER MANAGEMENT – Person proposing or conducting earth disturbance activities associated with oil and gas operations failed to comply with 25 Pa. Code § 102. 247 Environmental Health & Safety
102.11(a)1 – GENERAL REQUIREMENTS – BMP AND DESIGN STANDARDS – Person failed to design, implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation to protect, maintain, reclaim and restore water quality and existing and designated uses. 235 Environmental Health & Safety
CSL 401 – PROHIBITION AGAINST OTHER POLLUTIONS – Discharged substance of any kind or character resulting in pollution of Waters of the Commonwealth. 235 Environmental Health & Safety
OGA3216(C) – WELL SITE RESTORATIONS – PITS, DRILLING SUPPLIES AND EQUIPMENT – Failure to fill all pits used to contain produced fluids or industrial wastes and remove unnecessary drilling supplies/equipment not needed for production within 9 months from completion of drilling of well. 206 Environmental Health & Safety

Figure 5. Top 15 most frequently cited violations for unconventional drilling operations in Pennsylvania through December 3, 2019. Data from ref: DEP.

Of the 15 most common categories, only two are considered administrative violations. One of these is a general code, where we don’t know what happened to warrant the infraction without reading the written narrative that accompanies the data, and is therefore impossible to categorize. The only other administrative violation in the top 15 categories reads, “78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances,” which certainly sounds like it would have some real-world implications beyond administrative concerns.

Check out our Pennsylvania Shale Viewer map to see if there are violations at wells near you.

Bloated With Gas, Fraught With Trouble

To address the excess supply of gas, companies have tried to export the gas and liquids to other markets through pipelines. Those efforts have been fraught with trouble as well. Residents are reluctant to put up with an endless barrage of new pipelines, yielding their land and putting their safety at risk for an industry that can’t seem to move the product safely. The Revolution pipeline explosion hasn’t helped that perception, nor have all of the sinkholes and hundreds of leaky “inadvertent returns” along the path of the Mariner East pipeline system. In a sense, the industry’s best case scenario is to call these failures incompetence, because otherwise they would be forced to admit that the 2.5 million miles of hydrocarbon pipelines in the United States are inherently risky, prone to failure any time and any place.

In addition to increasing the transportation and export of natural gas to new markets, private companies and elected officials are collaborating to attract foreign investors to fund a massive petrochemical expansion in the Ohio River Valley. The planned petrochemical plants intend to capitalize on the cheap feedstock of natural gas.

Pennsylvania’s high content of NGLs is a selling point by the industry, because they have an added value when compared to gas. While all of these hydrocarbons can burn and produce energy in a similar manner, operators are required to remove most of them to get the energy content of the gas into an acceptable range for gas transmission lines. Because of this, enormous facilities have to be built to separate these NGLs, while even larger facilities are constructed to consume it all. Shell’s Pennsylvania Petrochemicals Complex ethane cracker being built in Beaver County, PA is scheduled to make 1.6 million metric tons of polyethylene per year, mostly for plastics.

This comes at a time when communities around the country and the world are enacting new regulations to rein in plastic pollution, which our descendants are going to finding on the beach for thousands of years, even if everyone on the planet were to stop using single-use plastics today. Of course, none of these bans or taxes are currently permitted in Pennsylvania, but adding 1.6 million metric tons per year to our current supply is unnecessary, and indeed, it is only the beginning for the region. A similar facility, known as the PTT Global Chemical cracker appears to be moving forward in Eastern Ohio, and ExxonMobil appears to be thinking about building one in the region as well. Industry analysts think the region produces enough NGLs to support five of these ethane crackers.

Despite all of these problems, the oil and gas industry still plans to fill the Ohio River Valley with new petrochemical plants, gas processing plants, and storage facilities in the hopes that someday, somebody may want what they’ve taken from the ground.

Here’s hoping that 2020 is a safer and healthier year than 2019 was. But there is no need to leave it up to chance. Together, we have the power to change things, if we all demand that our voices are heard. As a start, consider contacting your elected officials to let them know that renewing Pennsylvania’s blocking of municipal bans and taxes on plastic bags is unacceptable.

By Matt Kelso, Manager of Data & Technology, FracTracker Alliance

 

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Fracking Threatens Ohio’s Captina Creek Watershed

FracTracker’s Great Lakes Program Coordinator Ted Auch explores the risks and damages brought on by fracking in Ohio’s Captina Creek Watershed

 

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The Captina Creek Watershed straddles the counties of Belmont and Monroe in Southeastern Ohio and feeds into the Ohio River. It is the highest quality watershed in all of Ohio and a great examples of what the Ohio River Valley’s tributaries once looked, smelled, and sounded like. Sadly, today it is caught in the cross-hairs of the oil and gas industry by way of drilling, massive amounts of water demands, pipeline construction, and fracking waste production, transport, and disposal. The images and footage presented in the story map below are testament to the risks and damage inherent to fracking in the Captina Creek watershed and to this industry at large. Data included herein includes gas gathering and interstate transmission pipelines like the Rover, NEXUS, and Utopia (Figure 1), along with Class II wastewater injection wells, compressor stations, unconventional laterals, and freshwater withdrawal sites and volumes.

Ohio Rover NEXUS Pipelines map

The image at the top of the page captures my motivation for taking a deeper dive into this watershed. Having spent 13+ years living in Vermont and hiking throughout The Green and Adirondack Mountains, I fell in love with the two most prominent tree species in this photo: Yellow Birch (Betula alleghaniensis) and Northern Hemlock (Tsuga candadensis). This feeling of being at home was reason enough to be thankful for Captina Creek in my eyes. Seeing this region under pressure from the oil and gas industry really hit me in my botanical soul. We remain positive with regards to the area’s future, but protective action against fracking in the Captina Creek Watershed is needed immediately!

Fracking in the Captina Creek Watershed: A Story Map

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Want Not, Waste Not? Fossil Fuel Extraction’s Waste Disposal Challenges

Pennsylvania’s fracking industry is producing record amounts of toxic waste — where does it all go?

Drilling for methane and other fossil fuels is an energy-intensive process with many associated environmental costs. In addition to the gas that is produced through high volume hydraulic fracturing (“unconventional drilling,” or “fracking”), the process generates a great deal of waste at the drill site. These waste products may include several dozen tons of drill cutting at every well that is directionally drilled, in addition to liner materials, contaminated soil, fracking fluid, and other substances that must be removed from the site.

In 2018, Pennsylvania’s oil and gas industry (including both unconventional and conventional wells) produced over 2.9 billion gallons (nearly 69 million barrels) of liquid waste, and 1,442,465 tons of solid waste. In this article, we take a look at where this waste (and its toxic components) end up and how waste values have changed in recent years. We also explore how New York State, despite its reputation for being anti-fracking, isn’t exempt from the toxic legacy of this industry.

