Injected Water Migration from Wastewater Injection Wells to Nearby Gas Producing Wells in Southeastern Ohio and the Possibilities of Fresh Water Contamination

     This particular subject is relevant to me for a number of reasons. First, I am a geologist who has worked with the subsurface formations of southeastern Ohio for a number of years, decades in fact. Second, my work has been in the oil & gas industry. Third, I am currently seeking employment at either the ODNR or the Ohio EPA where I could possibly be involved in injection well investigations. If so, I would not write about anything here about what I may be involved with at that time. Fourth, I actually know some of the people who strongly oppose these injection wells and even one I reference here. Fifth, I live within 10-15 miles of these injection wells, and my water comes from wells even closer to them. I received a letter several years ago from my local water company that expressed concern about the wells, stating that they did not test for some of the things that could possibly come from injection wells. I was not concerned at the time from what I know about injection wells and the local geology. However, I do now believe concern should be predicated on the volume of water being injected daily, the allowable injection pressures, the number of wells in an area, which reservoirs are receiving water, and the history of issues of concern that have occurred regarding these wells and other injection wells in the region. There is quite a lot of water being injected at significant pressures, and some of it is shallower, and thus closer to aquifers. Much of the water comes from the Utica Shale in Ohio and the Marcellus Shale in Pennsylvania. The Appalachian Basin Marcellus and Utica Shale operations have the highest frack water recycling rates in the country, 93% in Pennsylvania in 2021, but there is now more water being injected per frac stage and per well than before and thus more water returning to surface per well during flowback than in previous years.  

     Batelle led a study around 2015-2016 and possibly beyond that sought to develop a framework for brine disposal wells in the Appalachian Basin oil and gas region. I was able to hear one of the presentations at a summer 2015 Onshore Technology Conference in Pittsburgh presented by the Research Partnership to Secure Energy for America (RPSEA). The study noted that injection pressures drive fluid migration. They acknowledged: “The geologic and reservoir parameters of injection zones poorly understood - planned assessment is required to meet long-term demand.” The study generalized that injected water was usually confined to areas about 3000ft from the wellbore. Apparently, that generalization does not hold in the case of the Athens County/Rome Township wells where injected water was found to migrate 1-1.5 miles, presumably 5280-7820ft or more from the wellbore, significantly more than twice the distance suggested in the study and in another situation where injected water is thought to have moved laterally as much as five miles. I believe the migration study utilized mostly the Clinton/Medina Formation, which consists of tight, low-porosity sandstones, and the so-called “Ohio” Newburg or Lockport Dolomite Formation which consists of low-medium porosity dolomite formed from the recrystallization of limestone which takes up less space than the original limestone. However, the Athens/Rome wells inject into the Devonian Ohio Shale formation where the space in the rock consists of fractures made by a regional jointing system. In most of the reservoirs, nearby wells that were hydraulically fractured may have enhanced the fracture porosity in the rocks. The Ohio Shale is also shallower and thus, closer to the freshwater aquifers up hole. Of course, this does not mean freshwater aquifers are at risk of being contaminated by injected water. The migration occurs in the same formation and moves more or less laterally along the geological structure which is nearly flat. However, nearby wells producing gas from the Devonian Ohio shale are bringing up water from the injection wells along with the gas. This is a problem. These Class II injection wells are designed to sequester produced water from other wells. The fact that injected water is being produced from nearby wells makes it necessary that either the injection wells be shut in or the producing gas wells be shut in and of course, it would be unfair to the gas producers to shut in their wells as the injection wells are causing them economic harm. According to Dani Kington’s Sept. 13 article in Athens County Independent:

 

“On May 1, ODNR Division of Oil and Gas Resources Management ordered the suspension of a Class II injection well in Rome Township on grounds that its operator, Reliable Enterprises LLC, violated an Ohio Administrative Code section that bars operators from contaminating or polluting surface land and surface or subsurface water. In late June, three wells in Torch operated by K&H Partners were suspended on the same grounds.”

 

“Applications for new Class II injection wells from both Reliable Enterprises and K&H were denied because of the suspensions. K&H’s application for a fourth well at its $43 million facility in Torch generated controversy when it was proposed in 2018.”

