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Class II Saltwater Disposal Wells in Ohio:
Understanding the Avenue to Success
Authors:
Tom Tomastik, Senior Geologist, ALL Consulting
J. Daniel Arthur, P.E., SPEC, ALL Consulting
Chuck Lowe, Senior Geologist, ALL Consulting
Presented at: 6th Annual AIPG Conference – The Expanding
World of Unconventional Shale Hydrocarbon Resources,
Worthington, Ohio, April 27-29, 2015
Introduction
• Rapid development of the
Marcellus and Utica
shales led to big demand
in Class II disposal wells.
• There are a limited
number of Class II SWD
wells in NY, PA, and WV.
• Ohio remains well suited
for handle the increase in
disposal activity.
Source: ODNR, 2015
Copyright 1999-Present
May 5, 2015
2
Ohio’s Class II SWD Program
• Ohio received primacy of its
Class II program in 1983.
• Ohio has seen a dramatic rise
in Class II SWD permitting
activity since 2010.
• Class II wells have increased
from 161 to 238 permitted
wells.
• Currently, there are 202 in
operation, 17 being drilled or
completed and 22 permitted.
Source: ALL Consulting, 2015
Copyright 1999-Present
May 5, 2015
3
Increased Ohio Injection Activity
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In mid-2010, with the enactment of Senate Bill 165, Ohio started tracking brine
disposal on a quarterly basis and in-state vs. out of state disposal volumes.
Disposal volumes in Ohio have continued to increase from a little over 12.5
million barrels in 2011 to over 23 million barrels in 2014.
Out-of-state disposal reached a peak of 58% in 2012 and has now leveled off to
about a 50/50 split, with the marked increase in disposal from Ohio’s Utica Shale
operations.
Copyright 1999-Present
May 5, 2015
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Increased Injection Activity Leads to
Increased Environmental Activism
Source: ecowatch.com
Source: insideclimatenews.org
Source: napalmcreek.com
Copyright 1999-Present
May 5, 2015
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…..And New Regulations
• Ohio has passed several
rounds of new regulations
since 2010 that have
impacted Class II SWDs concerning well
construction and
cementing, seismic
monitoring, additional
injection well testing
requirements, and
continuous integrity
monitoring.
Source: ODNR, 2015
Copyright 1999-Present
May 5, 2015
6
Challenges Facing Ohio Injection Well Applicants
and Operators can be Overwhelming
Source: youtube.com
Source: frackwire.com
Source: mytattospro.com
Copyright 1999-Present
May 5, 2015
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These Challenges Include:
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Finding and locating open spaces for well siting.
Identifying road network and access.
Addressing mineral rights issues.
Dealing with densely populated areas.
Finding adequate geologic formations for high capacity disposal.
Working with Regulatory Agency and permitting process.
Addressing opposition to injection wells.
Understanding well construction, cementing, and completion
practices.
Determining additional testing requirements – radioactive tracer or
spinner survey, pressure fall-off testing, original bottom hole pressure
recording, and any other tests deemed necessary.
Addressing seismic unit installation and monitoring requirements.
Selecting right options for surface facilities and proper pre-treatment
of fluids.
Addressing TENORM and solid waste issues.
Copyright 1999-Present
May 5, 2015
8
Well Siting Criteria
• Ideally, away from
populated areas.
• Good road network
and access.
• Purchasing or leasing
property, mineral
rights issues, rights to
inject.
• Favorable geologic
conditions for high
capacity disposal.
Copyright 1999-Present
Source: Google earth.com
May 5, 2015
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Geological Evaluation
• Proper geological
evaluation is critical to a
successful large
capacity disposal well in
Ohio.
• Knowledge of geologic
formations and regional
variations is important
in selecting appropriate
disposal intervals.
Source: DOGRM, 2013
Copyright 1999-Present
May 5, 2015
10
Working with Regulatory Agency and
Permitting Process
• Completion of the area of
review evaluation.
• Submittal of required
applicant forms.
• Fulfillment of public notice
requirement.
• Addressing of potential
objections to the
application.
Source: DOGRM, 2013
Copyright 1999-Present
May 5, 2015
11
Opposition to Injection Wells
• Opposition to saltwater
disposal wells has
increased dramatically in
Ohio in the last three
years.
• There have been
objections to SWD
applications and protests
and demonstrations at
operational sites.
