1) the % that is recycled is not impressively high in relation to total waste and that no one is overseeing how much is left down there-so who’s incharge of verifying that was is coming back up is getting disposed/injected “legally”?
2) it is cheaper to inject it than to recycle it (I live in TX-that’s what we do here-hello seismic activity)
3) what “is” recycled and used to frac new wells with has higher turbidity issues and makes the engines have to run on higher PSI’s
4) the recycled stuff is “frack on crack” with concentrated radiation
5) the longer we inject waste into the same disposal well, the more “filled” it gets, the more intense our seismic events (hello fracked up casings)
6) injection wells do not get along nicely with clean coal disposal wells
7) we inject our disposal waste into the Ellenberger formation which is deeper than the Barnett Shale, but one day, when we need to purify that for drinking needs, we will be sorry that we fracked that last resort source up.
Here is what Ft Worth has on line about disposal injection wells …
From: kim feil <email@example.com>
To: firstname.lastname@example.org; email@example.com; Robert Rivera <firstname.lastname@example.org>; email@example.com; firstname.lastname@example.org; email@example.com; firstname.lastname@example.org; email@example.com; firstname.lastname@example.org; email@example.com; firstname.lastname@example.org; Stuart.Young@arlingtontx.gov; email@example.com
Cc: firstname.lastname@example.org; email@example.com
Sent: Sun, July 15, 2012 4:28:14 PM
Subject: injection wells history of known ground water contamination
“In September 2003, Ed Cowley got a call to check out a pool of briny water in a bucolic farm field outside Chico, Texas. Nearby, he said, a stand of trees had begun to wither……Chico, a town of about 1,000 people 50 miles northwest of Fort Worth, …. A short distance away from the murky pond, an oil services company had begun pumping millions of gallons of drilling waste into an injection well…..The well had been authorized by the Railroad Commission of… As federal law requires, they also reviewed a quarter-mile radius around the site to make sure waste would not seep back toward the surface through abandoned wells or other holes in the area. Yet the precautions failed. “Salt water” brine migrated from the injection site and shot back to the surface through three old well holes nearby…. commission officials did not sample soil or water near the leak. If the injection well waste “had threatened harm to the ground water in the area, an in-depth RRC investigation would have been initiated,” Ramona Nye, a spokeswoman for Texas’ Railroad Commission, …. Accounts similar to Cowley’s appeared in an article about the leak in the Wise County Messenger, a local newspaper. …After the breach, the commission ordered two of the old wells to be plugged … It did not issue any violations against the disposal company…The commission allowed the well operator to continue injecting thousands of barrels of brine into the well each day. A few months later, brine began spurting out of three more old wells nearby.”
(1) operator-conducted pressure tests to check for cracks and leaks in the wells before they receive a permit to begin operations and
(2) pressure tests and reviews of well files for wells that were already operating under state programs before the federal program went into effect to make sure the wells had been properly constructed and were being properly operated.
While (US General Accounting Office) GAO’S evaluation of contamination cases was nationwide, its evaluation of how safeguards have been implemented focused only on state administered programs, under which most Class II wells are regulated. GAO analyzed, in late 1987 and early 1988, a randomly selected sample of Class II wells in four of the primacy states-Kansas, New Mexico, Oklahoma, and Texas to determine the extent to which states implemented program safeguards. About two-thirds of the state regulated Class II wells are located in these four states.
Although the full extent is unknown, EPA is aware of 23 cases (plus 4 suspected) nation wide in which drinking water was contaminated by Class II wells. In many of these cases, improperly plugged oil and gas wells in the vicinity of injection wells served as the pathway for brines to reach drinking water. Although operators of wells that began operating after the program went into effect are required to search for and plug any improperly plugged wells in the immediate vicinity of their injection wells, this requirement does not apply to those Class II wells that were operating before the program. Injection wells already operating before the program accounted for nearly all of the cases in which contamination has occurred through migration into improperly plugged wells. Moreover, GAO estimates that at least 70 percent of its universe of Class II wells were already operating before the program and therefore have not been subject to the requirement to search and plug nearby improperly plugged wells.
Although the four state programs we analyzed require the safeguards that are currently part of EPA’S program, some of these states are issuing permits to operate new Class II wells without evidence that pressure tests were conducted, and some have not finished reviewing files and pressure testing some of the existing wells. EPA and the states have taken steps to address some of these problems, but the states still need better documentation before issuing permits.
