Posts tagged "EPA UIC program"
Cincinnati City Council Lacks Education On Ohio’s UIC Program
Wednesday, May 22nd, 2013 | 0 Comments
Last week the Cincinnati City Council passed a resolution supporting a statewide ban on injection wells, which unfortunately isn’t the first time they have taken aim at disposal wells. Just last year they passed a resolution to ban injection wells in the city, which is funny because there is not a single producing well in Hamilton County, so why would there ever be a need for a disposal well? But, for some reason, the all-knowing City Council of Cincinnati feels the need to tell eastern Ohioans how they need to live their lives. On behalf of eastern Ohio, thank you for your concern, but I think you should concentrate on your own problems.
Unfortunately, what we have here is a City Council who is legislating on fear of the unknown, instead of from a basis of fact and real-world data. For those of us in eastern Ohio, Class II injection wells are nothing new. In fact, they have been used here in Ohio since the 1960s. Regrettably, the City Council is getting its information from Food & Water Watch, well-known for being an anti oil and gas development organization.
Usually, when making a decision that could potentially affect the whole state, most organizations would like to hear from both sides before making a decision. In this case, a one-sided deluge of misinformation and outright lies is enough for the Cincinnati City Council. However, if the city council would like to learn a bit about Class II injection, this post is for them.
In 1983, the Ohio Department of Natural Resources (ODNR) received primacy from the US EPA to permit, regulate, and enforce Ohio’s Class II underground injection control (UIC) program. In order to gain primacy, ODNR had to demonstrate its rules met or exceeded the federal UIC program. Since that time, Ohio has injected 202 million barrels of brine without one case of groundwater contamination, no doubt a fact that Food & Water Watch left out when lobbying the city council to pass this resolution. Why include facts when falsehoods are much more frightening?
Primacy is also not unique to Ohio. In fact, more than 40 states also have primacy over their UIC programs. In order for Ohio to maintain primacy, it must continue to demonstrate an ability to effectively manage and regulate the program to the EPA, while also being audited by the US EPA on a regular basis.
In addition to being audited (thankfully not by the IRS, especially nowadays), Ohio takes the lead in promulgating rules and regulations to make sure Ohio has one of the most stringent UIC programs in the nation. The UIC program rules and regulations have been updated twice in the past three years, thanks in no small part to on the ground enforcement of the program. This has allowed Ohio to actually go above and beyond what the federal government requires for UIC.
This was made clear in testimony provided to the Ohio legislature as it was considering regulatory revisions this spring. The below chart shows just a few of these examples:
Comparison of Ohio’s Class II Brine Injection Regulations with USEPA Regulations
Ohio Division of Oil & Gas Resources Management
United States Environmental Protection Agency
Unannounced inspections on an average of every 11-12 weeks.
One inspection done per well each year by EPA consultant.
Continuous mechanical integrity monitoring or monthly mini-tests to demonstrate continuous mechanical integrity.
Demonstration of mechanical integrity at least once every five years.
Injection volumes greater than 200 barrels per day require a ½-mile area of review of all other wells. Less than 200 barrels per day is a ¼-mile radius.
All Class II wells shall be cased and cemented to prevent movement of fluids into or between underground sources of drinking water.
ODNR has the authority to require seismic testing and monitoring.
Federal code does not specifically address seismic testing and monitoring.
Again, these are details that Food & Water Watch probably left out when discussing Ohio’s UIC program with Cincinnati City Council.
Vice Mayor Roxanne Qualls, who introduced the resolution, should have probably done a little more research before passing such an uneducated resolution. Maybe next time she would see there are no short term windfalls with oil and gas development, but only providing resources that create jobs and help her city prosper.
If there were no oil and gas development, companies like Procter and Gamble, Ashland, LyondellBasell, Rohm and Haas and even Duke Energy would lack the feedstock that help make these companies employ Cincinnati workers. I am sure she didn’t think about these companies when she decided oil and gas development has no place in her city, though most folks who claim to oppose oil and gas development don’t think about what our economy actually requires to operate. Or simply don’t think, period.
Oil and gas development is responsible for over 6,000 products we use in our everyday lives. If Vice Mayor Qualls would like to stand behind her resolution, then she should also ban any products that use oil and gas in the City of Cincinnati. So I guess the question is, would the City Council be willing to give up any of these products? I think not.
