Wicked Witch of the Waste

The Great Plains has become the unconventional oil & gas industry’s dumping ground, prompting questions about the security and resilience of the bread basket and the underlying Ogalalla Aquifer

Back in December of 2016, FracTracker analyzed the growing link between injection wells that dispose fracking waste and “induced seismicity” [1], or human-caused earthquakes. Our compiled maps from this analysis (including Figure 1 below) show seismic activity in Kansas and Oklahoma along with Class II injection well volumes up through 2015. 

Figure 1. Earthquakes and Class II Injection Well Activity at the Kansas-Oklahoma Border

This link was given acute attention at that time as a result of the magnitude 5.8 earthquake in Pawnee, Oklahoma on September 3rd, 2016, followed closely by a 4.5 earthquake on November 1st.  The industry’s increased production of waste came home to roost 5 days later when a magnitude 5.0 quake struck a mile west of the “Cushing Hub,” the largest commercial crude oil storage center in North America. The Cushing Hub is capable of storing 54 million barrels of crude – the equivalent of 2.8 times the U.S. daily oil refinery capacity and 3.1 times the daily oil refinery capacity of all of North America.

Sunflower State of Affairs

Since we published this analysis and associated maps, Class II injection wells have been in the news several times across the Great Plains. An investigation by KSN News found that the Kansas Corporation Commission (KCC) improperly permitted over 2,000 Class II injection wells. The KCC stated that public comment periods for well proposals lasted just 15 days, instead of the correct number of 30 days. This amounts to 42% and 28% of the state’s active and total inventory of oil and gas waste receiving wells approved with inaccurate public notices.

Quail Oil & Gas LC’s Class II Salt Water Disposal (SWD) well, Morris County,
KS near Diamond Creek (Photo Courtesy of Karla jo Grimmett at South 500 photography)

According to Cindy Hoedel, a freelance journalist in Kansas, the KCC responded to the investigation findings… by ruling that no remedy was needed and closing the docket.”

Attorneys representing the Sierra Club maintain that improper permitting by the KCC continued into the Fall of 2018:

“The significance is they are choking us off in terms of giving us less and less time to try to mount a protest, to submit any kind of comment, and that’s a lot,” Cindy Hoedel, a Matfield Green resident who has complained about earthquakes in her area, said… “These notices get published in these tiny little newspapers, and sometimes it might take us 15 days before we find it”

As Ms. Hoedel wrote in an email when I asked her to comment on issues relating to Kansas’ Class II injection wells:

“The Republican controlled Kansas Legislature is trying to fend off several proposed bills that would reform the KCC (the regulatory body that oversees the permitting of Class II underground injection control wells). Citizen challenges of individual applications for disposal and EOR [enhanced oil recovery] wells continue, with the KCC moving more aggressively than in the past to dismiss protestants before a hearing is held. Some of these dismissals are being challenged in appellate court. The activists’ view is that EPA, the SWDA [Safe Water Drinking Act] and Congress clearly intend for the public to be able to participate in the regulatory process; instead, KCC has written regulations that are effectively barriers to participation… Activists have questions about the large number of EOR wells being applied for in Kansas and what their true purpose is, given the insignificant amounts of oil being produced compared to high volumes of injected fluids. Another concern is that the injection well earthquakes in Oklahoma and Kansas continue, yet KCC refuses to add regs that would address seismic risk in permit applications. There is also a problem with harassment of citizens exercising their right to protest – Scott Yeargain and I were both turned in to the Kansas AG’s office by a KCC staffer on the bogus claim that we were practicing law without a license because we helped explain the convoluted process to other protesters.”

Grapes of Wrath

Meanwhile, across the border, Oklahoma City and its surrounding suburbs have become the San Francisco of the Great Plains, with regular earthquake swarms (including many that exceed magnitude 4.0). According to Think Progress reporter Samantha Page, despite the damages and lawsuits caused by these earthquakes, “for years, the state was slow to respond, while Gov. Mary Fallin (R) and others questioned the link to human activity.” 

Eventually, by the end of 2016, the Oklahoma Corporation Commission responded by implementing a ‘traffic light’ protocol, in which operations are paused or stopped altogether following earthquakes of certain magnitudes. For a time, the EPA demanded a moratorium on disposal across Class II wells injecting into the Arbuckle formation in “high seismically active focus areas.”

Chad Warmington, president of the Oklahoma Oil and Gas Association, said that this response by the EPA is “a stellar example of the inefficiency of the federal government…It’s akin to a newspaper telling us today the football scores from games played 15 months ago.”