The full extent to which Class II wells have caused drinking water contamination is unknown, largely because the method for detecting contamination-installing underground monitors can itself create a conduit for contamination and is therefore not widely used.
Among the 23 known contamination cases, most resulted from cracks in the injection wells or from injection directly into drinking water; these cases were discovered, for the most part, as a result of required pressure testing and file reviews. However, in more than a third of the known cases, drinking water became contaminated when injected brines traveled up into improperly plugged abandoned wells in the vicinity of the injection wells and entered drinking water through cracks in these old wells.
Since all but one of these injection wells were already operating at the time the program took effect, searches for and plugging of improperly plugged wells in the vicinity of the injection wells were not required. Contamination was not discovered, for the most part, until water supplies became too salty to drink or crops were ruined.
In 1976, before beginning the program, EPA proposed requiring all operators to search for and plug any improperly plugged abandoned wells within a 1/4 mile radius of their injection wells. However, commenters objected to making all wells subject to this rule because of the high costs involved. EPA decided to exempt those wells already operating, reasoning that because of the proximity between new wells and existing wells, the searches undertaken in the l/4-mile radius of new wells would eventually uncover and result in the plugging of all the old wells.
(obselete statement)…Since then, however, relatively few new injection wells have come into operation. As a result, less than a third of GAO’s universe of wells has been subject to area-of-review requirements. On the basis of a survey of old oil and gas production records, EPA has estimated that there are approximately 1.2 million abandoned oil and gas wells in the United States, of which about 200,000 may not be properly plugged. Moreover, among the four states that GAO examined, state officials in all but New Mexico believe that the numbers of improperly plugged wells are increasing – the result of the current (drillers going banrupt) economic decline in the oil industry.
Although these four states have programs to plug these wells, Texas and Oklahoma officials said they now have more wells to be plugged than they can afford to pay for, and Kansas officials fear that with the increased numbers of wells reported each year, their plugging program may not be sufficient in the future.
At the time of GAO’s (General Accounting Office) review of well files in late 1987 and early 1988, implementation of program safeguards in the four states reviewed was mixed. GAO found that the files of 41 percent (with a sampling error of + 14 percent) of the wells with permits contained no evidence that pressure tests had ever been performed, even though these tests are required before start-up and every 5 years thereafter. In three of the four states GAO reviewed, internal controls were not in place to ensure that all necessary documentation was on file.”
pg 11….”If contamination is extensive, however, and covers a large area, rehabilitation may be extremely costly. In these cases, if the aquifer is left to cleanse itself, the process can take as long as 250 years.”
pg19…..”Injection wells already operating comprise at least 70 percent of the estimated 88,000 Class II wells in our universe. According to EPA improperly plugged wells near operating injection wells present significant environmental problems.”
pg23….”..about half the known and suspected cases were discovered only after contamination had become obvious to the people affected, for example, when their well water became too salty to drink, their crops were ruined, or when they could see water flowing at the surface of old wells. Neither EPA nor the states routinely require groundwater monitoring for Class II wells.”
pg24….”The 23 cases in which contamination was confirmed can be traced to three principal causes: five cases resulted from leaks in the casing of the injection wells, nine cases resulted from injection into the USDW (underground source of drinking water), and nine resulted from migration of brines from operating injection wells into nearby oil and gas wells that had been left unplugged or improperly plugged.”
pg25… “In the other 18 cases, EPA or the state decided that cleanup was either technically not feasible, too expensive, or not practical because the aquifer was already high in brine content and not usable for drinking water without treatment.”
pg31…..”The importance of having sufficient safeguards is underscored by the fact that there are usually no practical remedies once contamination occurs. For most of the 23 confirmed cases, the drinking water sources that were contaminated will remain so for (as long as 250) years until natural processes restore water quality.”
pg35….”In Texas, officials acknowledged that they rarely reviewed the accuracy of information submitted to satisfy area-of-review requirements because of the time and staff required…..We found that those wells in Texas that had no record of pressure tests had all been issued permits before 1986 and were therefore not required to submit evidence.”
FYI, 1200 “identified” wells still need to be plugged in Texas as of June 2012
Heres a Jerry Lee Lewis vid “Whole Lotta Shaking Going On”