In the end, Cincinnati should stick with legislating issues that affect them and not trying to tell eastern Ohioans how to live their lives. I know they would not like it if we started passing resolutions banning Skyline Chili, and frankly, that would be silly anyway — not unlike trying to ban energy development.
Environmental Groups Seek Weaker Standards for Ohio’s UIC Program
Tuesday, March 19th, 2013 | 0 Comments
Anti-development groups joined forces yesterday to ask the U.S. Environmental Protection Agency to take control of Ohio’s Underground Injection Control program from the the Ohio Department of Natural Resources (ODNR). The groups including the Buckeye Forest Council, FrackFree Mahoning Valley and the Center for Health, Environment and Justice held protests and sent a letter to U.S. EPA requesting as much. What these activists fail to realize, or don’t care to recognize, is that Ohio’s UIC regulations provide broad authorities that exceed those in the federal program. So, these activists have officially gone on record seeking a more lax regulatory environment than what currently exists in Ohio.
According to a report from the Associated Press, the groups are seeking the change due to “recent federal indictments of a Youngstown-area businessman,” previous incidents in Youngstown linked to the same person and what they review as a “general lack of public responsiveness.” Given these activists are seeking a more lax regulatory that will fall to a smaller workforce of inspectors its worth asking if their concerns are supported by the events they reference. So, lets take a look at the facts as they exist, not as they are imagined by some.
In regards to the dumping incident, it’s worth mentioning the suspect was caught engaging in the illegal act because an ODNR employee responded swiftly to a public complaint. This was noted in the Youngstown Vindicator on Wednesday, February 6th. Specifically, the Vindicator noted:
Both the Ohio Department of Natural Resources and the Ohio Environmental Protection Agency received an anonymous tip late Thursday and were on the scene within three hours. They were able to obtain photographic evidence of the dumping taking place,
That doesn’t sound like a “general lack of public responsiveness” to most folks.
In fact, federal charges were filed under the Clean Water Act within a week of the event taking place due to the swift action by investigators with ODNR and Ohio EPA.
Yes, that’s right charges were filed under the Clean Water Act. The same legislation that the Center for Health, Environment and Justice says doesn’t apply to the oil and gas industry. In fact, on their website the group proudly touts efforts ”to end dirty and dangerous fracking; closure of the seven legal loopholes that let frackers in the oil and gas industry ignore the…Clean Water Act,”
It’s also worth noting that the regulations being protested by the activists, as outlined in SB 165, allowed ODNR to revoke the suspected company’s permits throughout the entire state.
So, in review. ODNR officials were on scene within three hours of receiving a tip of illegal dumping taking place. Due to their swift reaction they were able to gather photos of the event taking place which ultimately helped the U.S. EPA and U.S. Department of Justice (DOJ) file charges against the individual which, according to DOJ, could result in three years imprisonment and/or a $250,000 fine.
Meanwhile, the injection well that was linked to previous seismic activity in Youngstown - along with four others in a seven mile radius – has been shut down under indefinite suspension for the better of a year.
Successful history of Ohio’s UIC program
Since Ohio received primacy of the UIC program in 1983 over 200 million barrels of brine have been processed without a single case of groundwater contamination. If ODNR was not doing their jobs and the standards were weak, this certainly wouldn’t be the case. This history is matter of public record, not my opinion.
Since 1983, more than 202 million barrels (42 gallons per barrel) of brine have been injected back into depleted oil and gas reservoirs or deep geologic formations without one single instance of groundwater contamination.
- Ohio Department of Natural Resources Director James Zehringer, House Finance and Appropriations Subcommittee on Agriculture and Development Testimony in Support of House Bill 59
With out a single groundwater contamination case since it received primacy, it seems like ODNR’s UIC program must be doing their job at protecting Ohio’s groundwater.
But what’s more compelling than this is the fact Ohio’s UIC rules and regulations are actually more stringent than those used by the U.S. EPA. This was made clear in testimony provided to the Ohio legislature as it was considering regulatory revisions last year. The below chart shows just a few of these examples:
|Comparison of Ohio’s Class II Brine Injection Regulations with USEPA Regulations|
|Ohio Division of Oil & Gas Resources Management||United States Environmental Protection Agency|
|Unannounced inspections on an average of every 11-12 weeks.||One inspection done per well each year by EPA consultant.|
|Continuous mechanical integrity monitoring or monthly mini-tests to demonstrate continuous mechanical integrity.||Demonstration of mechanical integrity at least once every five years.|
|Injection volumes greater than 200 barrels per day require a ½-mile area of review of all other wells. Less than 200 barrels per day is a ¼-mile radius.||All Class II wells shall be cased and cemented to prevent movement of fluids into or between underground sources of drinking water.|
|ODNR has the authority to require seismic testing and monitoring.||Federal code does not specifically address seismic testing and monitoring.|
These are just a few examples of how Ohio’s regulatory system out performs its federal counterparts. Let’s face it, having unannounced inspections every 11-12 weeks instead of once a year should be something these groups applaud instead of condemn.