In reporting on the industry’s response, journalist Paul Monies, buried the lead when he pointed out the following in his second to last paragraph:

“Wastewater recycling remains an expensive option compared to the low costs of disposal wells in Oklahoma. While operators can inject wastewater into formations other than the Arbuckle, Hatfield said other formations don’t accept water as easily and are at shallower depths.”

The Map

Our second stab at mapping the scale and scope of Class II injection wells across the Great Plains is slightly different than our first effort in a few ways:

  1. This iteration includes Class II Salt Water Disposal (SWD) Injection Wells in Nebraska, Oklahoma, and Kansas on one map. Clicking on a well reveals its location, well name, operator, and the volume of wastewater disposed. Volumes are presented annually for Nebraska and monthly for 2011 to 2017 for Oklahoma and Kansas. We also present annual sums for Oklahoma from 2006 to 2010.
  2. The map shows Arkansas and Platte River Basin boundaries, which contain the entire inventory of OK, NE, and KS Class II wells.
  3. We’ve included Hydrologic Unit Codes, which when zoomed in to the map, identify sub-watersheds, and the Ogalalla Aquifer boundary, courtesy of the USGS’s Sharon Qi.
  4. Finally, we’ve includedUS Forest Service Robert G. Bailey’s Ecoregions to give a sense for the types of ecosystems threatened by the O&G industry’s demand for suitable waste disposal sites

View Map Full Screen | To view the legend on this map, click the “layers” icon on the top left of the screen

Table 1, below, breaks down the volumes of oil and gas wastewater disposed in Oklahoma, Kansas and Nebraska. Volumes are measured in million barrels, with one barrel equivalent to 42 gallons. The number of Class II SWD (salt water disposal) injection wells in these states is separated to show the total number of wells permitted verse the number of wells that were active (receiving waste).

Table 1. Class II injection well volumes in 2017

In total, 3,385,700,000 barrels of wastewater were disposed in 5,975 injection wells in these three states in 2017. The volume of wastewater disposed has increased in recent years (Table 2).

Table 2. Cumulative Class II injection well volumes to 2017, annual percent changes, and likely 2018 and 2027 volumes

In Table 2, the theoretical annual volumes for 2018 and 2027 are predictions based on the average of linear, exponential, and polynomial models.

The Kansas-Oklahoma Border

It is critical that we analyze the Great Plains fracking waste ecosystem across state lines. There are several reasons for this, including the proximity of Kansas’ most active Class II wells to the Oklahoma border (Figure 2) and the potential for the KCC to use enhanced oil recovery wells in Kansas to dispose of Oklahoma’s fracking waste.

Figure 2. Class II injection well volumes for 2017 along the Kansas-Oklahoma border.

Collaboration between front line communities, non-profits like FracTracker Alliance, and groups like the Kansas Water Advocacy Team (WAT) will be crucial to understanding the impacts of waste disposal writ large.  It seems like the “food vs energy” nexus has come to a head in the heart of the U.S. Bread Basket. We’ll continue to highlight and map the issues associated with this topic in the coming months and years.

Data Download Links

The following links contain the data used in the above tables and map, for use in excel and with Geographic Information Systems (GIS).

[1] To learn more about Induced Seismicity, read an exclusive FracTracker two-part series from former researcher with Virginia Tech Department of Geosciences, Ariel Conn: Part I and Part II.

Additionally, the USGS has created an Induced Earthquakes landing page as part of their Earthquake Hazards Program.

Getting Rid of All of that Waste – Increasing Use of Oil and Gas Injection Wells in Pennsylvania

Oil and gas development generates a lot of liquid waste.

Some of the waste comes that comes out of a well is from the geologic layer where the oil and gas resources are located. These extremely saline brines may be described as “natural,” but that does not make them safe, as they contain dangerous levels of radiation, heavy metals, and other contaminants.

Additionally, a portion of the industrial fluid that was injected into the well to stimulate production, known as hydraulic fracturing fluid, returns to the surface.  Some of these substances are known carcinogens, while others remain entirely secret, even to the personnel in the field who are employed to use the additives.

The industry likes to remind residents that they have used this technique for more than six decades, which is true. What separates “conventional” fracking from developing unconventional formations such as the Marcellus Shale is really a matter of scale.  Conventional formations are often stimulated with around 10,000 gallons of fluid, while unconventional wells now average more than 10 million gallons per well.

In 2017 alone, Pennsylvania oil and gas wells generated 57,653,023 barrels (2.42 billion gallons) of liquid waste.

Managing the waste stream

Liquid waste can be reused to stimulate other oil and gas wells, but reuse concentrates the contaminant load in the fluid. There is a limit to this concentration that operators can use, even for this industrial purpose.

