Wastewater Disposal Wells Under Scrutiny Following Irvin Leak
3 January 2012
By Don Hopey
The U.S. Environmental Protection Agency has fined Exco Resources
$159,624 for a leaking underground pipe at its Irvin drilling
wastewater disposal well in a remote, forested area of Clearfield
County that the company failed to report for four months.
That structural failure of the Exco well, one of six oil and gas
drilling wastewater disposal wells operating in Pennsylvania, has
raised worries about the operation and regulation of the others
and also about drilling company interest in siting about two dozen
additional deep disposal wells throughout the state.
One of those proposed disposal wells could be built just 900 feet
from the home drinking water well of Marianne and Rick Atkinson,
who live about two miles outside DuBois in Clearfield County.
Windfall Oil & Gas, headquartered in Reynoldsville, Jefferson
County, sent a required notice to the Atkinsons and other local
residents in November but has not yet submitted an application to
"The Exco injection well is in Bell Township, a sparsely populated
area 17 miles away from us, but here we live in a rural but more
populated area with 20 homes within a quarter mile and many more
just outside that," Ms. Atkinson said. "If a [disposal] well goes
bad in our neighborhood, then none of us will have any well
The problems at the Exco well in Bell Township began in April,
when the company first noticed a breach or "failed mechanical
integrity" in one of the piping, casing and cement layers of the
7,000-foot-deep disposal well, according to Roger Reinhart,
compliance and enforcement team leader for the Underground
Injection Program in the EPA's Philadelphia regional office.
Dallas-based Exco didn't report the problem to an EPA field
inspector until August and continued to accept tanker truckloads
of brine and wastewater from its own Marcellus Shale gas well
drilling operations until then. Also, for three months in 2010 the
company operated the well at an injection pressure higher than its
2005 EPA permit allowed.
The well has been shut down since August. Under terms of the EPA
consent agreement and final order it signed, the company is
required to repair the well and conduct and pass mechanical
integrity tests with an EPA field inspector present before it can
begin to accept wastewater again. Exco officials could not be
reached for comment.
Wastewater disposal wells typically pump drilling wastewater
thousands of feet underground into porous sandstone and limestone
formations. They are required by the federal Safe Drinking Water
Act to have those multiple pipe, casing and cement barriers to
reduce the risk that drilling wastewater, also known as "produced
water," will contaminate groundwater used for private and public
water supplies that is typically located just several hundred feet
below the surface.
Exco's structural problem at the Irvin well isn't unusual. Other
wastewater injection wells have had mechanical issues involving
piping, EPA officials said.
"This is the only one that continued to operate after it knew it
had a problem, but there have been other mechanical integrity
failures at other disposal wells in Pennsylvania," Mr. Reinhart
said, noting that fines for those well failures have been in the
"same neighborhood" as the one proposed for Exco.
"Parts break down. That's why we have redundancy protections built
into the wells. In this situation the company was aware it erred
and was delinquent in its training of workers and has corrected
Although the EPA said it has not found any shallow groundwater
contamination around Exco's failed Irvin well, Ms. Atkinson noted
that the company was not required by its EPA permit to drill, and
did not drill, any groundwater monitoring wells.
Jenny Lisak, a co-director of the Pennsylvania Alliance for Clean
Water and Air, a local grassroots environmental organization,
lives about three miles form the Irvin disposal well and began
testing springs and seeps around the site last summer after
neighbors noticed as many as 50 tanker trucks a day emptying their
Ms. Lisak, who has experience doing water tests for the Senior
Environmental Corps, said the sampling found levels of total
dissolved solids, or TDS, above 2,000 milligrams per liter in
forest springs that she would expect to register 30 to 60
milligrams per liter. The EPA secondary water quality standard for
drinking water for TDS is 500 milligrams per liter.
"I could tell there was something not right, and the tests show
there was something very wrong," Ms. Lisak said. "I'm concerned
because the springs are in a forested area that's open to the
public and one even has pipe where people can pull over in their
cars and stop to fill up water jugs. A sign needs to be posted to
inform people it's not fit to drink."
Despite the high TDS levels, the test results have not been
definitively linked to the problems at the Exco well. EPA
officials said last week they were unaware of those test results.