Waste that comes back to haunt us

According to a study by Physicians, Scientists and Engineers, over 80% of all waste from oil and gas drilling stays within the state of Pennsylvania. But once drilling wastes are sent to landfills, is that the end of them? Absolutely not!

Drilling waste also gets into the environment through secondary means. According to a recent report by investigative journalists at Public Herald, on average, 800,000 tons of fracking waste from Pennsylvania is sent to Pennsylvania landfills. When this waste is sent to landfills, radioactivity and other chemicals can percolate through the landfill, and are collected as leachate, which is then shipped to treatment plants.

Public Herald documented how fourteen sewage treatment plants in Pennsylvania have been permitted by Pennsylvania’s Department of Environmental Protection (PA DEP) to process and discharge radioactive wastes into more than a dozen Pennsylvania waterways.

Public Herald’s article includes an in-depth analysis of the issue. Their work is supported by a map of the discharge sites, created by FracTracker.

Trends over time

Pennsylvania Department of Environmental Protection maintains a rich database of oil and gas waste and production records associated with their Oil and Gas Reporting Website. The changes in waste disposal from Pennsylvania’s unconventional drilling reveal a number of interesting stories.

Let’s look first at overall unconventional drilling waste.

According to data from the federal Energy Information Administration, gas production in Pennsylvania began a steep increase around 2010, with the implementation of high volume hydraulic fracturing in the Marcellus Shale (see Figure 1). The long lateral drilling techniques allowed industry to exploit exponentially more of the tight shale via single well than was ever before possible with conventional, vertical drilling.

Figure 1. Data summary from FracTracker.org, based on EIA data.

The more recently an individual well is drilled, the more robust the production. We see an overall increase in gas production over time in Pennsylvania over the past decade. Paradoxically, the actual number of new wells drilled each year in the past 4-5 years are less than half of the number drilled in 2011 (see Figure 2).

Figure 2: Data summary from FracTracker.org, based on PA DEP data

Why is this? The longer laterals —some approaching 3 miles or more—associated with new wells allow for more gas to be extracted per site.

With this uptick in gas production values from the Marcellus and Utica Formations come more waste products, including copious amounts drilling waste, “produced water,” and other byproducts of intensive industrial operations across PA’s Northern Tier and southwestern counties.

Comparing apples and oranges?

When we look at the available gas production data compared with data on waste products from the extraction process, some trends emerge. First of all, it’s readily apparent that waste production does not track directly with gas production in a way one would expect.

Recall that dry gas production has increased annually since 2006 (see Figure 1). However, the reported waste quantities from industry have not followed that same trend.

In the following charts, we’ve split out waste from unconventional drilling by solid waste in tons (Figure 3) and liquid waste, in barrels (Figure 4).

Figure 3: Annual tonnage of solid waste from the unconventional oil and gas industry, organized by the state it is disposed in. Data source: PA DEP, processed by FracTracker Alliance

Figure 4: Annual volume of liquid waste from the unconventional oil and gas development, organized by state it is disposed in. One barrel is equivalent to 42 gallons. Data source: PA DEP, processed by FracTracker Alliance

Note the striking difference in disposal information for solid waste, compared with liquid waste, coming from Pennsylvania.

“Disposal Location Unknown”

Until just the last year, often more than 50% of the known liquid waste generated in PA was disposed of at unknown locations. The PA DEP waste report lists waste quantity and method for these unknown sites, depending on the year: “Reuse without processing at a permitted facility,” “Reuse for hydraulic fracturing,” “Reuse for diagnostic purposes,” “Reuse for drilling or recovery,” “Reuse for enhanced recovery,” and exclusively in more recent years (2014-2016), “Reuse other than road-spreading.”

In 2011, of the 20.5 million barrels of liquid waste generated from unconventional drilling, about 56% was allegedly reused on other drilling sites. However, over 9 million barrels—or 44% of all liquid waste—were not identified with a final destination or disposal method. Identified liquid waste disposal locations included “Centralized treatment plant for recycle,” which received about a third of the non-solid waste products.

In 2012, the quantity of the unaccounted-for fracking fluid waste dropped to about 40%. By 2013, the percentage of unaccounted waste coming from fracking fluid dropped to just over 21%, with nearly 75% coming from produced fluid, which is briny, but containing fewer “proprietary”—typically undisclosed—chemicals.

By 2017, accounting had tightened up further. PA DEP data show that 99% of all waste delivered to undisclosed locations was produced fluid shipped to locations outside of Pennsylvania. By 2018, all waste disposal was fully accounted for, according to DEP’s records.

In looking more closely at the data, we see that:

  1. Prior to 2018, well drillers did not consistently report the locations at which produced water was disposed of or reused. Between 2012 and 2016, a greater volume of unconventional liquid waste went unaccounted for than was listed for disposal in all other locations, combined.
  2. In Ohio, injection wells, where liquid waste is injected into underground porous rock formations, accounted for the majority of the increase in waste accepted there: 2.9 million barrels in 2017, and 5.7 million barrels in 2018 (a jump of 97%).
  3. West Virginia’s acceptance of liquid waste increased  significantly in 2018 over 2017 levels, a jump of over a million barrels, up from only 55,000. This was almost entirely due to unreported reuse at well pads.
  4. In 2018, reporting, in general, appears to be more thorough than it was in previous years. For example, in 2017, nearly 692,000 barrels of waste were reused at well pads outside PA, but those locations were not disclosed. Almost 7000 more barrels were also disposed of at unknown locations. In 2018, there were no such ambiguities.

A closer look at Pennsylvania’s fracking waste shipped to New York State

Despite a reputation for being resistant to the fracking industry, for most of this decade, the state of New York has been accepting considerable amounts of fracking waste from Pennsylvania. The greatest percentage shipped to New York State is in the form of drilling waste solids that go to a variety of landfills throughout Central and Western New York.

Looking closely at the bar charts above, it’s easy to notice that the biggest recipients of Pennsylvania’s unconventional liquid drilling waste are Pennsylvania itself, Ohio, as well as a significant quantity of unaccounted-for barrels between 2011 and 2016 (“Disposal location unknown”). The data for disposal of solid waste in New York tells a different story, however. In this case, Pennsylvania, Ohio, and New York State all play a role. We’ll take a look specifically at the story of New York, and illustrate the data in the interactive map that follows.

In this map, source locations in Pennsylvania are symbolized with the same color marker as the facility in New York that received the waste from the originating well pad. In the “Full Screen” view, use the “Layers” drop down menu to turn on and off data from separate years.