Another strategy is to decrease the volume of the waste through evaporation and other treatment methods. This also increases the contaminant concentration. Pennsylvania used to permit “treatment” of wastewater at sewage treatment facilities, before being forced to concede that the process was completely ineffective, and resulted in contaminating streams and rivers throughout the Commonwealth.

In many states, much of this waste is disposed of in facilities known as salt water disposal (SWD) wells, a specific type of injection well. These waste facilities fall under the auspices of the US Environmental Protection Agency’s Underground Injection Control (UIC) program. Such wells are co-managed with states’ oil and gas regulatory agencies, although the specifics vary by state.

These photos show SWD wells in other states, but what about in Pennsylvania?

The oil and gas industry in Pennsylvania has not used SWD wells as a primary disposal method, as the state’s geology has been considered unsuitable for this process.  For example, on page 67 of this 2009 industry report, the authors saw treatment of flowback fluid at municipal facilities as a viable option (before the process was  banned in 2011), but underground injection as less likely (emphasis added):

The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.

The ban on surface “treatment” being discharged into Pennsylvania waters has increased the pressure for finding new solutions for brine disposal.  This is compounded by the fact that the per-well volume of fluid injected into shale gas wells in the region has nearly tripled in that time period. Much of what is injected comes back up to the surface and is added to the liquid waste stream.

Chemically-similar brine from conventional wells has been spread on roadways for dust suppression. This practice was originally considered a “beneficial use” of the waste product, but the Pennsylvania Department of Environmental Protection (DEP) halted that practice in May 2018.

None of these waste management decisions make the geology in Pennsylvania suddenly suitable for underground injection, however, they do increase the pressure on the state to find a disposal solution.

Concerns with SWD wells

There are numerous concerns with salt water disposal wells.  In October 2018, the DEP held a hearing in Plum Borough, on the eastern edge of Allegheny County, where there is a proposal to convert the Sedat 3A conventional well to an injection well. Some of the concerns raised by residents include:

  • Fluid and/or gas migration- There are numerous routes for fluids and gas to migrate from the injection formation to drinking water aquifers or even surface water.  Potential conduits include coal mines, abandoned gas wells, water wells, and naturally occurring fissures in crumbling sedimentary formations.
  • Induced seismicity- SWD wells have been linked to increased earthquake activity, either by lubricating or putting pressure on old faults that had been dormant. Earthquakes can occur miles away from the injection location, and in sedimentary formations, not just igneous basement rock.
  • Noise, diesel pollution, loss of privacy, and road degradation caused by a constant stream of industrial waste haulers to the well location.
  • Complicating existing issues-  Plum Borough and surrounding communities are heavily undermined, and in fact the well bore goes right through the Renton Coal Mine (another part of which has been on fire for decades).  Mine subsidence is already a widespread issue in the region, and many fear that even small seismic events could exacerbate this.
  • Possibility of surface spill-  Oil and gas is, sadly, a sloppy industry, with unconventional operations having accumulated more than 13,000 violations in Pennsylvania since 2008.  If a major spill were to happen at this location, there is the possibility of release into Pucketa Creek, which drains into the Allegheny River, the source of drinking water for multiple communities.
  • Radioactivity and other contaminants- Flowback fluids are often highly radioactive, contain heavy metals, and other contaminants that are challenging to effectively clean.  The migration of radon gas into homes above the injection formation is also a possibility.

The current state of SWDs in Pennsylvania

Pennsylvania has numerous data sources for oil and gas, but they are not always in agreement. To account for this, we have mapped SWDs (and a five mile buffer around them) from two different data sources in the map below. The first source is a subset of SWD wells from a larger dataset of oil and gas locations from the DEP’s mapping website. The second source is from a Waste Facility Report, represented in pink triangles that are offset at an angle to allow users to see both datasets simultaneously in instances where they overlap.

Map of existing, proposed, and plugged salt water disposal (SWD) injection wells in Pennsylvania.

 View map fullscreen How FracTracker maps work

According to the first data set of DEP’s oil and gas locations, Pennsylvania contains 13 SWDs with an active status, one SWD with a regulatory inactive status, and eight that are plugged. The Waste Facility Report shows 10 SWD wells total, including one well that was left out of the other data set in Annin Township, McKean County.

It is worth noting that Pennsylvania’s definition for an “active” well status is confusing, to put it charitably. It does not mean that a well is currently in operation, nor does it even mean that it is currently permitted for the activity, whether that is waste disposal or gas production, or some other function. An active status means that the well has been proposed for a given use, and the well hasn’t been plugged, or assigned some other status.