Now just because Ohio received its primacy in 1983 doesn’t mean that Ohio is not subjected to review and new rules coming from the U.S. EPA. When ever new rules are placed into effect at the federal level, Ohio must follow them per Section 1425 of the Safe Drinking Water Act. Section 1425 clearly states that states must demonstrate that their existing standards are effective in preventing endangerment of drinking water in the United States. These programs must include permitting, inspection, monitoring, and record-keeping and reporting that demonstrates the effectiveness of their requirements.
The facts are simple and ODNR’s record speaks for itself. The agency is enforcing against the industry and is continuously looking at new rules and regulations to safeguard Ohio’s environment. This is something we have seen with SB 165 in 2010, SB 315 in 2012 and HB 59 in 2013. Having state primacy means rules and regulations can be swiftly implemented and go far and above what’s required at the federal level.
Given all of this, it appears that other than garnering a headline the only thing these activists accomplished was proving just how little they know, or care to know, about the actions of Ohio’s regulators and the regulations in place protecting Ohio’s environment.
Athens Activist Misses The Mark on Injection Wells
Monday, November 19th, 2012 | 4 Comments
Last week, the opinion piece penned by local activist Madelline ffitch regarding Class II injection wells. The column was heavy in rhetoric and anecdotal information, but light on facts.
Though we’ve covered the ins-and-outs of injection wells here on numerous occasions, there remains quite a bit of misinformation continuing to be circulated in our public conversation. Many of these misstatements are repeated in this column, so it seems worth revisiting.
Let’s take a look at some of the more egregious statements, and then separate the facts from the inflammatory.
ffitch: “Outrage about the out-of-state radioactive waste that is being dumped into substandard waste wells in our community…”
Two things off the mark here:
- “Substandard waste wells”
As we’ve covered before, Ohio has the most stringent UIC rules in the country. In fact Ohio’s updates to its regulation of injection wells prompted Tom Tomastik, a national expert on injection wells, to state in an email that Ohio “now has the most stringent Class II saltwater injection well regulations in the United States,”.
Ohio’s regulation of injection wells exceeds the standards set for by the EPA, which granted the state primacy in UIC oversight in 1983. In that time, nearly twenty years now, Ohio has “not had any subsurface [water] contamination,” according to Tomastik.
- “Radioactive waste”
Those who oppose the development of fossil fuels frequently throw around the phrase “radioactive waste” loosely, and it’s a very misleading term. The radioactive material referenced, in veiled phrasing, is naturally occurring radioactive material – or NORM – and it is surprisingly pervasive in every day life. It even occurs in our bodies in the form of radioactive potassium. It is present in things we use frequently, including public drinking water, Brazil nuts, peanut butter or granite countertops. On average, Americans receive a radiation dose of about 620 millirem each year. None of these levels are dangerous to human health, and the same can be said of NORM returning via flowback from a oil or natural gas well.
This fact has been confirmed by numerous and recent studies on the subject, including a radiological survey report by the Co-Physics Corporation in New York that concluded that “rock cuttings from the gas drilling operations, as sampled during this project, have radionuclide levels that do not pose any environmental health problems.”
This reinforces finding from last year by the New York State Department of Environmental Conservation Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program that states, that based upon currently available information, it is anticipated that flowback water do not contain levels of NORM of significance.
In the video below, ODNR Oil and Gas Division Chief Rick Simmers addresses NORM as it relates to oil and gas development.
Radioactive materials that can be associated with oil and gas or injection operations are sometimes referred to as NORM or Naturally Occurring Radioactive Material or TENORM Technically Enhanced Naturally Occurring Radioactive Material. These type of radioactive isotopes are literally in everything, including us.
