Wastewater Disposal Wells Under Scrutiny Following Irvin Leak

Pittsburgh Post-Gazette
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 EPA.

"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 water."

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 the problem."

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 contents there.

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 disposal wells.

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 complied.

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 wells."

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 records.

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 said.

"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: dhopey@post-gazette.com or 412-263-1983.