The Sedat 3A well in Plum, for example, has an active status, although the DEP has not yet granted it a permit to operate as a SWD well. Another  status type is “regulatory inactive,” which is given to a well that hasn’t been used for its stated purpose in 12 months, but may potentially have some future utility.

Karst, coal mines, and streams

While there are numerous factors worthy of consideration when siting SWD wells, this map focuses on three: the proximity of karst formations, coal mines and nearby streams that the state designates as either high quality or exceptional value.

Karst formations are unstable soluble rock formations like limestone deposits which are likely to contain numerous subsurface voids. These voids are concerning in this context. For one reason, there’s the possibility of contaminated fluids and gasses migrating into underground freshwater aquifers. Also, the voids are inherently structurally unstable, which could compound the impacts of artificially-induced seismic activity caused by fluid injections in the well.

Our analysis found over 78,000 acres (123 square miles) of karst geology within five miles of current, proposed, or plugged SWD wells in Pennsylvania.

Coal mines, while a very different sedimentary formation, have similar concerns because of subsurface voids. Mine subsidence is already a widespread problem in many of the communities surrounding SWD well sites.  Pennsylvania has several available data sets, including active underground mine permits and digitized mined areas, which are used in this map.  Active mine permits show current permitted operations, while digitized mine areas offer a highly detailed look at existing mines, including abandoned mines, although the layer is not complete for all regions of the state.

In Pennsylvania, there are 56,542 acres (88 square miles) of active mines within five miles of SWD wells. Our analysis found 97,902 acres (153 square miles) of digitized mined areas within five miles of SWD wells.  Combined, there are 139,840 acres (219 square miles) of existing and permitted mines within the 5 mile buffer zone around SWDs in Pennsylvania.

Streams with the designation “high quality” and “exceptional value” are the best streams Pennsylvania has to offer, in terms of recreation, fishing, and biological diversity. In this analysis, we have identified such streams within a five mile radius of SWD wells, irrespective of the given watershed of the well location.

While the rolling topography of Western Pennsylvania sheds rainwater in a complicated network of drainages, groundwater is not subject to that particular geography. Furthermore, groundwater regularly interacts with surface water through water wells, abandoned O&G wells, and natural seeps and springs. Therefore, it is possible for SWDs to contaminate these treasured streams, even if they are not located within the same watershed.

Altogether, there are 716 miles of high quality streams and 110 miles of exceptional value streams within 5 miles of the SWDs in this analysis.


For decades, geologists have concluded that the subsurface strata in Pennsylvania were not suitable for oil and gas liquid waste disposal in underground injection wells.  The fact that vast quantities of this waste are now being produced in Pennsylvania has not suddenly made it a suitable location for the practice.  If anything, additional shallow and deep wells have further fractured the sedimentary strata, thereby increasing the risk of contamination.

The only factor that has changed is the volume of waste being produced in the region. SWD wells in nearby Ohio and West Virginia have capacity issues from their own production wells, and it is not clear that the geologic formations across the border are that much better than in Pennsylvania. But as new wells are drilled and volumes of hydraulic fracturing fluid continue to spiral into the tens of millions of gallons per well, the pressure to open new SWD wells in the state will only increase.

Perhaps because of these pressures, DEP has become quite bullish on the technology:

Several successful disposal wells are operating in Pennsylvania and options for more sites are always being considered. The history of underground disposal shows that it is a practical, safe and effective method for disposing of fluids from oil and gas production.
Up against this attitude, residents are facing an uphill battle trying to prevent harm to their health and property from these industrial facilities in their communities.  Municipalities that have attempted to stand up for their residents have been sued by DEP to allow for these injection wells.  The Department’s actions, which put the interests of industry above the health of residents and the environment, is directly at odds with the agency’s mission statement:
The Department of Environmental Protection’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. We will work as partners with individuals, organizations, governments and businesses to prevent pollution and restore our natural resources.
It’s time for DEP to live up to its promises.

By Matt Kelso, Manager of Data and Technology, FracTracker Alliance

Bird's eye view of an injection well (oil and gas waste disposal)

A Disturbing Tale of Diminishing Returns in Ohio

Utica oil and gas production, Class II injection well volumes, and lateral length trends from 2010-2018

The US Energy Information Administration (EIA) recently announced that Ohio’s recoverable shale gas reserves have magically increased by 11,076 billion cubic feet (BCF). This increase ranks the Buckeye State in the top 5 for changes in recoverable shale natural gas reserves between 2016 and 2017 (pages 31- 32 here). After reading the predictable and superficial media coverage, we thought it was time to revisit the data to ask a pertinent question: What is the fracking industry costing Ohio?