View map full screenHow FracTracker maps work

Solid waste transported to New York State

From the early days of unconventional drilling in Pennsylvania, New York State’s landfills provided convenient disposal sites due to their proximity to the unconventional drilling occurring in Pennsylvania’s Northern tier of counties. Pennsylvania and Ohio took the majority of solid wastes from unconventional drilling waste from Pennsylvania. New York State, particularly between 2011-2015, was impacted far more heavily than all other states, combined (Figure 5, below).

Figure 5: Known disposal locations (excluding PA and OH) of Pennsylvania’s solid waste. Data source: PA DEP, processed by FracTracker Alliance

Here’s the breakdown of locations in New York to where waste was sent. Solid waste disposal into New York’s landfills also dropped by half, following the state’s ban on unconventional drilling in 2014. Most of the waste after 2012 went to the Chemung County Landfill in Lowman, New York, 10 miles southeast of Elmira.

Figure 6: Solid waste from unconventional drilling, sent to facilities in NYS. Data source: PA DEP, processed by FracTracker Alliance

Is waste immobilized once it’s landfilled?

The fate of New York State’s landfill leachate that originates from unconventional drilling waste is a core concern, since landfill waste is not inert. If drilling waste contains radioactivity, fracking chemicals, and heavy metals that percolate through the landfill, and the resulting leachate is sent to municipal wastewater treatment plants, will traditional water treatment methods remove those wastes? If not, what will be the impact on public and environmental health in the water body that receives the “treated” wastewater? In Pennsylvania, for example, a case is currently under investigation relating to pollution discharges into the Monongahela River near Pittsburgh. “That water was contaminated with diesel fuels, it’s alleged, carcinogens and other pollutants,” said Rich Bower, Fayette County District Attorney.

Currently, a controversial expansion of the Hakes Landfill in Painted Post, New York is in the news. Sierra Club and others were concerned about oversight of radium and radon in the landfill’s leachate and air emissions, presumably stemming from years of receiving drill cuttings. The leachate from the landfill is sent to the Bath Wastewater Treatment plant, which is not equipped to remove radioactivity. “Treated” wastewater from the plant is then discharged into the Cohocton River, a tributary of the Chesapeake Bay. In April 2019, these environmental groups filed a law suit against Hakes C&D Landfill and the Town of Campbell, New York, in an effort to block the expansion.

Similar levels of radioactivity in leachate have also been noted in leachate produced at the Chemung County Landfill, according to Gary McCaslin, President of People for a Healthy Environment, Inc.

In recent years, much of the solid unconventional waste arriving in New York State has gone to the Chemung County Landfill (see Figure 6, above). Over the course of several years, this site requested permission to expand significantly from 180,000 tons per year to 417,000 tons per year. However, by 2016, the expansion was deemed unnecessary, and according, the plans were put on hold, in part “…because of a decline in the amount of waste being generated due to a slower economy and more recycling than when the expansion was first planned years ago.” The data in Figure 5 above also parallel this story, with unconventional drilling waste disposed in New York State dropping from over 200,000 tons in 2011 to just over 20,000 tons in 2018.

Liquid waste transported to New York State

The story about liquid unconventional drilling waste exported from Pennsylvania to states other than Ohio is not completely clear (see Figure 7, below). Note that the data indicate more than a 2000% increase in waste liquids going from Pennsylvania to West Virginia after 2017. While it has not been officially documented, FracTracker has been anecdotally informed that a great deal of waste was already going to West Virginia, but that the record-keeping prior to 2018 was simply not strongly enforced.

Figure 7: Known disposal locations (excluding Pennsylvania and Ohio) of Pennsylvania’s liquid waste. Data source: PA DEP, processed by FracTracker Alliance

Beginning in the very early years of the Pennsylvania unconventional fracking boom, a variety of landfills in New York State have also accepted liquid wastes originating in Pennsylvania, including produced water and flowback fluids (see Figure 8, below).

Figure 8: Liquid waste from unconventional drilling, sent to facilities in New York State. Data source: PA DEP, processed by FracTracker Alliance

In addition, while this information doesn’t even appear in the PA DEP records (which are publicly available back to 2010), numerous wastewater treatment plants did accept some quantity, despite being fully unequipped to process the highly saline waste before it was discharged back into the environment.

One such facility was the wastewater treatment plant in Cayuga Heights, Tompkins County, which accepted more than 3 million gallons in 2008. Another was the wastewater treatment plant in Auburn, Cayuga County, where the practice of accepting drilling wastewater was initially banned in July 2011, but the decision was reversed in March 2012 to accept vertical drilling waste, despite strong public dissent. Another wastewater treatment plant in Watertown, Jefferson County, accepted 35,000 gallons in 2009.

Fortunately, most New York State wastewater treatment plant operators were wise enough to not even consider adding a brew of unknown and/or proprietary chemicals to their wastewater treatment stream. Numerous municipalities and several counties banned fracking waste, and once the ban on fracking in New York State was instituted in 2014, nearly all importation of liquid unconventional drilling waste into the state ceased.

Nevertheless, conventional, or vertical well drilling also generates briny produced water, which the New York State Department of Environmental Conservation (DEC) permits communities in New York to accept for ice and dust control on largely rural roads. These so-called “beneficial use determinations” (BUDs) of liquid drilling waste have changed significantly over the past several years. During the height of the Marcellus drilling in around 2011, all sorts of liquid waste was permitted into New York State (see FracTracker’s map of affected areas) and was spread on roads. As a result, the chemicals—many of them proprietary, of unknown constituents, or radioactive—were indirectly discharged into surface waters via roadspreading.

Overall, in the years after the ban in 2014 on high volume hydraulic fracturing was implemented, restrictions on Marcellus waste coming into New York have strengthened. Very little liquid waste entered New York’s landfills after 2013, and what did come in was sent to a holding facility owned by Environmental Services of Vermont. This facility is located outside Syracuse, New York.

New York State says “no” to this toxic legacy

Fortunately, not long after these issues of fracking fluid disposal at wastewater treatment facilities in New York State came to light, the practice was terminated on a local level. The 2014 ban on fracking in New York State officially prevented the disposal of Marcellus fluids in municipal wastewater treatment facilities and required extra permits if it were to be road-spread.

In New York State, the State Senate—after 8 years of deadlock—in early May 2019, passed key legislation that would close a loophole that had previously allowed dangerous oil and gas waste to bypass hazardous waste regulation. Read the press release from Senator Rachel May’s office here. However, despite strong support from both the Senate, and the Assembly, as well as many key environmental groups, the Legislature adjourned for the 2019 session without bringing the law to a final vote. Said Elizabeth Moran, of the New York Public Interest Research Group (NYPIRG), “I want to believe it was primarily a question of timing… Sadly, a dangerous practice is now going to continue for at least another year.”

 

See Earthworks’ recent three part in-depth reporting on national, New York, and Pennsylvania oil and gas waste, with mapping support by FracTracker Alliance.