The Ohio Department of Health is the agency that regulates NORM, TENORM and radioactive issues as a whole. The Ohio Department of Health has tested locations throughout the Utica Shale. They have looked at drill cuttings. They have looked at fluids and have found there are very low levels of NORM well within the established limits by the federal government and reflected in state law. Rick Simmers (January 11th, Covelli Centre, Youngstown)
ffitch: “This week, I talked to a local firefighter who said, as an emergency responder, she does not receive training or equipment to deal with exposure to radioactive hazardous waste,”
Ohio’s emergency responders are well equipped to deal with any rare situation that may arise in oil and gas development. In fact, as the Daily Jeffersonian stated in its article Emergency Response Training for Oil and Gas Field Industry Not New to Ohio, our state is “a trendsetter” for training for gas and oil field emergencies.
For over 12 years, the workshops – free of charge – to emergency responders. This curriculum has been endorsed by the Ohio Fire Chief’s Association, and serves as a model for other developing states developing similar programs of their own.
To date, nearly a thousand emergency responders hailing from over 40 counties have attended the program, which is conducted several times throughout the year.
ffitch: “Then, just yesterday, I heard the news that a friend is selling his farm and moving because he believes that the injection well near his land threatens the health of the livestock he depends on to make his living.”
It’s unfortunate if the gentleman the author refers to here is moving based on the idea that, somehow, his farm or his livestock would be impacted by a nearby injection well.
Injection wells have been developed in agricultural regions since the days of Constantine. According to the EPA’s History of the UIC Program, the use of injection wells was documented as early as A.D. 300, with large-scale commercial use of injection wells in the U.S. beginning in the1930s.
To date, over 144,000 Class II injection wells have been developed across the United States, with 181 (or .12% of the nation’s total) developed here in Ohio.
The EPA has declared the use of injection wells as a “safe and inexpensive” means of disposal, with the main objective of the UIC program ensuring the protection of underground sources of drinking water. This is why the use of injection wells is regulated under the Underground Injection Control program of the federal Safe Drinking Water Act, passed by Congress in 1974. EPA administers the UIC program, and delegates regulatory authority over SDWA to the state of Ohio. The underground injection program is regulated under Section 1422 of the Safe Drinking Water Act.
With over seventeen centuries of success as a safe means of wastewater disposal, one can rest assured there is no cause to move due to an injection well.
ffitch: “No matter where you stand on other issues – Republican, Democrat, Libertarian, right, left or in between – we can all get together on this one. “
This is one we can agree on. The safe, responsible development of our natural energy resources is one of the few issues supported by all parties, including the President of the United States, former Republican presidential nominee Mitt Romney, and Ohio senators Rob Portman (R) and Sherrod Brown (D).
ffitch: “Appalachian Ohio is simply being treated as a big dumpsite for frack-waste trucked in from states that consider this material too hazardous to be dumped in their own backyards. “
In a cross post published this weekend, we covered how this notion is far from fact. Let’s take a quick look some of the highlights coming out of New York and Pennsylvania:
- Pa. DEP Secretary Michael Krancer: “Where wastewater cannot be treated and reused/recycled, the best solution for disposing of high TDS wastewater is deep well injection. Using deep well injection should result in no discharge to either surface or ground water, another fact I pointed out in the NRDC letter. Although much of the best geology in the Commonwealth for deep well injection is currently being used for gas storage, exploration for new injection sites does continue, and DEP and EPA will continue to process any permit applications in accordance with applicable laws and regulations.” (July 31, 2012)
- Krancer added: “While DEP staff and I are ready and willing to work to improve the UIC program in Pennsylvania, given the current structure of the program, I cannot agree that enacting a moratorium on new permits is a sound position.”
- Former Pa. DEP Secretary John Hanger: “The good news about PA drilling wastewater practices is that nearly all shale gas wastewater is either recycled or deep well injected.” (Sept. 18, 2012)
- NPR, StateImpact Pennsylvania: “Several new deep injection wells are in the planning process, one in Brady Township, Clearfield County and two in Warren County.” (Aug. 7, 2012)
- Pa. Dept. of Conservation and Natural Resources: “If the disposal method is to be an injection well, two permits are needed: one from the PADEP and another from the U.S. Environmental Protection Agency. Appendix 5 of the Oil and Gas Operators Manual and Section 78.18 of the Pennsylvania Code…provide more information on these permitting issues.” (DCNR website)
- NY DEC: “No significant adverse impacts are identified with regard to the disposal of liquid wastes.” (Draft SGEIS, 2011, ES p. 12)
- NY Department of Environmental Conservation: “Wells for Disposal of Brine Produced with Oil and/or Gas” (DEC’swebsite lists the disposal wells located in and regulated by the state of New York).