Recent Shale Gas Trends in Ohio

According to the EIA’s report, Ohio currently sits at #7 on their list of proven reserves. It is estimated there are 27,021 BCF of shale gas beneath the state (Figure 1).

Graph of natural gas reserves in different states 2016-2017

Figure 1. Proven and change in proven natural gas reserves from 2016 to 2017 for the top 11 states and the Gulf of Mexico (calculated from EIA’s “U.S. Crude Oil and Natural Gas Proved Reserves, Year-End 2017”).

There are a few variations in the way the oil and gas industry defines proven reserves:

…an estimated quantity of all hydrocarbons statistically defined as crude oil or natural gas, which geological and engineering data demonstrate with reasonable certainty to be recoverable in future years from known reservoirs under existing economic and operating conditions. Reservoirs are considered proven if economic producibility is supported by either actual production or conclusive formation testing. – The Organization of Petroleum Exporting Countries

… the quantity of natural resources that a company reasonably expects to extract from a given formation… Proven reserves are classified as having a 90% or greater likelihood of being present and economically viable for extraction in current conditions… Proven reserves also take into account the current technology being used for extraction, regional regulations and market conditions as part of the estimation process. For this reason, proven reserves can seemingly take unexpected leaps and drops. Depending on the regional disclosure regulations, extraction companies might only disclose proven reserves even though they will have estimates for probable and possible reserves. – Investopedia

What’s missing from this picture?

Neither of the definitions above address the large volume of water or wastewater infrastructure required to tap into “proven reserves.” While compiling data for unconventional wells and injection wells, we noticed that the high-volume hydraulic fracturing (HVHF) industry is at a concerning crossroads. In terms of “energy return on energy invested,” HVHF is requiring more and more resources to stay afloat.

OH quarterly Utica oil & gas production along with quarterly Class II injection well volumes:

The map below shows oil and gas production from Utica wells (the primary form of shale gas drilling in Ohio). It also shows the volume of wastewater disposed in Class II salt water disposal injection wells.

 View map fullscreen | How FracTracker maps work

Publications like the aforementioned EIA article and language out of Columbus highlight the nominal increases in fracking productivity. They greatly diminish, or more often than not ignore, how resource demand and waste production are also increasing. The data speak to a story of diminishing returns – an industry requiring more resources to keep up gross production while simultaneously driving net production off a cliff (Figure 2).

Graph of Utica permits in Ohio on a cumulative and monthly basis along with the average price of West Texas Intermediate (WTI) and Brent Crude oil per barrel from September, 2010 to December, 2018

Figure 2. Number of Utica permits in Ohio on a cumulative and monthly basis along with the average price of West Texas Intermediate (WTI) and Brent Crude oil per barrel from September 2010 to December 2018

The Great Decoupling of New Year’s 2013

In the following analysis, we look at the declining efficiency of the HVHF industry throughout Ohio. The data spans the end of 2010 to middle of 2018. We worked with Columbus-area volunteer Gary Allison to conduct this analysis; without Gary’s help this work and resulting map, would not have been possible.

A little more than five years ago today, a significant shift took place in Ohio, as the number of producing gas wells increased while oil well numbers leveled off. The industry’s permitting high-water mark came in June of 2014 with 101 Utica permits that month (a level the industry hasn’t come close to since). The current six-month permitting average is 25 per month.

As the ball dropped in Times Square ringing in 2014, in Ohio, a decoupling between oil and gas wells was underway and continues to this day. The number of wells coming online annually increased by 229 oil wells and 414 gas wells.

Graph showing Number of producing oil and gas wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 3. Number of producing oil and gas wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Graph of Producing oil and gas wells as a percentage of permitted wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 4. Producing oil and gas wells as a percentage of permitted wells in Ohio’s Utica Shale Basin from 2011 to Q2-2018


The ringing in of 2014 also saw an increase in the number of producing wells as a percentage of those permitted. In 2014, the general philosophy was that the HVHF industry needed to permit roughly 5.5 oil wells or 7 gas wells to generate one producing well. Since 2014, however, this ratio has dropped to 2.2 for oil and 1.4 for gas well permits.

Put another way, the industry’s ability to avoid dry wells has increased by 13% for oil and 18% for gas per year. As of Q2-2018, viable oil wells stood at 44% of permitted wells while viable gas wells amounted to 71% of the permitted inventory (Figure 4).

Production declines

from the top-left to the bottom-right

To understand how quickly production is declining in Ohio, we compiled annual (2011-2012) and quarterly (Q1-2013 to Q2-2018) production data from 2,064 unconventional laterals.