 

ODNR noted in one of the denied applications: “an Ohio shale injection zone poses a substantial risk” for migration. The ODNR order stated that these wells “endanger and are likely to endanger public health, safety, or the environment.” The danger is that the nearby producing wells would continue to produce water at higher pressures that would need to be managed and that need to manage it would increase the likelihood of spills. I don’t think the danger is high for spills but clearly, it is an untenable situation and the ODNR made the right decision to suspend the wells. The order calls for the suspension to continue until the conditions that caused the suspension are fixed. In August an ODNR administrator noted that “ODNR has received no evidence or reports that any groundwater, surface water, or water wells have been impacted.”

     K&H argued that there was no evidence that the water production in the nearby gas wells was from their wells and not naturally occurring. However, from my experience water testing could probably reasonably determine that from analysis of the chlorides and other components of the produced water. “The Chief's Preliminary Order explained that an increase of brine at the nearby shut-in production wells cannot be plausibly explained as naturally originating and, based on the Division's investigation, the brine is migrating from the K&H Wells. The Chief's Preliminary Order also explained why K&H's evidence of non-migration was flawed. For example, even if the 2020 report prepared by K&H's consultant ALL Consulting supports K&H’s argument that the brine is not migrating radially (pooling around the injection sites), the report is nonetheless consistent with the more likely scenario that brine is migrating through fractures or conduits. It does not undermine the Division's findings.” Environmentalists continue to state that there may be freshwater aquifer contamination for local water well owners but aside from spills, there is not a readily available geological or physical mechanism for water to climb through the stratigraphic section since there are many impermeable sealing formations between producing/injecting formations and freshwater aquifers. Thus, their argument that water can migrate “outside of the permitted injection zone” is highly unlikely under most circumstances. They don’t seem to understand and should understand that fluids migrating laterally within a permeable reservoir is not the same as fluids migrating vertically through different rock formations with differing grain sizes, porosities, and permeabilities. However, there is a possibility that undocumented abandoned, idle, or orphaned wells in the area could take on migrating water and leak or spill water into aquifers or even to the surface. Thus, there is indeed some potential risk. There is a more remote possibility that a conducting fault could move fluids up stratigraphy, but these are not found in the area in general. ODNR adopted a precautionary approach based on the evidence at hand and the potential for permanent aquifer damage in the event of injected water somehow entering an aquifer: “Accordingly, when an injection well is showing signs of migration, the Chief cannot and does not wait for evidence that the migration has actually impacted an aquifer before issuing an order suspending operation. If he did so, it would be too late.” Below is a map showing the positions of the injection wells and the nearby producing wells.

 

 

 

     In January 2023, two injection wells in nearby Noble County injecting into the deeper Clinton and Medina formations at about 6000ft below the surface were suspended due to migration into other Clinton/Medina wells as far as five miles away that were being plugged or worked over. The distance of the migration is quite surprising – up to 10 times that of the Battelle study but still confined to the Clinton/Medina, which is a fluvial-deltaic depositional environment in this area with compartmentalized reservoirs thought to be common. As the producing wells were extensively hydraulically fractured there may be new induced fracture patterns combined with the geology that led to the long distance and very linear migration pattern. The map below shows the linear pattern of the injected water migration. Pressures and volumes in those wells were much higher than regional water pressures and volumes. Thus, it is quite likely that the injection wells are responsible for those higher pressures and volumes. Just as in the Ohio Shale wells, the owners of the producing wells have a legitimate complaint that they are being harmed economically by the water encroachment reducing their gas production and increasing their water handling costs. They should not have to pay to re-inject the water. Clearly, there is too much water being injected at too high pressures if indeed it is the case that injection, as thought, that injection pressures drive fluid migration.

 

 Source: Ohio Department of Natural Resources

 

     I have actually prospected some Ohio Shale wells in the immediate area of Athens County for gas production. Gas production there is quite spotty and naturally fractured areas with good production are not easy to delineate. There are dry holes as well as isolated good to very good gas wells. Pressure in the Ohio shale is quite low, so it is considered under-pressured compared to deeper reservoirs, which aids its ability to take in injected water. However, as the overall fracture porosity and permeability in the area is spotty and unpredictable it stands to reason that the overall volume available for water injection is also spotty and unpredictable.  