If these states believe that injection wells are “unsafe”, then how are new ones being proposed there? More importantly, why are the regulators saying that the wells are safe?
The fact is injection wells remain the safest, most effective means of waste disposal, as they have for centuries. These are not new or unique operations taking place in Ohio (or elsewhere, for that matter), but rather a time-tested and proven practice.
In the discussion of Ohio’s continuing development of our homegrown energy resources, it is vital we have an honest, fact-based conversation rather than one based in fear and void of any factual information. Our gift in the Utica Shale is an opportunity too great to be hindered by a conversation that is anything but truth.
NRDC Out of Its Depth on Ohio Injection Wells
Thursday, August 23rd, 2012 | 3 Comments
The Natural Resources Defense Council (NRDC) has its sights set on Ohio, but it continues to drop the ball when it comes to demonstrating even a passing knowledge of Ohio’s oil and gas regulatory system. THe latest example: NRDC’s recent blog post entitled “New Ohio Fracking Waste Underground Injection Rules Still Second Class,” which features commentary from an NRDC lawyer that completely misses the mark with respect to the regulations that govern wastewater disposal and management across our state.
While calling Ohio’s Class II well injection program “second class” might make for a good quip, it shows the author has very little understanding of UIC regulations and therefore simply can’t comprehend what some of the most stringent regulations in the nation look like.
Before digging into NRDC’s claim some simple background is needed. The classification of Underground Injection Control (UIC) parameters are set by the U.S. EPA. The classifications have been in place since the passage of the Safe Drinking Water Act (SDWA) in 1974. Currently there are 172,068 Class II UIC wells in the United States and they are considered the preferred and environmentally safe method for disposal of oilfield fluid wastes. Ohio gained primacy of its UIC program from the U.S. EPA in 1983 and since the passage of HB 501 in 1985, Class II wells are the only method of disposal for brine and produced waters.
In gaining this primacy, Ohio has made its rules more stringent then those set by the federal government. For example, federal regulations require one well inspection each year and a demonstration of mechanical integrity at least once every five years.
Ohio on the other hand has unannounced inspections every 11–12 weeks and continuous mechanical integrity monitoring or monthly mini-tests to demonstrate continuous mechanical integrity to ensure proper well functionality. In addition, all new wells in Ohio are required to be continuously monitored and will include an automatic shut-off device set to terminate operations if the permitted maximum allowable surface injection pressure is exceeded.
That means that injection wells in Ohio exceed U.S. EPA standards, are inspected at least four times a year, are monitored 24 hours a day, and can be shut off by operators, or regulators, at a moments notice. To most objective observers none of this sound “second class.”
These regulations make certain that disposal wells are functioning properly at all times and the continuous monitoring will give the operator and the state able warning to correct any issues that could occur.
Of course, Ohio’s regulations go above and beyond inspection and monitoring. At a recent disposal well visit, David Hill described the environmental protections required by regulations to ensure groundwater is protected from well operations.
“8,902 feet deep is the total depth. We have three layers of casing, surrounded by three layers of cement. So if there was to be an issue here, the water would literally have to break through 4 layers of steel and 3 layers of cement to contaminate the fresh water.” – David Hill
Beyond inspections, monitoring and environmental safeguards new regulations are also in place to address seismic concerns which the industry and state takes very seriously. As a result of regulatory changes agreed to by all parties, ODNR can require a variety of tests to determine if faults exists in an area where a disposal well is planned.
These tests include:
- Pressure fall-off testing to ensure tight seals in the reservoir and casing
- Geological investigation of potential faulting within the immediate vicinity of the proposed injection well location, which may include seismic surveys or other methods determined by the chief which will give not only the operator
- Monitoring seismic activity
- Radioactive tracer or spinner survey
- Gamma ray, compensated density-neutron, and resistivity geophysical logging suite on all newly drilled injection wells to determine slight fractures in unknown geological regions of the state
These tests are not required for all new wells being brought online, as the NRDC requests, for very simple reasons. Through out various geologic studies performed by the Ohio Geological Survey, as well as multiple universities over the years, there are many areas of the state where ODNR has a very good knowledge of the geology making this request unnecessary.