First, we present average data for the nine oldest wells with respect to oil and gas production on a per day basis (Note: Two of the nine wells we examined, the Geatches MAH 3H and Hosey POR 6H-X laterals, only produced in 2011-2012 when data was collected on an annual basis preventing their incorporation into Figures 6 and 7 belwo). From an oil perspective, these nine wells exhibited 44% declines from year 1 to years 2-3 and 91% declines by 2018 (Figure 5). With respect to natural gas, these nine wells exhibited 34% declines from year 1 to years 2-3 and 79% declines by 2018 (Figure 5).

Figure 5. Average daily oil and gas production decline curves for the above seven hydraulically fractured laterals in Ohio’s Utica Shale Basin, 2011 to Q2-2018

Four of the nine wells demonstrated 71% declines by the second and third years and nearly 98% declines by by Q2-2018 (Figure 6). These declines lend credence to recent headlines like Fracking’s Secret Problem—Oil Wells Aren’t Producing as Much as Forecast in the January 2nd issue of The Wall Street Journal. Four of the nine wells demonstrated 49% declines by the second and third years and nearly 81% declines by Q2-2018 (Figure 7).

Figure 6. Oil production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Figure 7. Natural gas production decline curves for seven hydraulically fractured laterals in Ohio’s Utica Shale Basin from 2011 to Q2-2018

Fracking waste, lateral length, and water demand

from bottom-left to the top-right

An analysis of fracking’s environmental and economic impact is incomplete if it ignores waste production and disposal. In Ohio, there are 226 active Class II Salt Water Disposal (SWD) wells. Why so many?

  1. Ohio’s Class II well inventory serves as the primary receptacle for HVHF liquid waste for Pennsylvania, West Virginia, and Ohio.
  2. The Class II network is situated in a crescent shape around the state’s unconventional wells. This expands the geographic impact of HVHF to counties like Ashtabula, Trumbull, and Portage to the northeast and Washington, Athens, and Muskingum to the south (Figure 8).

Map of Ohio showing cumulative production of unconventional wells and waste disposal volume of injection wells

Figure 8. Ohio’s unconventional gas laterals and Class II salt water disposal injection wells. Weighted by cumulative production and waste disposal volumes to Q3-2018.

Disposal Rates

We graphed average per well (barrels) and cumulative (million barrels) disposal rates from Q3-2010 to Q3-2018 for these wells. The data shows an average increase of 24,822 barrels (+1.05 million gallons) per well, each year.

That’s a 51% per year increase (Figure 9).

A deeper dive into the data reveals that the top 20 most active Class II wells are accepting more waste than ever before: an astounding annual per well increase of 728,811 barrels (+30.61 million gallons) or a 230% per year increase (Figure 10). This divergence resulted in the top 20 wells disposing of 4.95 times the statewide average between Q3-2010 and Q2-2013. They disposed 13.82 times the statewide average as recently as Q3-2018 (Figure 11).

All of this means that we are putting an increasing amount of pressure on fewer and fewer wells. The trickle out, down, and up of this dynamic will foist a myriad of environmental and economic costs to areas surrounding wells. As an example, the images below are injection wells currently under construction in Brookfield, Ohio, outside Warren and minutes from the Pennsylvania border.

More concerning is the fact that areas of Ohio that are injection well hotspots, like Warren, are proposing new fracking-friendly legislation. These disturbing bills would lubricate the wheels for continued expansion of fracking waste disposal and permitting. House bills 578 and 393 and Senate Bill 165 monetize and/or commodify fracking waste by giving townships a share of the revenue. Such bills “…would only incentivize communities to encourage more waste to come into their existing inventory of Class II… wells, creating yet another race to the bottom.” Co-sponsors of the bills include Democratic Reps. Michael O’Brien, Glenn Holms, John Patterson, and Craig Riefel.

Lateral Lengths

The above trends reflect an equally disturbing trend in lateral length. Ohio’s unconventional laterals are growing at a rate of 9.1 to 15.6%, depending on whether you buy that this trend is linear or exponential (Figure 12). This author believes the trend is exponential for the foreseeable future. Furthermore, it’s likely that “super laterals” in excess of 3-3.5 miles will have a profound impact on the trend. (See The Freshwater and Liquid Waste Impact of Unconventional Oil and Gas in Ohio and West Virginia.)

This lateral length increase substantially increases water demand per lateral. It also impacts Class II well disposal rates. The increase accounts for 76% of the former and 88% of the latter when graphed against each other (Figure 13).