The EPA said the only documented case of a disposal well causing
groundwater contamination in Pennsylvania occurred in the early
1990s near Custer City, south of Bradford in McKean County, where
"petroleum products" showed up in private residential water wells
down-gradient from the disposal well. It was later determined that
the contamination had traveled up the disposal well casing from an
unmapped, unplugged and long-abandoned oil well that had been
drilled in the 1890s and was invisible on the surface. Owners of
the affected private water wells were eventually hooked up to a
public water system.
The briny drilling wastewater, long a disposal requirement for
conventional shallow oil and gas wells, is an issue too for the
rapidly growing Marcellus Shale gas drilling industry. That
growing industry has put more than 1,600 shale gas wells into
production in the state.
Each Marcellus well drilled a mile or more deep and then
horizontally through the shale layer uses approximately 4 million
gallons of water mixed with chemicals and sand to hydraulically
fracture or "frack" the rock. A million gallons of that mixture --
sometimes more, sometimes less -- returns to the surface carrying
a variety of dissolved salts, metals, organic chemicals and other
impurities, sometimes in concentrations that may present a threat
to human health, aquatic life and water quality.
In the last several months drilling companies have had
pre-application discussions with the EPA about 20 to 25 new
But demand for new disposal wells has built slowly during the
early stages of the Marcellus Shale drilling boom, in large part
due to the availability of commercial disposal wells in Ohio and
West Virginia, and other, less expensive disposal routes in
Pennsylvania -- most notably a route through public sewage
treatment facilities into surface waters. Public water treatment
plants were asked to voluntarily stop accepting drilling
wastewater in April because of the difficulties it poses for
traditional treatment methods, and the industry has largely
Karen Johnson, EPA's regional Underground Injection Control
Program manager and chief of its Ground Water and Enforcement
branch, said she expects demand to continue to expand because of
the loss of the surface water disposal alternatives and as the
industry in the state grows. She said the industry's efforts to
reuse and recycle drilling wastewater will dampen but not
eliminate the need for disposal wells in the state.
"We've had lots of interest in new disposal wells and the
[industry's] water treatment systems will still have waste," Ms.
Johnson said. "But the expected increase in recycling should
reduce the number of wells the industry requires."
Travis Windle, a spokesman for the Marcellus Shale Coalition, an
advocacy organization with more than 250 member companies involved
in Marcellus Shale gas drilling, said the coalition has focused
its efforts on recycling wastewater.
"There's been a fundamental sea change over the past 18 months
toward recycling," he said, "and as the technology advances, we'll
withdraw less water and reduce our discharges of waste and
produced water and rely less and less on the deep injection
But despite that long-term goal, there's still a demand for deep
disposal wells and a public distrust of anything that risks
contamination of freshwater aquifers.
In June, the EPA issued new Class II permits to Bear Lakes
Properties for two commercial disposal wells in Warren County that
would be able to accept wastewater from any oil or gas drilling
operation. Operation of those wells has been delayed by a pending
appeal to the federal Environmental Appeals Board by township
supervisors and two township residents questioning the EPA's
permit review process and the risk of earthquakes posed by
drilling the wells.
Nationally, according to the EPA, there are approximately 144,000
Class II wells with the vast majority used for fluid injection to
stimulate production of nearby oil and natural gas wells. About 20
percent or 30,000 of the Class II wells are used for disposal of
more than 2 billion gallons of brine and wastewater a day produced
by oil and gas drilling operations.
Most are in Texas -- which has more than 10,000 disposal wells --
California, Oklahoma, and Kansas. West Virginia has 65 deep
disposal wells. Virginia has about a dozen, according to EPA
Pennsylvania's disposal wells range in depths from 2,000 to 8,000
feet and can operate for decades. Three of the six disposal wells
in the state -- the Columbia Gas Co. well in Beaver County; the
Range Resources commercial well in Erie County; and the Cottonwood
well in Somerset County -- were first permitted in 1985 when the
EPA began the program.
Amy Mall of the Natural Resources Defense Council said the
non-profit national environmental advocacy group has petitioned
the EPA to strengthen the federal oil and gas disposal well
regulations, which haven't been updated since 1988, and classify
brine and drilling wastewater as non-hazardous material subject to
lesser disposal regulations.
"Waste from gas drilling is increasing day by day and as we look
at more data we know that some of it is quite toxic," Ms. Mall
"Hazardous waste disposal wells are much more tightly regulated,
and drilling waste should be subject to hazardous waste rules. If
it meets certain criteria it should be treated as such."
Don Hopey: email@example.com or 412-263-1983.