Again the NRDC tries to instill fear of the unknown in order to gain support on an incredibly technical subject. It wants to change the rules of the program and have Ohio deem all Class II wells as Class I wells which is something even the U.S. EPA has determined to be unnecessary.
An objective review clearly shows Ohio’s UIC program has the necessary tools and safeguards in place for that make its Class II UIC regulations among the best in the nation. However, it seems the author of this post is a bit to far removed from the Buckeye State to understand the complexity of these regulations, and how they actually work. I suppose he could be forgiven, after all its doubtful he sees many Class II UIC wells from his posh office in Chicago.
Following an earlier post which also misrepresents Ohio’s regulations it is clear that NRDC either has no idea what they are talking about or is choosing to willfully ignore the pragmatic, bi-partisan, regulatory updates that have been undertaken in the Buckeye State in recent years. Maybe jobs and affordable energy don’t matter to NRDC or perhaps they are so devout in their campaign against natural gas that they have blinded themselves to any objectivity on the issue.
Whatever the issue, it says quite a bit that their positions are miles apart from groups actually engaged in a constructive conversation on regulations governing oil and natural gas development. One example, STRONGER, a group supported by U.S. EPA that reviews regulations for their environmental strength and success rate, found Ohio’s regulations to be well managed and meeting their objectives. Those objectives include, of course, the protection of Ohio’s land, air, and water.
Given this, perhaps the Natural Resources Defense Council should change their name to the No Resources Developed Council. It seems this would more closely reflect their actual mission. Meanwhile those of us in Ohio will continue to ensure that oil and natural gas development in the Buckeye State is providing thousands of jobs, saving Ohio consumers billions and is being held to nation leading regulatory standards.
Energy In Depth Ohio Injects Itself Into a Disposal Well
Wednesday, April 4th, 2012 | 1 Comment
Energy In Depth Ohio recently visited a Class II injection well to get a first-hand look at the disposal well process. Our host, Dave Hill, President of David R. Hill, Inc, gave us an all access tour of his facilities and showed us the numerous safety and environmental safeguards in place at these facilities. We share that experience with you on this blog to help Ohioans gain a better sense of how this asset safely disposes byproducts from oil and natural gas development.
Injection Well Background
Injection wells have been regulated by the U.S. EPA for nearly 40 years under the Safe Drinking Water Act. In that time there have been over 144,000 Class II injection wells permitted and constructed in the United States. Here in Ohio, our Class II Injection well program is regulated under the Ohio Department of Natural Resources after they received primacy from the US EPA in 1985. Ohio has permitted 181 injection wells for disposal of produced water from oil and natural gas development.
Steps Involved in the Injection Well Process
There are primarily four steps that go into the injection well process at Mr. Hill’s facility.
Once the water leaves the water trucks, it is pumped into the storage tanks. It is allowed to settle out by gravity, then the water is pumped into the pumped house. We have two large Triplex pumps that take the water and pump the water back into the ground in a well just a few feet behind us at 8,900 feet deep. After the trucks unload the brine, it is pumped into large storage tanks on site where it settles out by using gravity. – Dave Hill
Although the process seems simple enough, it is actually a very delicate process that all begins when a brine truck comes to the site and parks in the bay. Once in the bay, the driver hooks a hose to the brine tank on the truck and pumps the produced water into the well’s storage tanks.
When the trucks are finished pumping they fill out a report detailing what was hauled and the natural gas well site where the liquids originated among other items. The report is in essence a timeline from pick up to delivery – much like the system in place to track a Fed Ex or UPS package.
It contains the UIC number, who the truck owner is. The day they picked it up. The time they picked it up. Who the drive is and where they took it. They brought it to our well, our permit number. API permit number. It has to have the API permit number where it came from, whether its pit water or production water and then the time they dispose it. So it is literally like a chain of custody. – Dave Hill
There are 21 tanks on Mr. Hill’s operation including four large storage tanks where produced water is pumped. The water is then cycled through the remaining 14 tanks until it is transferred into the pump house. The gravity allows most of the dirt or rocks to settle before being transferred to the pump house.
With these storage tanks holding produced water, an operator takes great measure to ensure proper protections are in place. The storage tanks actually sit within a berm with thick plastic lining the area. The berm is designed to hold the entire amount of liquid held in the storage tanks if all of it were to escape- a very unlikely proposition.
