A preliminary report released by the Ohio Department of Natural Resources (ODNR) on Friday concludes that a dozen earthquakes in northeastern Ohio were “almost certainly” induced by injection of gas-drilling wastewater (a full copy of the report is embedded below). The evidence is overwhelming: The earthquakes did not begin until three months after the injection well went online; the quakes were all clustered around the well bore; and a new fault has been discovered in the bedrock where the wastewater was being injected. Taken together, the ODNR is as sure as it can get that the injection well was causing the earthquakes.
Therefore, the ODNR has issued new regulations for injection wells, what state officials are calling among the toughest rules in the nation. From the ODNR press release:
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.
ODNR also released a preliminary report on the relationship between the Northstar 1 Class II disposal well and 12 Youngstown area earthquakes.
Geologists believe induced seismic activity is extremely rare, but it can occur with the confluence of a series of specific circumstances. After investigating all available geological formation and well activity data, ODNR regulators and geologists found a number of co-occurring circumstances strongly indicating the Youngstown area earthquakes were induced. Specifically, evidence gathered by state officials suggests fluid from the Northstar 1 disposal well intersected an unmapped fault in a near-failure state of stress causing movement along that fault.
All of the conditions associated with induced seismic activity are addressed in Ohio’s new well permitting and construction regulations.
According to the U.S. EPA, more than 144,000 Class II disposal wells inject 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. Prior to Class II disposal wells in Ohio, brine was stored in surface pits with harmful environmental results.*
*Ohio Department of Environmental Resources (Mar 9, 2012) – Ohio’s New Rules for Brine Disposal Among Nation’s Toughest