All part of the big picture

As long as hydrocarbon extraction continues, the issues of waste disposal—in addition to carbon increases in the atmosphere from combustion and leakage—will result in impacts on human and environmental health. Communities downstream and downwind will bear the brunt of landfill expansions, water contamination, and air pollution. Impacts of climate chaos will be felt globally, with the greatest impacts at low latitudes and in the Arctic.

Transitioning to net-zero carbon emissions cannot be a gradual endeavor. Science has shown that in order to stay under the 1.5 °C warming targets, it must happen now, and it requires the governmental buy-in to the Paris Climate Agreement by every economic power in the world.

No exceptions. Life on our planet requires it.

We have, at most, 12 years to make a difference for generations to come.

By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

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Getting Rid of All of that Waste – Increasing Use of Oil and Gas Injection Wells in Pennsylvania

Oil and gas development generates a lot of liquid waste.

Some of the waste comes that comes out of a well is from the geologic layer where the oil and gas resources are located. These extremely saline brines may be described as “natural,” but that does not make them safe, as they contain dangerous levels of radiation, heavy metals, and other contaminants.

Additionally, a portion of the industrial fluid that was injected into the well to stimulate production, known as hydraulic fracturing fluid, returns to the surface.  Some of these substances are known carcinogens, while others remain entirely secret, even to the personnel in the field who are employed to use the additives.

The industry likes to remind residents that they have used this technique for more than six decades, which is true. What separates “conventional” fracking from developing unconventional formations such as the Marcellus Shale is really a matter of scale.  Conventional formations are often stimulated with around 10,000 gallons of fluid, while unconventional wells now average more than 10 million gallons per well.

In 2017 alone, Pennsylvania oil and gas wells generated 57,653,023 barrels (2.42 billion gallons) of liquid waste.

Managing the waste stream

Liquid waste can be reused to stimulate other oil and gas wells, but reuse concentrates the contaminant load in the fluid. There is a limit to this concentration that operators can use, even for this industrial purpose.

Another strategy is to decrease the volume of the waste through evaporation and other treatment methods. This also increases the contaminant concentration. Pennsylvania used to permit “treatment” of wastewater at sewage treatment facilities, before being forced to concede that the process was completely ineffective, and resulted in contaminating streams and rivers throughout the Commonwealth.

In many states, much of this waste is disposed of in facilities known as salt water disposal (SWD) wells, a specific type of injection well. These waste facilities fall under the auspices of the US Environmental Protection Agency’s Underground Injection Control (UIC) program. Such wells are co-managed with states’ oil and gas regulatory agencies, although the specifics vary by state.

These photos show SWD wells in other states, but what about in Pennsylvania?

The oil and gas industry in Pennsylvania has not used SWD wells as a primary disposal method, as the state’s geology has been considered unsuitable for this process.  For example, on page 67 of this 2009 industry report, the authors saw treatment of flowback fluid at municipal facilities as a viable option (before the process was  banned in 2011), but underground injection as less likely (emphasis added):

The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.

The ban on surface “treatment” being discharged into Pennsylvania waters has increased the pressure for finding new solutions for brine disposal.  This is compounded by the fact that the per-well volume of fluid injected into shale gas wells in the region has nearly tripled in that time period. Much of what is injected comes back up to the surface and is added to the liquid waste stream.

Chemically-similar brine from conventional wells has been spread on roadways for dust suppression. This practice was originally considered a “beneficial use” of the waste product, but the Pennsylvania Department of Environmental Protection (DEP) halted that practice in May 2018.

None of these waste management decisions make the geology in Pennsylvania suddenly suitable for underground injection, however, they do increase the pressure on the state to find a disposal solution.

Concerns with SWD wells

There are numerous concerns with salt water disposal wells.  In October 2018, the DEP held a hearing in Plum Borough, on the eastern edge of Allegheny County, where there is a proposal to convert the Sedat 3A conventional well to an injection well. Some of the concerns raised by residents include:

  • Fluid and/or gas migration- There are numerous routes for fluids and gas to migrate from the injection formation to drinking water aquifers or even surface water.  Potential conduits include coal mines, abandoned gas wells, water wells, and naturally occurring fissures in crumbling sedimentary formations.
  • Induced seismicity- SWD wells have been linked to increased earthquake activity, either by lubricating or putting pressure on old faults that had been dormant. Earthquakes can occur miles away from the injection location, and in sedimentary formations, not just igneous basement rock.
  • Noise, diesel pollution, loss of privacy, and road degradation caused by a constant stream of industrial waste haulers to the well location.
  • Complicating existing issues-  Plum Borough and surrounding communities are heavily undermined, and in fact the well bore goes right through the Renton Coal Mine (another part of which has been on fire for decades).  Mine subsidence is already a widespread issue in the region, and many fear that even small seismic events could exacerbate this.
  • Possibility of surface spill-  Oil and gas is, sadly, a sloppy industry, with unconventional operations having accumulated more than 13,000 violations in Pennsylvania since 2008.  If a major spill were to happen at this location, there is the possibility of release into Pucketa Creek, which drains into the Allegheny River, the source of drinking water for multiple communities.
  • Radioactivity and other contaminants- Flowback fluids are often highly radioactive, contain heavy metals, and other contaminants that are challenging to effectively clean.  The migration of radon gas into homes above the injection formation is also a possibility.

The current state of SWDs in Pennsylvania

Pennsylvania has numerous data sources for oil and gas, but they are not always in agreement. To account for this, we have mapped SWDs (and a five mile buffer around them) from two different data sources in the map below. The first source is a subset of SWD wells from a larger dataset of oil and gas locations from the DEP’s mapping website. The second source is from a Waste Facility Report, represented in pink triangles that are offset at an angle to allow users to see both datasets simultaneously in instances where they overlap.

Map of existing, proposed, and plugged salt water disposal (SWD) injection wells in Pennsylvania.

 View map fullscreen How FracTracker maps work

According to the first data set of DEP’s oil and gas locations, Pennsylvania contains 13 SWDs with an active status, one SWD with a regulatory inactive status, and eight that are plugged. The Waste Facility Report shows 10 SWD wells total, including one well that was left out of the other data set in Annin Township, McKean County.

It is worth noting that Pennsylvania’s definition for an “active” well status is confusing, to put it charitably. It does not mean that a well is currently in operation, nor does it even mean that it is currently permitted for the activity, whether that is waste disposal or gas production, or some other function. An active status means that the well has been proposed for a given use, and the well hasn’t been plugged, or assigned some other status.

The Sedat 3A well in Plum, for example, has an active status, although the DEP has not yet granted it a permit to operate as a SWD well. Another  status type is “regulatory inactive,” which is given to a well that hasn’t been used for its stated purpose in 12 months, but may potentially have some future utility.