If, in the very rare circumstance there is a leak, there is a sump pump designed to pump the leaked liquid back into the storage tanks for proper disposal.
Once in the pump house, the produced water is filtered to remove any dirt and rocks remaining in the water as those remnants could plug the well. Once the produced water is filtered it then goes to one of the Triplex pumps for disposal.
The disposal well itself contains multiple layers of steel and concrete designed to protect the water aquifer from potential contamination. Dave Hill explains the well’s safeguards in the video below including the levels of redundancy designed to exceed those in place in the airline industry for example.
8,902 feet deep is the total depth. We have three layers of casing, surrounded by three layers of cement. So if there was to be an issue here, the water would literally have to break through 4 layers of steel and 3 layers of cement to contaminate the fresh water. – Dave Hill
The well itself is outside the pump house and is smack dab in the middle of a functioning cow pasture. When walking to the well you couldn’t help but notice that the cattle graze all around the fenced in well. Luckily I missed stepping in more than a few cow patties.
The disposal site is roughly the size of a parking spot fenced in to make sure the cows do not disturb the operation. As you can see in the video below the cows graze right beside the fenced in area and are not bothered by the operation.
The elaborate set of pipes takes the produced water from the pump and injects it into the cased and cemented well. At the site is also a telemetry device that enables remote monitoring of the well which allows the well to be monitored inside of the pump house as well as from other remote locations.
A disposal well tour is not something most folks have an opportunity to do. However, it is a worthwhile activity as it provides perspective one could never get otherwise. That is the understanding that disposal wells are a sophisticated and environmentally friendly way of disposing produced water and are a testament to the high safety measures operators take in developing our natural resources.
Beacon Journal: Turning Waste Into Wealth for Ohio
Monday, October 3rd, 2011 | 0 Comments
A couple days removed from the Columbus Dispatch story on the regulated use of injection wells in Ohio, the Akron Beacon Journal follows up on the issue today, with reporter Bob Downing providing lots of good facts and figures – and also a great profile of a few local folks who continue to benefit from the safe disposition of wastewater deep underground.
In doing so, Downing touches on one of the big differences between Ohio and Pennsylvania, where landowners last year collected more than $1.8 billion in rents and royalties alone as a result of Marcellus development. But that $1.8 billion came only from wells that produce natural gas. Here in Ohio, not only will royalties come in the form of energy production at the beginning of the process, but for some folks, they’ll also be generated at the end when it comes time to dispose of the water.
The Beacon Journal tracks the story of one gentleman who’s been collecting rents for years – Roger Root of Trumbell County. According to the Mr. Root: We didn’t have Christmas for a couple of years, but the payments made sure that the taxes were paid and that we didn’t lose the farm. It helped save our farm. It saved us.” And all this, remember, from a well that isn’t even producing oil or natural gas.
Of course, for everything the paper gets right in its piece today, it somehow forgets to mention in its nearly 1,800-word piece that injection wells aren’t just regulated ODNR – they’re regulated federally by EPA as well. As we wrote last week in our rebuttal to the Dispatch series, injection wells have been used in the United States since the 1930s – not just by oil and natural gas producers, but by manufacturers, mining folks, chemical companies, and just about every other industrial entity you can imagine.
But no one in Ohio has really heard of injection wells ‘til now, have they? And there’s a pretty good reason for that. According to ODNR: “We have not had any subsurface contamination of groundwater since we took over the program in 1983.” According to EPA, there are more than 144,000 wastewater injection wells in operation today in the United States – with those wells capturing and permanently storing more than two billion barrels of brine each and every day.
Compare that to Ohio: 181 wells, 168 million gallons over a four year span. Not exactly the “flood of wastewater” described by the Dispatch last week, is it? Heck, we’re barely even a rounding error.
Of course, what may be a “rounding error” from a national perspective is much more significant than for more than a few Ohio residents directly benefiting from the work. You see, not only are benefits accruing to Roger Root, but local Ohio businesses are also taking advantage – especially the ones who haul that water around.
The Beacon Journal mentions one such person: Ray Pander of Palmyra Township. According to his website, Ray hauls water at $74 an hour – and collects an additional $1 for every gallon of brine he disposes of. Currently, Ray’s trucking company employs 30 people and features a fleet of 22 trucks. But with the Utica Shale coming online, no one should be surprised when ol’ Ray hangs the “Help Wanted” outside his office in Newton Falls.