• The applicant needs to be
prepared to address these
challenges.
Copyright 1999-Present
Source: Commondreams.org
May 5, 2015
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Well Construction, Cementing, and
Completion Practices
• Understanding proper
well construction design,
geophysical log
interpretation, cementing,
and completion practices
in Ohio are essential to a
successful SWD well.
Source: DOGRM, 2013
Copyright 1999-Present
May 5, 2015
13
Additional Ohio Downhole Testing
Requirements
• Additional testing
requirements such as
radioactive tracer or
spinner survey logging.
• Pressure fall-off tests.
• Testing and recording
original bottom hole
pressures.
• Any other tests the
Chief deems necessary.
Copyright 1999-Present
Source: Lufkin.com
May 5, 2015
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Seismic Unit Installation
• Ohio regulations can
require submittal of a
seismic monitoring
plan.
• Seismic unit installation
is now required on deep
Knox – Mt. Simon Class
II SWD wells.
• Agreed seismic unit
locations with ODNR
Copyright 1999-Present
Source: ALL Consulting, 2014
May 5, 2015
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Actual Seismic Monitoring
• Seismic monitoring in
real-time.
• Required to submit
data to DOGRM.
• Notification to
operator of seismic
event in real-time by
automated e-mail.
Copyright 1999-Present
Source: ISTI, 2015
May 5, 2015
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Designing a Surface Facility
Source: ALL Consulting, 2014
Copyright 1999-Present
May 5, 2015
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Typical Injection Surface Facility
Operation in Ohio
• Two types of surface
facilities are common –
earthened dike with
minimum of 30 mil liner
or concrete dike.
• Dike must be able to
contain all fluids in event
of accidental release.
• Concrete unloading pad
with drain and sump that
collects any spillage is
required.
Source: DOGRM, 2012
Copyright 1999-Present
May 5, 2015
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Pre-treatment of Injection Fluids
• It is extremely important to
properly filter and
chemically treat the
injectate prior to injection.
• Chemical treatment needs
to address not only the type
of fluid to be injected, but
also the sensitivity of the
injection formations.
• Advanced technology
applications can offer
additional alternatives and
cost savings.
Copyright 1999-Present
Source: ALL Consulting, 2012
May 5, 2015
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TENORM and Solid Waste Disposal
in Ohio
TENORM in Ohio is regulated by
the Ohio Dept. of Health (ODH).
Oil and gas regulations also address
requirements for testing or
manifesting of TENORM solid
wastes.
Radium-226 and Radium-228 are
the predominant TENORM issues
with oil and gas.
At Ohio Class II SWD facilities, solids
required to be tested for TENORM
will be tank bottoms, pipe scale,
and filter media.
These solids can also be manifested
for shipment out of state without
conducting testing.
Copyright 1999-Present
Source: slideshare.net
May 5, 2015
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TENORM Regulations in Ohio
• Ohio has some of the
most stringent TENORM
rules in the country.
• Ohio landfills can only
accept TENORM wastes at
concentrations of less
than 5 picocuries per
gram above background
radiation.
• Regulations allow for
dilution of TENORM
wastes with approval
from Ohio Dept. of
Health.
Source: ODH, 2015
Copyright 1999-Present
May 5, 2015
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Conclusions
• Proper consideration of
these challenges can
lead to success in Ohio’s
SWD environment.
• ALL is actively engaged
in assisting oil and gas
clients in Ohio and
understands how to
maneuver in the
disposal well landscape
and how to address
these challenges.
Copyright 1999-Present
Source: ALL Consulting, 2015
May 5, 2015
22
Questions?
Tom Tomastik, Senior Geologist and
Regulatory Specialist
ALL Consulting, LLC
10811 Keller Pines Court
Galena, Ohio 43021
ttomastik@all-llc.com
www.all-llc.com
Source: ALL Consulting, 2015
Citation Information: Tom Tomastik, J. Daniel Arthur, and Chuck Lowe,, ALL
Consulting, “Class II Saltwater Disposal Wells in Ohio: Understanding the Avenue
to Success” Presented at the 6th Annual AIPG Conference – The Expanding World
of Unconventional Shale Hydrocarbon Resources, Worthington, Ohio, April 2729, 2015.
Copyright 1999-Present
May 5, 2015
23