Figure 12. Ohio Utica unconventional lateral length from Q3-2010 to Q4-2018

Figure 13. Ohio Utica unconventional water demand and Class II SWD injection well disposal volumes vs lateral length from Q3-2010 to Q4-2018.


This relationship between production, resource demand, and waste disposal rates should disturb policymakers, citizens, and the industry. One way to this problem is to more holistically price resource utilization (or stop oil and gas development entirely).

Unfortunately, states like Ohio are practically giving water away to the industry.

Politicians are constructing legislation that would unleash injection well expansion. This would allow disposal to proceed at rates that don’t address supply-side concerns. It’s startling that an industry and political landscape that puts such a premium on “market forces” is unwilling to address these trends with market mechanisms.

We will continue to monitor these trends and hope to spread these insights to states like Oklahoma and Texas in the future.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance – with invaluable data compilation assistance from Gary Allison

Data Downloads

FracTracker is a proponent of data transparency, and so we often share the data we use to construct our maps analyses. Click on the links below to download the data associated with the present analysis:

  • OH Utica laterals

    Ohio’s Utica HVHF laterals as of December 2018 in length (feet) (zip file)
  • Wastewater disposal volumes

    Inventory of volumes disposed on a quarterly basis from 2010 to Q3-2018 for all 223 active Class II Salt Water Disposal (SWD) Injection wells in Ohio (zip file)

Photo by Pat Sullivan/AP

California regulators need to protect groundwater from oil and gas waste this time around

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

California’s 2nd Largest Waste Stream

Every year the oil and gas industry in California generates billions of gallons of wastewater, also known as produced water. According to a study by the California Council on Science and Technology, in 2013, more than 3 billion barrels of produced water were extracted along with some 0.2 billion barrels of oil across the state. This wastewater is usually contaminated with a mixture of heavy metals, hydrocarbons, naturally occurring radioactive materials, and high levels of salts. Yet, contaminated wastewater from oil-field operations is exempt from the hazardous waste regulations enforced by the Resource Conservation and Recovery Act (RCRA).

Operators are, therefore, not required to measure or report the chemistry of this wastewater. Even with these unknowns, it is legally re-injected back into groundwater aquifers for disposal. Once an aquifer is contaminated it can be extremely difficult, if not impossible, to clean up again. Particularly in California, where water resources are already stretched thin, underground injection of oil and gas wastewater is a major environmental and economic concern.

Regulatory Deficiency

Under the Underground Injection Control program, wastewater is supposed to be injected only into geologic formations that don’t contain usable groundwater. However, a loophole in the Safe Drinking Water Act allows oil and gas companies to apply for what’s called an aquifer exemption, which allows them to inject wastewater into aquifers that potentially hold high-quality drinking water. To learn more about aquifer exemptions, see FracTracker’s summary, here.

The California department responsible for managing these aquifer exemption permits – the Division of Oil, Gas, and Geothermal Resources (DOGGR) – has for decades failed in its regulatory capacity. In 2015, for example, DOGGR admitted that at least 2,553 wells had been permitted to inject oil and gas waste into non-exempt aquifers – aquifers that could be used for drinking water. Independent audits of DOGGR showed decades of poor record-keeping, lax oversight, and in some cases, outright defiance of the law – showing the cozy relationship between regulators and the oil and gas industry. While 176 wells (those that were injecting into the cleanest drinking water) were initially shut down, most of the rest of the 2,377 permits were allowed to continue injecting into disputed wells through the following two years of the regulatory process.

The injection wells targeted by the Environmental Protection Agency (EPA), including those that were shut down, are shown in the map below (Figure 1).

Figure 1. Map of EPA-targeted Class II Injection Wells

View map fullscreen | How FracTracker maps work | Map Data (CSV): Aquifer Exemptions, Class II Wells

The timeline of all this is just as concerning. The State of California has known about these problems since 2011, when the EPA audited California’s underground injection program and identified substantial deficiencies in its program, including failure to protect some potential underground sources of drinking water, a one-size-fits-all geologic review, and inadequate and under-qualified staffing for carrying out inspections. In 2014, the Governor’s office requested that the California EPA perform an independent review of the program. EPA subsequently made a specific remediation plan and timeline for DOGGR, and in March of 2015 the State finalized a Corrective Action Plan, to be completed by February 2017.

Scientific Review of CA Oil and Gas Activities

Meanwhile, in 2013, the California Senate passed SB-4, which set a framework for regulating hydraulic fracturing in California. Part of the bill required an independent scientific study to be conducted on oil and gas well stimulation, including acid well stimulation and hydraulic fracturing. The California Council on Science and Technology organized and led the study, in collaboration with the Lawrence Berkeley National Laboratories, which combined original technical data analyses and a review of relevant literature, all of which was extensively peer-reviewed. The report argues that both direct and indirect impacts of fracking must be accounted for, and that major deficiencies and inconsistencies in data remained which made research difficult. They also recommended that DOGGR improve and modernize their record keeping to be more transparent.