Karst, coal mines, and streams

While there are numerous factors worthy of consideration when siting SWD wells, this map focuses on three: the proximity of karst formations, coal mines and nearby streams that the state designates as either high quality or exceptional value.

Karst formations are unstable soluble rock formations like limestone deposits which are likely to contain numerous subsurface voids. These voids are concerning in this context. For one reason, there’s the possibility of contaminated fluids and gasses migrating into underground freshwater aquifers. Also, the voids are inherently structurally unstable, which could compound the impacts of artificially-induced seismic activity caused by fluid injections in the well.

Our analysis found over 78,000 acres (123 square miles) of karst geology within five miles of current, proposed, or plugged SWD wells in Pennsylvania.

Coal mines, while a very different sedimentary formation, have similar concerns because of subsurface voids. Mine subsidence is already a widespread problem in many of the communities surrounding SWD well sites.  Pennsylvania has several available data sets, including active underground mine permits and digitized mined areas, which are used in this map.  Active mine permits show current permitted operations, while digitized mine areas offer a highly detailed look at existing mines, including abandoned mines, although the layer is not complete for all regions of the state.

In Pennsylvania, there are 56,542 acres (88 square miles) of active mines within five miles of SWD wells. Our analysis found 97,902 acres (153 square miles) of digitized mined areas within five miles of SWD wells.  Combined, there are 139,840 acres (219 square miles) of existing and permitted mines within the 5 mile buffer zone around SWDs in Pennsylvania.

Streams with the designation “high quality” and “exceptional value” are the best streams Pennsylvania has to offer, in terms of recreation, fishing, and biological diversity. In this analysis, we have identified such streams within a five mile radius of SWD wells, irrespective of the given watershed of the well location.

While the rolling topography of Western Pennsylvania sheds rainwater in a complicated network of drainages, groundwater is not subject to that particular geography. Furthermore, groundwater regularly interacts with surface water through water wells, abandoned O&G wells, and natural seeps and springs. Therefore, it is possible for SWDs to contaminate these treasured streams, even if they are not located within the same watershed.

Altogether, there are 716 miles of high quality streams and 110 miles of exceptional value streams within 5 miles of the SWDs in this analysis.

Conclusion

For decades, geologists have concluded that the subsurface strata in Pennsylvania were not suitable for oil and gas liquid waste disposal in underground injection wells.  The fact that vast quantities of this waste are now being produced in Pennsylvania has not suddenly made it a suitable location for the practice.  If anything, additional shallow and deep wells have further fractured the sedimentary strata, thereby increasing the risk of contamination.

The only factor that has changed is the volume of waste being produced in the region. SWD wells in nearby Ohio and West Virginia have capacity issues from their own production wells, and it is not clear that the geologic formations across the border are that much better than in Pennsylvania. But as new wells are drilled and volumes of hydraulic fracturing fluid continue to spiral into the tens of millions of gallons per well, the pressure to open new SWD wells in the state will only increase.

Perhaps because of these pressures, DEP has become quite bullish on the technology:

Several successful disposal wells are operating in Pennsylvania and options for more sites are always being considered. The history of underground disposal shows that it is a practical, safe and effective method for disposing of fluids from oil and gas production.
Up against this attitude, residents are facing an uphill battle trying to prevent harm to their health and property from these industrial facilities in their communities.  Municipalities that have attempted to stand up for their residents have been sued by DEP to allow for these injection wells.  The Department’s actions, which put the interests of industry above the health of residents and the environment, is directly at odds with the agency’s mission statement:
The Department of Environmental Protection’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. We will work as partners with individuals, organizations, governments and businesses to prevent pollution and restore our natural resources.
It’s time for DEP to live up to its promises.

By Matt Kelso, Manager of Data and Technology, FracTracker Alliance

Bird's eye view of an injection well (oil and gas waste disposal)

A Disturbing Tale of Diminishing Returns in Ohio

Utica oil and gas production, Class II injection well volumes, and lateral length trends from 2010-2018

The US Energy Information Administration (EIA) recently announced that Ohio’s recoverable shale gas reserves have magically increased by 11,076 billion cubic feet (BCF). This increase ranks the Buckeye State in the top 5 for changes in recoverable shale natural gas reserves between 2016 and 2017 (pages 31- 32 here). After reading the predictable and superficial media coverage, we thought it was time to revisit the data to ask a pertinent question: What is the fracking industry costing Ohio?

Recent Shale Gas Trends in Ohio

According to the EIA’s report, Ohio currently sits at #7 on their list of proven reserves. It is estimated there are 27,021 BCF of shale gas beneath the state (Figure 1).

Graph of natural gas reserves in different states 2016-2017

Figure 1. Proven and change in proven natural gas reserves from 2016 to 2017 for the top 11 states and the Gulf of Mexico (calculated from EIA’s “U.S. Crude Oil and Natural Gas Proved Reserves, Year-End 2017”).

There are a few variations in the way the oil and gas industry defines proven reserves:

…an estimated quantity of all hydrocarbons statistically defined as crude oil or natural gas, which geological and engineering data demonstrate with reasonable certainty to be recoverable in future years from known reservoirs under existing economic and operating conditions. Reservoirs are considered proven if economic producibility is supported by either actual production or conclusive formation testing. – The Organization of Petroleum Exporting Countries

… the quantity of natural resources that a company reasonably expects to extract from a given formation… Proven reserves are classified as having a 90% or greater likelihood of being present and economically viable for extraction in current conditions… Proven reserves also take into account the current technology being used for extraction, regional regulations and market conditions as part of the estimation process. For this reason, proven reserves can seemingly take unexpected leaps and drops. Depending on the regional disclosure regulations, extraction companies might only disclose proven reserves even though they will have estimates for probable and possible reserves. – Investopedia

What’s missing from this picture?

Neither of the definitions above address the large volume of water or wastewater infrastructure required to tap into “proven reserves.” While compiling data for unconventional wells and injection wells, we noticed that the high-volume hydraulic fracturing (HVHF) industry is at a concerning crossroads. In terms of “energy return on energy invested,” HVHF is requiring more and more resources to stay afloat.

OH quarterly Utica oil & gas production along with quarterly Class II injection well volumes:

The map below shows oil and gas production from Utica wells (the primary form of shale gas drilling in Ohio). It also shows the volume of wastewater disposed in Class II salt water disposal injection wells.


 View map fullscreen | How FracTracker maps work

Publications like the aforementioned EIA article and language out of Columbus highlight the nominal increases in fracking productivity. They greatly diminish, or more often than not ignore, how resource demand and waste production are also increasing. The data speak to a story of diminishing returns – an industry requiring more resources to keep up gross production while simultaneously driving net production off a cliff (Figure 2).