 

 

State Primacy is Not the Main Reason Ohio Has More Injection Wells

 

     Environmental activists have long been calling for the US EPA to take over regulation of wastewater injection wells from the Ohio Department of Natural Resources, which was given primacy by the US EPA, with its rules considered to be equal to or more stringent than the EPA’s rules. State primacy is common in many regulatory areas and is not considered less effective at all. In fact, it is often better. It is also more efficient and known for faster regulatory decisions as state agencies are better staffed, more local, and more knowledgeable of the conditions particular to that state. State primacy does, however, lead to faster permit approval times. The U.S. EPA can take years to approve injection wells. Activists have long favored delay. Delay is often the goal when banning is not an option. West Virginia has state primacy and does have more injection wells than Pennsylvania but far less than Ohio. The desire among environmental activists to revoke the ODNR’s primacy is not shared by the US EPA to my knowledge. An article in Energy News Network pointed out the views of a coalition of environmental activists and community groups: “Ohio’s Class II well program contains numerous technical deficiencies that have allowed for underregulated oil and gas waste disposal which has resulted in serious consequences to human health and the environment,” attorneys from EarthJustice, the Sierra Club of Ohio, and various community groups say in their petition to the EPA asking them to begin the rulemaking process to revoke Ohio’s primacy over its Class II program “due to the longstanding and systemic failures.” I do not think this is true. Their argument includes the fact that Ohio takes most of the injected water from Pennsylvania and West Virginia as well as Ohio. This is not due to primacy as often suggested but due to the favorability of Ohio geology compared to West Virginia and Pennsylvania geology. Ohio has an abundance of under-pressured reservoirs and saline reservoirs that will take in injected water. While spills can and do happen at abandoned wells and while injected water can migrate and come to the surface through nearby producing wells, there is no evidence that any freshwater or surface water has been contaminated by injected wastewater or that any contamination is imminent or likely.

 

 

Activists and Their Scientist Allies Want to Do Citizen Science to Find a Smoking Gun That They are Not Likely to Find

 

     Organized activists have long been opposing wastewater injection wells in Southeast Ohio. Induced seismicity used to be a major concern but a better understanding of what leads to it, how to prevent it, and a better state seismograph network have resulted in few additional induced seismicity events since the early 2010s as I predicted in a blogpost in 2015. Another issue touted by activists is radioactivity. The Marcellus Shale is more radioactive than the Utica. Typically, the radioactivity levels are not considered threatening as long as it is not entering surface or groundwater. There is, however, some concern with the use of this saltwater as a road treatment to melt snow. It should end up quite diluted by rainwater, snow, etc., but activists elevate it as a big concern. Theoretically, it could increase the radioactivity, salt, or chemical content of local water where it is not sufficiently diluted and water testing could detect elevated levels of contaminants, though likely below allowable limits. Thus, it may not be the best water to use for snow melt.

     The activist groups along with their volunteer Ph.D. soil scientist/geologist Julie Weatherington-Rice, who works in environmental consulting, advocate for citizen science to look for a “smoking gun” of surface water or groundwater contamination. Wastewater as road salt is not likely to yield enough contamination. They believe that subsurface contamination is there to find but there is no real mechanism for it aside from spills and leaking wells. Thus, spill prevention and monitoring of wells is important. All existing wells near injection wells should be monitored for water encroachment. Ideally, there would be less water being injected in a given area so new injection well permits adjacent to areas already injecting millions of barrels of water should be scrutinized heavily. The permeable space in these reservoirs in a given area is considerable but not infinite. There are plenty of areas in the state where injection wells could be constructed or converted and having them spaced out could make injected volumes in a given area less of a problem. Public opposition to such wells may be one reason why this is not happening.  According to the ODNR 34 million barrels of wastewater were injected into Ohio wells in 2022, 22 million barrels (65%) from Ohio wells, and 12 million barrels, (35%) from out-of-state wells (WV and PA).   

