Underground Injection Issues May 10, 2012
The Saltwater Disposal Institute (SDI) specializes in economical, safe management of oil and gas wastes, primarily waste water via deep-well injection. We publish this blog in order to shed light on regulatory trends, public attitudes, and industry responses.
Disposal Well Protests:
Injection wells, especially those associated with the Shale-Gas play, appear every day in the national news media. Injection wells have lately drawn local protests from citizens fearing environmental impacts. One well in particular is perhaps an indication of the changes in America’s attitudes.
One of Amerex Resources joint venture operating partners received a permit for a commercial Class II disposal well in southern Oklahoma, one of a few states who distinguish commercial and private disposal wells in the oil and gas sector. A private well can only accept waste from the operator’s producing wells while the commercial well can accept waste water from any oil and/or gas well. The proposed well specified in the permit, having received no protests from industry nor public, was not drilled prior to the permit expiration. This operating partner has recently filed for a new permit but this new application has received over 1,300 protests, mostly in the form of petitions initiated by residents.
South-central Oklahoma is heavily involved in the oil and gas industry and contains over 6,000 producing wells that averaged a total 200,000 bbls per of oil per month. The county in which the Commercial Saltwater Disposal well is located is home to over 1,000 injection and disposal wells that must manage approximately 20 Million bbls of salt water every month. 27,000 people reside in the county where oil and gas is the 4th largest employer (although in the past five years that sector’s employment has grown by far the fastest). Oil and gas jobs pay wages more than twice the regional average (OK Commerce Dept, 2012). Despite these facts, many people in the county’s largest town have protested the second application for the disposal well.
The new application was initiated in March, 2012 at the Oklahoma Corporation Commission (OCC) office. Suitable public notice was done and the protest period was over in May, 2012. None of the 11 oil and gas operators in the area of the well objected but a great many private citizens filed protests. A voluntary public meeting hosted in April to air the details of the application and to allow citizens to make themselves heard. Dr. Langhus and Dr. Marian Smith, both with Odin Oil and Gas and consultants to Amerex Resources, were contracted to represent our operating partner in this action. The following issues were brought up by citizens at the meeting:
- The disposal well will damage fresh water resources the same as old water-floods did in the 50’s and 60’s.
- Truck traffic would severely impact the municipality and its residents.
- Tanker-truck accidents could result in salt water spills that would represent significant environmental and human-health threats.
- Noise from the operation would be intolerable to neighbors of the well.
It should be emphasized that none of these complaints concern permitting issues under the jurisdiction of the OCC. The issues of concern are outside the authority of the Underground Injection Control (UIC) Program as it is defined in statutes and regulations, however, they have captured the attention of citizens and have become a great deal more important than technical permit issues and for that reason alone they must be addressed by disposal well applicants.
Historical pollution and impacts to water resources are serious subjects that are on the minds of residents. Anyone associated with older water floods and loss of water resources in the past is anxious to assure that nothing like this happens again. In the case of Oklahoma, many old water-floods caused the loss of water wells. Oklahoma has been the home to many water-flood projects since the ancestor of Exxon-Mobil installed the first in 1931 in Rogers County. Water-floods typically contain several injection wells that return produced water into oil-producing reservoirs. They can have the advantage of increasing oil production but can also have the dis-advantages of leaks in injection wells, producing wells, and surface pipelines. In the past, water-floods have impacted soil and water resources around the state, resulting in expensive remediation efforts by operators.
Marathon Oil Company operated several water-floods in the vicinity in the 50’s, 60’s, and 70’s. The formations being flooded included a number of Pennsylvanian sands including Tussy, Deese, Hart, Pontotoc, Layton, Dewey, Hoxbar, Tuley, Robberson, Skaggs, Newberry, Douglas, Cisco, and others. Injection pressures needed to be up to 2,500 psi to get water into the tight Pennsylvanian sands. Injection at such high pressures puts a strain on injection well casing, production well casing, and pipelines. This resulted in leaks, surface releases, and subsurface releases, some of which were not detected for long periods of time. Long-term leaks led to contamination of aquifers in the area and abandonment of numerous water wells.
Oklahoma’s history with water-floods led to increased scrutiny by state regulators, especially the OCC whose oil and gas authority was established in 1914. The OCC operated for most of its history as a reactionary entity that only took action in response to specific complaints from industry or citizens. Modern environmental regulations in the 1970’s and 80’s prompted the OCC to adopt prohibitions and controls on various activities in the oilfield. Part of those new regulations were aimed at deep-well injection, culminating with the endorsement of the OCC as lead agency for the new Federal Underground Injection Control (UIC Program); new UIC regulations aimed to prevent impacts such as those seen in the old water-floods. Today’s water flood and disposal wells are subject to numerous regulations designed to prevent leaks and impacts to Oklahoma’s surface and groundwater.