Graph of Utica permits in Ohio on a cumulative and monthly basis along with the average price of West Texas Intermediate (WTI) and Brent Crude oil per barrel from September, 2010 to December, 2018

Figure 2. Number of Utica permits in Ohio on a cumulative and monthly basis along with the average price of West Texas Intermediate (WTI) and Brent Crude oil per barrel from September 2010 to December 2018

The Great Decoupling of New Year’s 2013

In the following analysis, we look at the declining efficiency of the HVHF industry throughout Ohio. The data spans the end of 2010 to middle of 2018. We worked with Columbus-area volunteer Gary Allison to conduct this analysis; without Gary’s help this work and resulting map, would not have been possible.

A little more than five years ago today, a significant shift took place in Ohio, as the number of producing gas wells increased while oil well numbers leveled off. The industry’s permitting high-water mark came in June of 2014 with 101 Utica permits that month (a level the industry hasn’t come close to since). The current six-month permitting average is 25 per month.

As the ball dropped in Times Square ringing in 2014, in Ohio, a decoupling between oil and gas wells was underway and continues to this day. The number of wells coming online annually increased by 229 oil wells and 414 gas wells.

Graph showing Number of producing oil and gas wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 3. Number of producing oil and gas wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Graph of Producing oil and gas wells as a percentage of permitted wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 4. Producing oil and gas wells as a percentage of permitted wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Permits

The ringing in of 2014 also saw an increase in the number of producing wells as a percentage of those permitted. In 2014, the general philosophy was that the HVHF industry needed to permit roughly 5.5 oil wells or 7 gas wells to generate one producing well. Since 2014, however, this ratio has dropped to 2.2 for oil and 1.4 for gas well permits.

Put another way, the industry’s ability to avoid dry wells has increased by 13% for oil and 18% for gas per year. As of Q2-2018, viable oil wells stood at 44% of permitted wells while viable gas wells amounted to 71% of the permitted inventory (Figure 4).

Production declines

from the top-left to the bottom-right

To understand how quickly production is declining in Ohio, we compiled annual (2011-2012) and quarterly (Q1-2013 to Q2-2018) production data from 2,064 unconventional laterals.

First, we present average data for the nine oldest wells with respect to oil and gas production on a per day basis (Note: Two of the nine wells we examined, the Geatches MAH 3H and Hosey POR 6H-X laterals, only produced in 2011-2012 when data was collected on an annual basis preventing their incorporation into Figures 6 and 7 belwo). From an oil perspective, these nine wells exhibited 44% declines from year 1 to years 2-3 and 91% declines by 2018 (Figure 5). With respect to natural gas, these nine wells exhibited 34% declines from year 1 to years 2-3 and 79% declines by 2018 (Figure 5).

Figure 5. Average daily oil and gas production decline curves for the above seven hydraulically fractured laterals in Ohio’s Utica Shale Basin, 2011 to Q2-2018

Four of the nine wells demonstrated 71% declines by the second and third years and nearly 98% declines by by Q2-2018 (Figure 6). These declines lend credence to recent headlines like Fracking’s Secret Problem—Oil Wells Aren’t Producing as Much as Forecast in the January 2nd issue of The Wall Street Journal. Four of the nine wells demonstrated 49% declines by the second and third years and nearly 81% declines by Q2-2018 (Figure 7).

Figure 6. Oil production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 7. Natural gas production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Fracking waste, lateral length, and water demand

from bottom-left to the top-right

An analysis of fracking’s environmental and economic impact is incomplete if it ignores waste production and disposal. In Ohio, there are 226 active Class II Salt Water Disposal (SWD) wells. Why so many?

  1. Ohio’s Class II well inventory serves as the primary receptacle for HVHF liquid waste for Pennsylvania, West Virginia, and Ohio.
  2. The Class II network is situated in a crescent shape around the state’s unconventional wells. This expands the geographic impact of HVHF to counties like Ashtabula, Trumbull, and Portage to the northeast and Washington, Athens, and Muskingum to the south (Figure 8).
Map of Ohio showing cumulative production of unconventional wells and waste disposal volume of injection wells

Figure 8. Ohio’s unconventional gas laterals and Class II salt water disposal injection wells. Weighted by cumulative production and waste disposal volumes to Q3-2018.

Disposal Rates

We graphed average per well (barrels) and cumulative (million barrels) disposal rates from Q3-2010 to Q3-2018 for these wells. The data shows an average increase of 24,822 barrels (+1.05 million gallons) per well, each year.

That’s a 51% per year increase (Figure 9).

A deeper dive into the data reveals that the top 20 most active Class II wells are accepting more waste than ever before: an astounding annual per well increase of 728,811 barrels (+30.61 million gallons) or a 230% per year increase (Figure 10). This divergence resulted in the top 20 wells disposing of 4.95 times the statewide average between Q3-2010 and Q2-2013. They disposed 13.82 times the statewide average as recently as Q3-2018 (Figure 11).

All of this means that we are putting an increasing amount of pressure on fewer and fewer wells. The trickle out, down, and up of this dynamic will foist a myriad of environmental and economic costs to areas surrounding wells. As an example, the images below are injection wells currently under construction in Brookfield, Ohio, outside Warren and minutes from the Pennsylvania border.

More concerning is the fact that areas of Ohio that are injection well hotspots, like Warren, are proposing new fracking-friendly legislation. These disturbing bills would lubricate the wheels for continued expansion of fracking waste disposal and permitting. House bills 578 and 393 and Senate Bill 165 monetize and/or commodify fracking waste by giving townships a share of the revenue. Such bills “…would only incentivize communities to encourage more waste to come into their existing inventory of Class II… wells, creating yet another race to the bottom.” Co-sponsors of the bills include Democratic Reps. Michael O’Brien, Glenn Holms, John Patterson, and Craig Riefel.

Lateral Lengths

The above trends reflect an equally disturbing trend in lateral length. Ohio’s unconventional laterals are growing at a rate of 9.1 to 15.6%, depending on whether you buy that this trend is linear or exponential (Figure 12). This author believes the trend is exponential for the foreseeable future. Furthermore, it’s likely that “super laterals” in excess of 3-3.5 miles will have a profound impact on the trend. (See The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia.)

This lateral length increase substantially increases water demand per lateral. It also impacts Class II well disposal rates. The increase accounts for 76% of the former and 88% of the latter when graphed against each other (Figure 13).

Figure 12. Ohio Utica unconventional lateral length from Q3-2010 to Q4-2018

Figure 13. Ohio Utica unconventional water demand and Class II SWD injection well disposal volumes vs lateral length from Q3-2010 to Q4-2018.

Conclusion

This relationship between production, resource demand, and waste disposal rates should disturb policymakers, citizens, and the industry. One way to this problem is to more holistically price resource utilization (or stop oil and gas development entirely).