     Weatherington-Rice emphasizes subsurface uncertainty in arguing that injected water can move upward through geology toward aquifers. Higher volumes and higher pressures can certainly make water move and there is plenty of evidence that it moves laterally and no evidence that it moves vertically. Open conducting faults are very rare to non-existent in the area due to existing tectonic stresses, but joint systems do occur that provide space for fluids to move in certain reservoirs. She also said: “the state is “owned by oil and gas” and that its chances will depend on whether citizen scientists can find a smoking gun.” I do not think that is true about the state and I doubt a smoking gun will be found, aside from spills or possibly a leaking well. The activists concede that they are limited by the cost of water testing in their quest to find their smoking gun. In late 2015 and early 2016 Ohio University and Athens County paid for water well testing within a 2-mile radius of the Rome Township injection wells. No contamination was found, just a trace of naturally occurring methane. I am reasonably confident that will continue to be the case if and when future tests are done, again, with the possible exception of a spill or leaking well. Ideally, the company operating the injection wells should periodically pay for nearby water well testing as well as compensate nearby gas producers for water encroachment issues.

 

References:

Ohio Injection Wells Suspended Over ‘Imminent Danger’ to Drinking Water. Dani Kington. Athens Independent. Inside Climate News. September 13, 2023. Ohio Injection Wells Suspended Over ‘Imminent Danger’ to Drinking Water - Inside Climate News

Ohio Injection Wells Suspended Over ‘Imminent Danger’ to Drinking Water. Dani Kington. Dani Kington. Athens Independent. September 7, 2023. Local injection wells suspended over 'imminent danger' to drinking water – Athens County Independent (athensindependent.com)

Alleging continual pollution, advocates ask U.S. EPA to take over Ohio injection well permitting. David DeWitt / Ohio Capital Journal. Energy News Network. October 20, 2022. Alleging continual pollution, advocates ask U.S. EPA to take over Ohio injection well permitting | Energy News Network

Ohio Environmentalists, Oil Companies Battle State Over Dumping of Fracking Wastewater. John Hurdle. Inside Climate News. May 14, 2023. Ohio Environmentalists, Oil Companies Battle State Over Dumping of Fracking Wastewater - Inside Climate News

ODNR Issues Permit for K&H 3 Injection Well Without Considering Concerns. A Story of Lies and Willful Ignorance. April 7, 2015. Bernhard Debatin. Slow Down Fracking & Injection Wells in Athens County (Blog). Slow Down Fracking & Injection Wells in Athens County | Providing Information and a Forum for Discussion on Fracking and Injection Wells (wordpress.com)

Development of Subsurface Brine Disposal Framework in the Northern Appalachian Basin. Joel R. Sminchak & Dr. Naraj Gupta. PIOGA Presentation Slides. July 29, 2015. Development of Subsurface Brine Disposal Framework · PDF fileDevelopment of Subsurface Brine Disposal Framework in the Northern ... • We did work with operators to monitor wellhead - [PDF Document] (vdocuments.mx)

Regional modeling of class II wastewater injection wells, Appalachian Basin. Tom Sparks. Kentucky Geological Survey Annual Seminar. May 13, 2016. Kentucky Well Sample and Core Library. annualSeminar2016_Sparks.pptx (live.com)

The Current Local Controversy Over Waste-Water Injection Wells in Southeastern Ohio and the Unlikelihood of Further Induced Seismicity in the State. Kent C. Stewart. Blue Dragon Energy Blog. August 27, 2015. Blue Dragon Energy Blog: The Current Local Controversy Over Waste Water Injection Wells in Southeastern Ohio and the Unlikelihood of Further Induced Seismicity in the State

2023-02 Deeprock Disposal Solutions LLC 9896 Suspension of Injection Operations_1067446. Ohio Department od Natural Resources. January 9, 2023.  2023-02 Deeprock Disposal Solutions LLC 9896 Suspension of Injection Operations_1067446 - DocumentCloud

Ohio's Grassroots Environmentalists: We Told You This Would Happen, and You Didn't Listen. The Buckeye Environmental Network and Ohio Brine Task Force. September 5, 2023.  Press Release on Chief's Orders 8-28-2023.docx (3).pdf - Google Drive

6/30/23 ODNR motion to dismiss. Ohio Department of Natural Resources. 6/30/23 ODNR motion to dismiss - DocumentCloud