Filling the Void: A Citizens’ Audit of Ohio Oil and Gas Waste Disposal Wells

Filling the Void: A Citizens’ Audit of Ohio 

Oil and Gas Waste Disposal Wells

Nathan Rutz and Melissa English

Ohio Citizen Action and Ohio Citizen Action Education Fund

December 2014

Waste Water from Oil Fracking Injected into Clean Aquifers | NBC Bay Area

Waste Water from Oil Fracking Injected into Clean Aquifers | NBC Bay Area.

EPA Program to Protect Underground Sources from Injection of Fluids Associated with Oil and Gas Production Needs Improvement


EPA Program to Protect Underground Sources from Injection of Fluids Associated with Oil and Gas Production Needs Improvement

Why GAO Did This Study

Every day in the United States, at least

2 billion gallons of fluids are injected

into over 172,000 wells to enhance oil

and gas production, or to dispose of

fluids brought to the surface during the

extraction of oil and gas resources.

These wells are subject to regulation to

protect drinking water sources under

EPA’s UIC class II program and

approved state class II programs.

Because much of the population relies

on underground sources for drinking

water, these wells have raised

concerns about the safety of the

nation’s drinking water.

GAO was asked to review EPA’s

oversight of the class II program. This

report examines (1) EPA and state

roles, responsibilities, and resources

for the program, (2) safeguards to

protect drinking water, (3) EPA

oversight and enforcement of class II

programs, and (4) the reliability of

program data for reporting. GAO

reviewed federal and state laws and

regulations. GAO interviewed EPA and

state officials and reviewed class II

programs from a nongeneralizable

sample of eight states selected on the

basis of shale oil and gas regions and

the highest number of class II wells.

What GAO Recommends

GAO recommends that, among other

things, EPA review emerging risks

related to class II program safeguards

and ensure that it can effectively

oversee and efficiently enforce class II

programs. EPA agreed with all but the

enforcement recommendation. GAO

continues to believe that EPA should

take actions to ensure it can enforce

state class II regulations, as discussed

in the report.

What GAO Found

The Environmental Protection Agency’s (EPA) role in the Underground Injection

Control (UIC) class II program is to oversee and enforce fluid injection into wells

associated with oil and gas production, known as class II wells. EPA has

approved 39 states to manage their own class II programs, and EPA regions are

responsible for managing the programs in remaining states. EPA regions and

states use a mix of resources to manage class II programs, including EPA grant

funding, state funding, and federal and state personnel. EPA’s UIC grant funding

has remained at about $11 million for at least the past 10 years.

Class II programs from the eight selected states that GAO reviewed have

safeguards, such as construction requirements for injection wells, to protect

against contamination of underground sources of drinking water. Programs in two

states are managed by EPA and rely on EPA safeguards, while the remaining six

programs are state managed and have their own safeguards that EPA deemed

effective at preventing such contamination. Overall, EPA and state program

officials reported that these safeguards are protective, resulting in few known

incidents of contamination. However, the safeguards do not address emerging

underground injection risks, such as seismic activity and overly high pressure in

geologic formations leading to surface outbreaks of fluids. EPA officials said they

manage these risks on a state-by-state basis, and some states have additional

safeguards to address them. EPA has tasked its UIC Technical Workgroup with

reviewing induced seismicity associated with injection wells and possible

safeguards, but it does not plan reviews of other emerging risks, such as high

pressure in formations. Without reviews of these risks, class II programs may not

have the information necessary to fully protect underground drinking water.

EPA is not consistently conducting two key oversight and enforcement activities

for class II programs. First, EPA does not consistently conduct annual on-site

state program evaluations as directed in guidance because, according to some

EPA officials, the agency does not have the resources to do so. The agency has

not, however, evaluated its guidance, which dates from the 1980s, to determine

which activities are essential for effective oversight. Without such an evaluation,

EPA does not know what oversight activities are most effective or necessary.

Second, to enforce state class II requirements, under current agency regulations,

EPA must approve and incorporate state program requirements and any

changes to them into federal regulations through a rulemaking. EPA has not

incorporated all such requirements and changes into federal regulations and, as

a result, may not be able to enforce all state program requirements. Some EPA

officials said that incorporating changes into federal regulations through the

rulemaking process is burdensome and time-consuming. EPA has not, however,

evaluated alternatives for a more efficient process to approve and incorporate

state program requirements and changes into regulations. Without incorporating

these requirements and changes into federal regulations, EPA cannot enforce

them if a state does not take action or requests EPA’s assistance to take action.

EPA collects a large amount of data on each class II program, but the data are

not reliable (i.e., complete or comparable) to report at a national level. EPA is

working on a national database that will allow it to report UIC results at a national

level, but the database will not be fully implemented for at least 2 to 3 years.

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The Trillion-Gallon Loophole: Lax Rules for Drillers that Inject Pollutants Into the Earth – ProPublica

The Trillion-Gallon Loophole: Lax Rules for Drillers that Inject Pollutants Into the Earth – ProPublica.

Injection Wells: The Poison Beneath Us – ProPublica

Injection Wells: The Poison Beneath Us – ProPublica.

