Class I injection wells are
utilized to store industrial and municipal waste. There are not many Class I
injection wells, about ten in Ohio. Deep Rock Disposal Solutions is drilling
such a well at its facilities in Washington County, Ohio, near Marietta. The
plan is to inject landfill leachate into the Rose Run Sandstone reservoir at
around 8000ft in depth. The sandstone is a saline reservoir in this area,
although it does produce significant quantities of oil & gas further west,
where it subcrops at the Knox Unconformity in what are essentially buried
outcrops or buried hills.
ALL Consulting, which is
managing the project, describes the well as a ‘non-hazardous Class I injection
well.’ Below, ALL Consulting’s Dan Arthur, an expert on well plugging, a former
EPA scientist, and educator, gave details of the project:
“ALL Consulting is currently managing a rather
significant project that involves overseeing the permitting, drilling,
completion, and testing of a Class I Non-Hazardous injection well in Ohio on a
Design/Build (D/B) basis. This project will facilitate injection of landfill
leachate to depths approximately 8,000 feet below land surface (into the Rose
Run Sandstone) and eliminate the need for thousands of truck trips to haul the
landfill leachate to the local public water treatment system for disposal. Regulatory
requirements for Class I injection wells in Ohio are even more stringent than
the U.S. EPA requirements for Class I wells, including performing 10 miles of
seismic surveys to identify any faulting that could lead to induced seismicity,
stringent casing and cementing well construction requirements, numerous
geophysical logging suites and testing requirements to ensure compliance with
all Ohio EPA Class I regulations. Class I injection continues to be the sound
and environmentally friendly methodology approved by U.S. EPA to remove waste
water streams from being discharged into the surface waters of a state.”
The U.S. Environmental
Protection Agency notes that about 53% of Class I wells are non-hazardous
industrial waste and 17% hazardous waste. The other 30% injects non-hazardous
municipal waste, although all, or nearly all of these are in Florida.
As Dan Arthur noted, Ohio,
which has been granted primacy for Class I injection wells, has rules and
requirements that exceed those of the U.S. EPA. One rule for Non-Hazardous
Class I wells is the required geological studies as indicated below:
Geologic studies of the injection and confining zones to
determine that:
• The receiving formations are sufficiently permeable,
porous, homogeneous and thick enough to receive the fluids at the proposed
injection rate without requiring excessive pressure.
• Formations are large enough to prevent pressure buildup
and injected fluid would not reach aquifer recharge areas.
• There is a low-permeability confining zone to prevent
vertical migration of injection fluids.
• Injected fluids are compatible with well materials and
with rock and fluid in injection zone.
• The area is geologically stable.
• The injection zone has no economic value.
The construction requirements
for Non-Hazardous Class I injection wells are as follows:
• Approved engineering schematics and subsurface
construction details.
• At least two layers of concentric casing and cement.
• Outer (or surface) casing cemented to the surface.
• Tubing and packer design based on:
o Well depth
o Characteristics of the injected fluid
o Injection and annular pressure
o Injection rate
o Temperature and volume of injected fluid
o Size of well casing
o Cementing requirements
• Tests during drilling to ensure no vertical migration of
fluid.
In addition, there are the
following operation requirements:
• Maintain injection at pressures that will not initiate
new fractures or propagate existing fractures.
• Approved fluids and permitted pressures must be
maintained in the annular space.
• Continuous monitoring and recording devices.
The project plans to inject
up to 6000 barrels, or 252,000 gallons of waste per day into the well. If the
well accepted that much waste every single day of the year, it would equal about
92 million gallons per year. However, that level of injection is not likely to
happen. Injection pressures exceeding 13,000 psi are expected. That means that
there would be some concern about induced seismicity, although there are no
mapped basement faults in the area of concern for slipping. Nonetheless, with
pressures and volumes that high, there will still be some concern.
Environmental groups have
expressed concern about contaminating drinking water aquifers, but that is not
a realistic concern, except in the case of accidental spills. There has been
some documented migration of injection water in the general area from Class II
oil & gas wastewater injection wells. However, these wells injected
wastewater into the much shallower Devonian Shale formation nearly a mile above
the Rose Run Sandstone. The Devonian Shale exhibits fracture porosity, which
may allow injected fluids to migrate much farther laterally through the
formation, through the fractures. Wastewater is thought to have migrated a few
miles, affecting producing gas wells in the Devonian Shale in the area. No
water migrated anywhere near drinking water aquifers, being a few thousand feet
below and separated by ample confining layers. Basically, the only legitimate
concern for drinking water aquifers is through accidental spills. There is the
same risk for spills now with trucking the waste to water treatment facilities.
Keeping that waste out of the treatment plants makes it easier for them to
treat existing water to adequate standards.
Deep Rock Disposal Solutions has selected a 2-mile area of review (AoR), exceeding the requirement of a ¼ mile AoR.
The company will utilize existing seismometer network stations around its nearby Class II injection wells to monitor any seismic activity.
The Ohio
EPA held a 2-hour meeting in Marietta in September for the public, where many
questions were asked.
References:
Ohio
EPA to host public meeting about company’s proposal to drill class 1 injection
well. YouTube. WTAP Parkersburg, WV. Bing
Videos
Class
I Non-Hazardous Injection Well in Ohio. Dan Arthur. ALL Consulting. December
12, 2025. Class I
Non-Hazardous Injection Well in Ohio - ALL Consulting
Requirements
for Class I Injection: Wells and Class I Hazardous Waste Wells. Ohio EPA. uic-class1-requirements.pdf
Class
I Industrial and Municipal Waste Disposal Wells. U.S. EPA. Class
I Industrial and Municipal Waste Disposal Wells | US EPA
Injection
Wells. Erin O’Neil. Marietta Times. July 29, 2025. Injection
Wells | News, Sports, Jobs - Marietta Times
Washington
County Fights Back Against Proposed Class I Injection Well. Vanlyn Ramsay. Buckeye
Environmental Network. September 11, 2025. Washington
County Fights Back Against Proposed Class I Injection Well (9/9/25) - Buckeye
Environmental Network



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