Unfortunately, states like Ohio are practically giving water away to the industry.

Politicians are constructing legislation that would unleash injection well expansion. This would allow disposal to proceed at rates that don’t address supply-side concerns. It’s startling that an industry and political landscape that puts such a premium on “market forces” is unwilling to address these trends with market mechanisms.

We will continue to monitor these trends and hope to spread these insights to states like Oklahoma and Texas in the future.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance – with invaluable data compilation assistance from Gary Allison


Data Downloads

FracTracker is a proponent of data transparency, and so we often share the data we use to construct our maps analyses. Click on the links below to download the data associated with the present analysis:

  • OH Utica laterals

    Ohio’s Utica HVHF laterals as of December 2018 in length (feet) (zip file)
  • Wastewater disposal volumes

    Inventory of volumes disposed on a quarterly basis from 2010 to Q3-2018 for all 223 active Class II Salt Water Disposal (SWD) Injection wells in Ohio (zip file)
Photo by Pat Sullivan/AP https://www.houstonchronicle.com/news/houston-texas/houston/article/Fracking-research-hits-roadblock-with-Texas-law-6812820.php

California regulators need to protect groundwater from oil and gas waste this time around

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

California’s 2nd Largest Waste Stream

Every year the oil and gas industry in California generates billions of gallons of wastewater, also known as produced water. According to a study by the California Council on Science and Technology, in 2013, more than 3 billion barrels of produced water were extracted along with some 0.2 billion barrels of oil across the state. This wastewater is usually contaminated with a mixture of heavy metals, hydrocarbons, naturally occurring radioactive materials, and high levels of salts. Yet, contaminated wastewater from oil-field operations is exempt from the hazardous waste regulations enforced by the Resource Conservation and Recovery Act (RCRA).

Operators are, therefore, not required to measure or report the chemistry of this wastewater. Even with these unknowns, it is legally re-injected back into groundwater aquifers for disposal. Once an aquifer is contaminated it can be extremely difficult, if not impossible, to clean up again. Particularly in California, where water resources are already stretched thin, underground injection of oil and gas wastewater is a major environmental and economic concern.

Regulatory Deficiency

Under the Underground Injection Control program, wastewater is supposed to be injected only into geologic formations that don’t contain usable groundwater. However, a loophole in the Safe Drinking Water Act allows oil and gas companies to apply for what’s called an aquifer exemption, which allows them to inject wastewater into aquifers that potentially hold high-quality drinking water. To learn more about aquifer exemptions, see FracTracker’s summary, here.

The California department responsible for managing these aquifer exemption permits – the Division of Oil, Gas, and Geothermal Resources (DOGGR) – has for decades failed in its regulatory capacity. In 2015, for example, DOGGR admitted that at least 2,553 wells had been permitted to inject oil and gas waste into non-exempt aquifers – aquifers that could be used for drinking water. Independent audits of DOGGR showed decades of poor record-keeping, lax oversight, and in some cases, outright defiance of the law – showing the cozy relationship between regulators and the oil and gas industry. While 176 wells (those that were injecting into the cleanest drinking water) were initially shut down, most of the rest of the 2,377 permits were allowed to continue injecting into disputed wells through the following two years of the regulatory process.

The injection wells targeted by the Environmental Protection Agency (EPA), including those that were shut down, are shown in the map below (Figure 1).

Figure 1. Map of EPA-targeted Class II Injection Wells


View map fullscreen | How FracTracker maps work | Map Data (CSV): Aquifer Exemptions, Class II Wells

The timeline of all this is just as concerning. The State of California has known about these problems since 2011, when the EPA audited California’s underground injection program and identified substantial deficiencies in its program, including failure to protect some potential underground sources of drinking water, a one-size-fits-all geologic review, and inadequate and under-qualified staffing for carrying out inspections. In 2014, the Governor’s office requested that the California EPA perform an independent review of the program. EPA subsequently made a specific remediation plan and timeline for DOGGR, and in March of 2015 the State finalized a Corrective Action Plan, to be completed by February 2017.

Scientific Review of CA Oil and Gas Activities

Meanwhile, in 2013, the California Senate passed SB-4, which set a framework for regulating hydraulic fracturing in California. Part of the bill required an independent scientific study to be conducted on oil and gas well stimulation, including acid well stimulation and hydraulic fracturing. The California Council on Science and Technology organized and led the study, in collaboration with the Lawrence Berkeley National Laboratories, which combined original technical data analyses and a review of relevant literature, all of which was extensively peer-reviewed. The report argues that both direct and indirect impacts of fracking must be accounted for, and that major deficiencies and inconsistencies in data remained which made research difficult. They also recommended that DOGGR improve and modernize their record keeping to be more transparent.

Figure 2. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

Figure 2*. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

A major component of the SB-4 report covered California’s Class II injection program. Researchers analyzed the depths of groundwater aquifers protected by the Safe Drinking Water Act, and found that injection and hydraulic fracturing activity was occurring within the same or neighboring geological zones as protected drinking water (Figure 2*).

*Reproduced from California Council on Science and Technology: An Independent Scientific Assessment of Well Stimulation in California Vol. 3.

More Exemptions to be Granted

Now, EPA is re-granting exemptions again. Six aquifer exemptions have been granted, and more are on the docket to be considered. In this second time around, it is imperative that regulatory agencies be more diligent in their oversight of this permitting process to protect groundwater resources. At the same time, the 2015 California bill SB 83 mandates the appointment of an independent review panel to evaluate the Underground Injection Control Program and to make recommendations on how to improve the effectiveness of the program. This process is currently in the works and a panel has been assembled, and FracTracker Alliance will be working to provide data, maps and analyses for this panel.

Stay tuned for more to come on which aquifers are being exempted, why, and what steps are being taken to protect groundwater in California.


Feature image by Pat Sullivan/AP

A Hazy Future Report Cover

A Hazy Future: Pennsylvania’s Energy Landscape in 2045

Report Calculates Impacts from PA’s Planned Natural Gas Infrastructure

FracTracker Alliance released the report: A Hazy Future: Pennsylvania’s Energy Landscape in 2045 today, which details the potential future impacts of a massive buildout of Marcellus Shale wells and associated natural gas infrastructure.

Industry analysts forecast 47,600 new unconventional oil and gas wells may be drilled in Pennsylvania by 2045, fueling new natural gas power plants and petrochemical facilities in PA and beyond. Based on industry projections and current rates of consumption, FracTracker – a national data-driven non-profit – estimates the buildout would require 583 billion gallons of fresh water, 386 million tons of sand, 798,000 acres of land, 131 billion gallons of liquid waste, 45 million tons of solid waste, and more than 323 million truck trips to drilling sites.