Poisoning the Well: How the Feds Let Industry Pollute the Nation’s Underground Water Supply – ProPublica

Poisoning the Well: How the Feds Let Industry Pollute the Nation’s Underground Water Supply – ProPublica.

PA DEP Oil & Gas Reporting Website – Statewide Data Downloads By Reporting Period

PA DEP Oil & Gas Reporting Website – Statewide Data Downloads By Reporting Period.

This database shows that much PA unconventional drilling waste is coming to NY for disposal

Spreadsheet showing waste transported to NY from PA Chesapeake wells from Jan to June, 2012.  Most is drill cuttings deposited in Painted Post and Niagara Falls landfills.

NYwaste repositories.1-6of2012.Chesapeake

The Trillion-Gallon Loophole: Lax Rules for Drillers that Inject Pollutants Into the Earth – ProPublica

The Trillion-Gallon Loophole: Lax Rules for Drillers that Inject Pollutants Into the Earth – ProPublica.

Meeting Minard

Meeting Minard.

The Minard Run Oil Company, based in Bradford, Pennsylvania, claims to be the oldest family-owned and -operated independent oil producer in the United States. Founded in 1875 by Pennsylvania Senator Lewis Emery, Jr., the company today is run by four of his great-grandchildren and one of his great-great-grandchildren.

In mid-March, Minard purchased 415 natural gas wells in the Finger Lakes from Chesapeake Energy, the nation’s second-largest producer of natural gas—at least for now. Chesapeake, formed in 1989, enjoys none of Minard’s stability: The company has been beleaguered by criticism of its corporate governance, the shenanigans of CEO Aubrey MacLendon (thoroughly documented by Jeff Goodell in Rolling Stone), and a business plan that has left it severely short of cash—perhaps $10 billion short this year alone. The company’s stock price has fallen 50 percent in the last year. How bad is the company’s management? This week, New York State Comptroller Thomas DiNapoli, who heads that state’s pension fund, recommended that Chesapeake’s stockholders refuse to renew the terms of two incumbent board members, saying it was a “necessary first step toward reconstituting a board that is currently entrenched and unaccountable to shareholders.” Corporate raider Carl Icahn, who is circling around the company, has indicated that he thinks the company’s problems are largely the result of poor management at the top.

The sale of Chesapeake’s New York assets to Minard is no doubt part of an effort to meet the cash shortfall. Minard’s new real estate interests, meantime, have augmented the company’s interest in the future of gas well drilling in New York State, especially the future of horizontal, deep-well, hydraulic fracturing, which is the subject of a state review.

Which may help to explain why, in the first week in May, James J. Macfarlane, Minard’s vice president for exploration, acquisitions, and operations, met with Republican State Senator Mark Grisanti in Buffalo’s Donovan State Office Building. Also in the meeting were Brad Gill, executive director of the Independent Oil and Gas Association on New York, or IOGA; Stephen W. Rhoads, manager of state government relations, Appalachia Region, for Shell Energy; and Daniel M. Krainin, an attorney in the New York office of the law firm Beveridge & Diamond, which specializes in environmental and land use law. Macfarlane and Rhoads are both board members of IOGA.

Grisanti, who is chair of the Senate’s Environmental Conservation Committee, has been in a crucible of pressure from both industry-funded proponents of horizontal fracking and environmental activists opposed to the practice. So far, he has declined to take a public position on whether the state ought to permit fracking, preferring to wait until the New York State Department of Environmental Conservation completes its review of the permitting and regulatory scheme it released last year.



Concern: Minard Run now owns one of the state’s three injection disposal wells.  They own fifteen thousand acres of lease holdings in the Marcellus in Bradford County.
We’d better pay attention here.  Minard Run, in their acquisitions  in Cayuga and Onondaga County in March, picked up the injection disposal well near Cayuga Lake not far from Montezuma Wildlife Refuge, name of well on DEC database Quill 672.  
Many  of the wells Minard picked up from CHK were old (1980s) Queenston sandstone wells, lots in Cayuga County.
In Ohio, many of the injection wells are older sandstone wells which were subsequently permitted to flip to injection disposal wells. 

There is no mandated public hearing when the EPA permits an injection well in NY.  (EPA has oversight, NY one of ten states that has not requested primacy for oversight.)   EPA does have to post on their website for thirty days any pending permits – and IF they consider there is sufficient public interest, they MAY issue a press release which the municipality MAY choose to publish.    

John Holko, of Lenape,  who owns another of the injection wells southeast of Rochester, was at the Auburn City Council meeting when they rescinded the ban on taking waste at the municipal treatment plant.  He was also quoted in the NYTimes as saying the infrastructure on waste will be developed as it goes in NY.    His injection well, named Ranous on the DEC site, drilled and permitted for injection in 1985, is 640′ deep.  No zero missing there.  Ranous well is the only one of the three wells exempt from mandated biannual certified sampling of injectate and exempt from nearby ground water monitoring wells required at the two other injection wells.  Interesting as it is the most shallow, the other two wells being 1080′ and 1800′ deep,  shallow still in relation to the injection wells in OH and TX which are several thousand feet deep.

Something to watch, Minard now owning that injection well, they having Marcellus holdings. Waste being a wildcard.  

Mary M