Environmental bonds are required of every operator in the state. In addition most operators carry insurance to cover unforeseen impacts.
Truck Traffic is not controlled by the OCC but rather is the jurisdiction of the state, county, or municipality. Nonetheless, it behooves the operator to manage traffic away from residential areas and along well-maintained county roads. The meeting drew many comments about potential truck traffic in the town and in particular through residential neighborhoods and by an elementary school. Drivers of trucks delivering to the Commercial Saltwater Disposal well will, however, be instructed to avoid that route and use a different exit off I-35 and one of two routes that avoid the town.
Salt water toxicity for humans and other animals is very low (NaCl MSDS, Nov 2010) . For humans the self-limiting effect of offensive taste will restrict intake of salt water well before toxic doses are reached. Livestock will drink salt water if fresh water is not available but they are able to tolerate significant amounts of brine. Some varieties of farm animals are able to exist on 1% (10,000 ppm) salt water – this is indeed the basis for the Federal Statutory definition of “Drinking Water” being less than 10,000 ppm total dissolved salts. Hundreds of other organic and inorganic compounds can occasionally be found in produced salt water but their concentration is usually very low.
Citizens at the public meeting were concerned over the possibility of “hazardous wastes” entering the commercial disposal well. These wastes would be any liquids that are not associated with oil and gas production such as routine industrial waste water. The nature and source of these worrisome wastes rests on the regulatory framework surrounding oil and gas waste material. In December 1978, EPA proposed hazardous waste management standards that included reduced requirements for several types of large volume wastes. Generally, EPA believed these large volume “special wastes” are lower in toxicity than other wastes being regulated as hazardous waste. Subsequently, Congress exempted these wastes from the Resource Conservation And Recovery Act (RCRA) Subtitle C hazardous waste regulations pending a study and regulatory determination by EPA (42. U.S.C. § 6901). In 1988, EPA issued a regulatory determination stating that control of E&P wastes under RCRA Subtitle C regulations is not warranted (53 Fed Reg: 25446; July 6, 1988). Since then, E&P wastes have remained exempt from Subtitle C regulations with subsequent modifications and guidances. Federal EPA and state environmental regulatory agencies have remained steadfast in recognizing the fundamental differences between E&P exempt wastes and routine industrial wastes.
Amerex’s operating partner has also proposed that the Commercial Saltwater Disposal well will be staffed 24 hours a day, will have secure, computer-monitored and controlled connection valves, will have no open pits available to rogue waste haulers, will manifest all loads arriving at the plant, and will equip the well with full-time sensors to monitor specific gravity and conductivity in order to intercept any non-exempt liquids from entering the well. Hauling industrial waste in tankers meant for oil and gas waste is against Oklahoma law and a trucker doing so risks losing his livelihood. This operating partner could risk heavy fines and shut-downs for taking ineligible wastes and risks the capability of its well from unknown down-hole reactions that could plug the Arbuckle Injection Zone in the vicinity of the borehole.
Citizens expressed concern over radioactive constituents in the waste water but this has not been an issue in Oklahoma’s oilfields. While almost every substance in nature carries some radioactivity, the vast majority of plants, rocks, fluids, and animal tissue is very low. Some situations are different and are fraught with dangerous levels of radiation – transcontinental airline flight above the shielding effect of the atmosphere carries the risk of high levels of radiation and some ore bodies contain high concentrations of uranium or radium. Oklahoma’s oilfield waters have not been shown to be radioactive above local background levels.
Sound levels surrounding the disposal well will be higher at some times than at others. While the horizontal in-pipe pumps used by our operating partner are much quieter than industry-standard open-air triplex pumps, this operating partner has volunteered to install sound-walls where appropriate to deflect noise from neighboring residences. These walls are common to oil and gas wells built in a suburban environment.
The prudent operator will anticipate substantive objections to SWD operations and calm those fears with industry-standard or innovative solutions. The next installment of this blog will elucidate some of the solutions applied by Amerex Resources to address and alleviate public fears about commercial disposal wells.
About the authors:
Marian M. Smith, Ph.D. is a reservoir geologist with experience in petroleum reservoir and aquifer characterization as well as geological and environmental education. She brings valuable public speaking skills and instructional experience to Odin Oil and Gas and the SDI.
Bruce G. Langhus, Ph.D. is a petroleum geologist with over 45 years’ experience in oil and gas business including water-flood design and operation; Class I, II, and III disposal well location, permitting and operation; and injection well remediation. Dr. Langhus has been the Class II Program Manager in Oklahoma, the second largest UIC program in the country. He was a founding partner of ALL Consulting, a successful geotechnical consultancy in Tulsa, OK. Dr. Langhus is now part of Amerex Resources with prospective disposal well and facility acquisitions in Texas, Oklahoma, Kansas, Montana, and North Dakota.