A Hazy Future - Impact Summary

“Only 1,801 of the 10,851 unconventional wells already drilled count as a part of this projection, meaning we could see an additional 45,799 such wells in the coming decades,” commented Matt Kelso, Manager of Data and Technology for FracTracker and lead author on the report.

Why the push for so much more drilling? Out of state – and out of country – transport is the outlet for surplus production.

“The oil and gas industry overstates the need for more hydrocarbons,” asserted FracTracker Alliance’s Executive Director, Brook Lenker. “While other countries and states are focusing more on renewables, PA seems resolute to increase its fossil fuel portfolio.”

The report determined that the projected cleared land for well pads and pipelines into the year 2045 could support solar power generation for 285 million homes, more than double the number that exist in the U.S.

A Hazy Future shows that a fossil fuel-based future for Pennsylvania would come at the expense of its communities’ health, clean air, water and land. It makes clear that a dirty energy future is unnecessary,” said Earthworks’ Pennsylvania Field Advocate, Leann Leiter. Earthworks endorsed FracTracker’s report. She continued, “I hope Governor Wolf reads this and makes the right choices for all Pennsylvanians present and future.”

A Hazy Future reviews the current state of energy demand and use in Pennsylvania, calculates the footprint of industry projections of the proposed buildout, and assesses what that would look like for residents of the Commonwealth.

About FracTracker Alliance

Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is a national organization with regional offices across the United States in Pennsylvania, the District of Columbia, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional, and national level, informing their actions to positively shape our nation’s energy future.

Questions? Email us: info@fractracker.org.

JOSHUA DOUBEK / WIKIMEDIA COMMONS

Groundwater risks in Colorado due to Safe Drinking Water Act exemptions

Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.

FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.

Learn more about Class II injection wells.

Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.

What exactly are aquifer exemptions?

The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.

Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more

Research shows injection wells do fail

co_classiiwellexplosion

Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.

Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.

Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.

A recent article by ProPublica quoted Mario Salazar, an engineer who worked for 25 years as a technical expert with the EPA’s underground injection program in Washington:

In 10 to 100 years we are going to find out that most of our groundwater is polluted … A lot of people are going to get sick, and a lot of people may die.

Also in the ProPublic article was a study by Abrahm Lustgarten, wherein he reviewed well records and data from more than 220,000 oil and gas well inspections, and found:

  1. Structural failures inside injection wells are routine.
  2. Between 2007-2010, one in six injection wells received a well integrity violation.
  3. More than 7,000 production and injection wells showed signs of well casing failures and leakage.

This means disposal wells can and do fail regularly, putting groundwater at risk. According to Chester Rail, noted groundwater contamination textbook author:

…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.

According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).

As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.

Will existing Class II wells fail?

For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!

Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.

It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.

Aquifer Exemptions in Colorado

According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.

Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.

Map 1. Aquifer exemptions in Colorado


View map fullscreen | How FracTracker maps work

Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.

In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.

Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.

When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.

You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.

Groundwater Monitoring Data Maps

Map 2. Water quality and depths of groundwater wells in Colorado
Groundwater risks in Colorado - Map 2
View live map | How FracTracker maps work

In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.

Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.

Map 3. Spatial “hot-spot” analysis of groundwater quality and depth of groundwater wells in Colorado
Groundwater risks in Colorado - Map 3
View live map | How FracTracker maps work

In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.

The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.

Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.

Site Assessments – Exploring Specific Regions

Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.

From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.

Wells with high or increasing levels of TDS are a red flag for potential contamination events.

Methods

Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.

Case of Increasing TDS Readings

If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)

The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.

This area deserves additional sampling and monitoring to assess whether contamination has occurred.


Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).

Groundwater Contamination Case in 2007

We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.

When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.

co_classiipetition

Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.

 

co_eac_uicpermit

Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.

co_fieldinspectionreport_leak

Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.

Areas where lack of data restricted analyses

In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.

Southeastern Colorado

Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.

In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.

Western Colorado

In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.

Northwestern Colorado

http://digital.denverlibrary.org/cdm/ref/collection/p16079coll32/id/346073

A crew from Bonanza Creek repairs an existing well in the McCallum oil field. Photo by Ken Papaleo / Rocky Mountain News

In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.

Trends and Future Development

Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.

These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.

This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.

Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.

Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.

The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.


Feature Image: Joshua Doubek / WIKIMEDIA COMMONS

Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

 

October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.

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

What are aquifer exemptions? Permitted exemptions from the Safe Drinking Water Act

We’d like to give our readers a bit of background on aquifer exemptions, because we’re going to be covering this topic in a few upcoming blog posts. Stay tuned!

Liquid Waste Disposal

Drilling for oil and gas produces both liquid and solid waste that must be disposed of. The liquid waste from this industry is considered a “Class II waste” according to the US EPA. Aquifers are places underground capable of holding or transmitting groundwater. To dispose of Class II waste, operators are granted aquifer exemptions, by the EPA based on the state’s recommendations. The term “exemption,” specifically, refers to the Safe Drinking Water Act, which protects underground sources of drinking water (USDWs).

Therefore, these exemptions grant oil and gas operators the right to contaminate groundwaters, albeit many of the groundwater formations used for disposal in Class II wells are very deep.

Learn more about disposal well classes and aquifer exemptions on this story map by the US EPA

Aquifer Exemption Criteria

There are several qualifiers for a USDW to be granted exempt from the Safe Drinking Water Act. Aquifer exemptions are granted for underground formations that are not currently used as a source of drinking water and meet one of the following criteria:

  • The formation contains commercially producible minerals or hydrocarbons;
  • The formation is so deep that recovery of water for drinking water purposes is economically or technologically impractical; or,
  • The formation is so contaminated that it would be economically or technologically impractical to render the water fit for human consumption.
  • In some states, aquifer exemptions are not approved for formations with Total Dissolved Solids (TDS*) equal to or less than 3,000 mg/l TDS.

If an underground formation qualifies for an exemption, it does not mean that groundwater cannot be used for drinking water, just that it is not currently a source of drinking water. The most precarious criteria requirement, therefore, is the determination that a USDW is simply not “economically viable” or it is “technologically impractical,” meaning that the cost of drilling a groundwater well to the depth of the aquifer (under the condition of the current need for water) may make the investment impractical. In the near future, this water may be needed and highly valued, however.

TDS = Total dissolved solids are inorganic salts (e.g. calcium, magnesium, potassium, sodium, bicarbonates, chlorides, and sulfates), as well as some organic matter, dissolved in water.

The Lay of the Land

Below, we have put together a map of aquifer exemptions in the U.S. Click on the dots and shaded areas to learn more about a particular aquifer.

Map of all aquifer exemptions in the U.S.

View map fullscreen | How FracTracker maps work


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

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