Reacting to a study showing earthquakes resulted from an oil and gas injection well, the state of Ohio has adopted strict rules forbidding the injection of oil and gas drilling byproducts deep under ground.
This should be of interest to everyone in Colorado, where the development of more effective drilling techniques has created renewed interest in underground fossil fuel deposits, including the Niobrara formation that underlies part of El Paso County. The county might see rampant drilling by Ultra Resources of Houston, which has obtained mineral leases on thousands of acres and acquired 18,000 acres on the east side of Colorado Springs.
As we reported in January, seismic activity has been linked anecdotally with the use of injection wells to get rid of fracking materials used in oil and gas drilling, but the Ohio study is a watershed finding that could reverberate across the country.
Ohio's Department of Natural Resources reports that the EPA says there are more than 144,000 Class II disposal wells injecting more than two billion gallons of brine every day in the United States. "The U.S. EPA considers the deep injection of brine using Class II disposal wells as the preferred and environmentally safe method for disposal of oilfield fluid wastes," the Ohio agency says on its website.
But when earthquakes started happening in the Youngstown area in 2010, the Ohio Department of Natural Resources delved further, as reported by the agency's website:
In November 2011, newly appointed ODNR Director James Zehringer sought to obtain the additional data. After his first briefing on the seismic activity, Director Zehringer ordered the Ohio Geological Survey to seek an outside research partner and deploy the needed portable seismometers around the Youngstown area. The Lamont-Doherty Earth Observatory at Columbia University had the available equipment and was willing to assist the state. The seismometers were deployed on Dec. 1, 2011.
On Dec. 24, the newly deployed equipment recorded a 2.7-magnitude earthquake in the area. Data from the portable seismometers was downloaded and analyzed by experts at Lamont-Doherty. On Dec. 29, Lamont-Doherty presented ODNR with their preliminary findings, which indicated the seismic event depth was 2,454 ft. below the injection well.
Based on the Lamont-Doherty data, Director Zehringer instructed ODNR regulators to seek the immediate halt of injections at Northstar 1, either voluntarily by the operator or by agency order. At 5 p.m. on Dec. 30, ODNR inspectors witnessed the shut down of the well. (Lamont-Doherty Analysis)
The findings led the state to issue this notice today:
COLUMBUS, OH — Ohio’s oil and gas regulators today announced new environmentally responsible standards for transporting and disposing of brine, a by-product of oil and natural gas hydraulic fracturing. The new regulatory framework makes Ohio’s rules for brine monitoring and disposal among the nation’s toughest. The Ohio Department of Natural Resources (ODNR) developed the new regulations after researching the link between a series of seismic events in the Youngstown area and a brine disposal well.
The new safeguards: prohibit any new wells to be drilled into the Precambrian basement rock formation; mandate operators submit extensive geological data before drilling; and implement state-of-the-art pressure and volume monitoring devices including automatic shut-off switches and electronic data recorders. In addition, ODNR will require that brine haulers install electronic transponders to ensure “cradle to grave” monitoring of all shipments.
“Ohio has developed a new set of regulatory standards that positions the state as a national leader in safe and environmentally responsible brine disposal,” said ODNR Director James Zehringer. “Ohioans demand smart environmental safeguards that protect our environment and promote public health. These new standards accomplish this goal.”
The new safeguards will be added to Ohio’s existing disposal well regulatory framework. The regulations will apply to new Class II disposal well permit applications and to existing disposal wells, if applicable. Ohio regulates Class II disposal wells on behalf of the U.S. EPA. In 1983, the U.S. EPA gave Ohio regulatory authority over its Underground Injection Control program because the state’s disposal well regulations met or exceeded U.S. EPA standards.
The comprehensive list of proposed new regulations includes:
· Requires a review of existing geologic data for known faulted areas within the state and a prohibition on locating new Class II disposal wells within these areas;
· Requires a complete suite of geophysical logs (including, at a minimum, gamma ray, compensated density-neutron, and resistivity logs) to be run on newly drilled Class II disposal wells. A copy of the completed log, with analytical interpretation, will be submitted to ODNR;
· Authority for ODNR to require the plugging with cement of wells penetrating into the Precambrian basement rock and prohibiting injection into the Precambrian basement rock;
· Requires the submission, at time of permit application, of any information available concerning the existence of known geological faults within a specified distance of the proposed well location, and submission of a plan for monitoring any seismic activity that may occur;
· Evaluates the potential for conducting seismic surveys;
· Requires a measurement or calculation of original down hole reservoir pressure prior to initial injection;
· Requires conducting a step-rate injection test to establish formation parting pressure and injection rates;
· Requires the installation of a continuous pressure monitoring system, with results being electronically available to ODNR for review;
· Requires the installation of an automatic shut-off system set to operate if the fluid injection pressure exceeds a maximum level to be set by ODNR; and
· Requires the installation of an electronic data recording system for purposes of tracking all fluids brought by a brine transporter for injection.
All of the reforms will be considered during the permitting process for new Class II disposal wells and will be implemented as attached permit conditions until they are either codified in law or written into administrative rule, which carries the weight of law.
Colorado has more than 800 injection wells, as we reported last month in a story about disposal of hydraulic fracturing waste from oil and gas drilling.
As the then head of the Colorado Oil and Gas Commission, Dave Neslin, told us, the state is monitoring injection wells in light of the seismic activity registered elsewhere and in Colorado in the past. From our story:
The most common way to dispose of waste material is by injecting it 12,000 feet into the ground, Neslin says.
He acknowledges that earthquakes began in 1963 in the Denver area after an injection well was drilled at the nearby Rocky Mountain Arsenal. When injection stopped in 1968, so did the seismic activity, a memo posted on the COGCC's website says.
"This is an issue we're looking at now and coordinating with the Colorado Geological Survey as part of our permitting for underground injection wells," Neslin says. "We want to be sure the new wells being drilled are being sited in areas that will reduce or avoid the risk of any seismic connection."