UPDATE …GAO June 2014 report “EPA to Protect Underground Sources from Injection of Fluids Associated with OiL & GAS Production Needs Improvement”
Back in 1992 the New York Times discussed the “problematic” oil & gas wells that are unknown/unregistered, or improperly sealed. But pair up those “problem wells” that are in close proximity to class II injection wells…and “well” that is double jeopardy.
These “problem” wells become conduits for ground water contamination via communicating with disposal injection wells or enhanced recovery injection wells.
This historic EPA 1987 report is a must read showing the EPA has had decades upon decades to mitigate fossil fuel extraction risks even before the unconventional/horizontal drilling and even shows the exempting of oil and gas drilling fluids as “hazardous” waste (on page 11-16) which predates the Halliburton Loophole from the Energy Policy Act of 2005.
Fast forward to the frenzy of unconventional drilling here in the Barnett Shale and note this 2010 WFAA video is about a new gas well pad site + an injection well down the road = the claim for one or both ruining this man’s well water…..http://www.wfaa.com/news/local/Water-well-driller-blames-gas-rig-for-tainted-supply-104456654.html
So now that you have this lead in info, here is the “previously confidential” General Accounting Office (GAO) report from 1989 which implicates Class II injection wells. But first I want to QUICKLY mention the other two problems with injection wells…
1) They are lightening strike prone. Read here for the 2013 Somervell County Dec 23 where a Class B poison was used to extinguish that injection well fire.
2) Injection wells are linked to causing seismic events now being called “frackswarms”.
HERE IS THE LINK TO THE GAO REPORT….
http://www.gao.gov/assets/150/147952.pdf …..HERE ARE THE HIGHLIGHTS I CUT AND PASTED FOR YOUR READING EASE…..
“EPA did not issue regulations for primacy states (KS, TX, NM, & OK) to follow in developing their programs but issued less binding guidance documents, which specified a number of basic safeguards to protect against drinking water contamination. The guidance includes:
(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 bankrupt) 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.”
End of GAO report highlights.
Here are more reasons to hate Injection Wells….Pressure tests can and have been faked….we cannot trust the O&G industry..period.
Texas Sharon blogged back in 2008 that Peggy Heinkel-Wolfe, a local fearless reporter, wrote…”Texas has nearly 78,000 injection wells, including about 50,000 of the nation’s 144,000 Class II wells used for “exempt” oil and gas wastewater.”
So it was no surprise to me that the ATSDR reported on the following link http://www.atsdr.cdc.gov/toxprofiles/tp115-c6.pdf on Table 6-1 called “Releases to the Environment from Facilities that Produce, Process, or Use Phenol” that in 2005Texas contributed 83% (1.2 million pounds per year) of the United State’s Phenolreleased via Class II Underground Injection Wells.
So if this is the 2005 figure, read on to figure out how much we dispose by now.
http://www.texastribune.org/2013/03/29/disposal-wells-fracking-waste-stir-water-concerns/ reported…“The amount of wastewater being disposed of in Texas wells has skyrocketed with the spread of fracking, to nearly 3.5 billion barrels in 2011 from 46 million barrels in 2005, according to data from the Railroad Commission of Texas, the state’s oil and gas regulator. On average, companies in Texas dispose of 290 million barrels of wastewater — equivalent to about 18,500 Olympic-size swimming pools — each month.”
You do the math with me…..
ATSDR says in 2005 that 1,225,500 ppy (pounds per year) of phenol was injected in TX.
RRC says in 2005 that 46 million barrels of waste water was generated that had to be injected. That means for every 38 barrels of injection waste, that one pound of Phenol (a major metabolite of Benzene) was generated. Keep in mind that one teaspoon of Benzene contaminates about 261,000 gallons of water…