Figure 2. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

Figure 2*. Depths of groundwater total dissolved solids (a common measure of groundwater quality) in five oil fields in the Los Angeles Basin. Blue and aqua colors represent protected groundwater; the heavy black horizontal line indicates the shallowest hydraulically fractured well in each field. In three of the five wells (Inglewood, Whittier, and Wilmington), fracking and wastewater injection takes place directly adjacent to, or within, protected groundwater.

A major component of the SB-4 report covered California’s Class II injection program. Researchers analyzed the depths of groundwater aquifers protected by the Safe Drinking Water Act, and found that injection and hydraulic fracturing activity was occurring within the same or neighboring geological zones as protected drinking water (Figure 2*).

*Reproduced from California Council on Science and Technology: An Independent Scientific Assessment of Well Stimulation in California Vol. 3.

More Exemptions to be Granted

Now, EPA is re-granting exemptions again. Six aquifer exemptions have been granted, and more are on the docket to be considered. In this second time around, it is imperative that regulatory agencies be more diligent in their oversight of this permitting process to protect groundwater resources. At the same time, the 2015 California bill SB 83 mandates the appointment of an independent review panel to evaluate the Underground Injection Control Program and to make recommendations on how to improve the effectiveness of the program. This process is currently in the works and a panel has been assembled, and FracTracker Alliance will be working to provide data, maps and analyses for this panel.

Stay tuned for more to come on which aquifers are being exempted, why, and what steps are being taken to protect groundwater in California.

Feature image by Pat Sullivan/AP


Groundwater risks in Colorado due to Safe Drinking Water Act exemptions

Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.

FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.

Learn more about Class II injection wells.

Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.

What exactly are aquifer exemptions?

The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.

Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more

Research shows injection wells do fail


Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.

Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.

Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.

A recent article by ProPublica quoted Mario Salazar, an engineer who worked for 25 years as a technical expert with the EPA’s underground injection program in Washington:

In 10 to 100 years we are going to find out that most of our groundwater is polluted … A lot of people are going to get sick, and a lot of people may die.

Also in the ProPublic article was a study by Abrahm Lustgarten, wherein he reviewed well records and data from more than 220,000 oil and gas well inspections, and found:

  1. Structural failures inside injection wells are routine.
  2. Between 2007-2010, one in six injection wells received a well integrity violation.
  3. More than 7,000 production and injection wells showed signs of well casing failures and leakage.

This means disposal wells can and do fail regularly, putting groundwater at risk. According to Chester Rail, noted groundwater contamination textbook author:

…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.

According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).

As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.

Will existing Class II wells fail?

For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!

Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.

It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.

Aquifer Exemptions in Colorado

According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.

Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.

Map 1. Aquifer exemptions in Colorado

View map fullscreen | How FracTracker maps work

Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.

In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.

Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.

When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.

You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.

Groundwater Monitoring Data Maps

Map 2. Water quality and depths of groundwater wells in Colorado
Groundwater risks in Colorado - Map 2
View live map | How FracTracker maps work

In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.

Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.

Map 3. Spatial “hot-spot” analysis of groundwater quality and depth of groundwater wells in Colorado
Groundwater risks in Colorado - Map 3
View live map | How FracTracker maps work

In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.

The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.

Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.

Site Assessments – Exploring Specific Regions

Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.

From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.

Wells with high or increasing levels of TDS are a red flag for potential contamination events.


Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.

Case of Increasing TDS Readings

If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)

The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.

This area deserves additional sampling and monitoring to assess whether contamination has occurred.

Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).

Groundwater Contamination Case in 2007

We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.

When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.


Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.



Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.


Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.

Areas where lack of data restricted analyses

In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.

Southeastern Colorado

Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.

In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.

Western Colorado

In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.

Northwestern Colorado

A crew from Bonanza Creek repairs an existing well in the McCallum oil field. Photo by Ken Papaleo / Rocky Mountain News

In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.

Trends and Future Development

Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.

These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.

This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.

Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.

Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.

The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.

Feature Image: Joshua Doubek / WIKIMEDIA COMMONS

Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance


October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.

Northeast Ohio Class II injection wells taken via FracTracker's mobile app, May 2015

What are aquifer exemptions? Permitted exemptions from the Safe Drinking Water Act

We’d like to give our readers a bit of background on aquifer exemptions, because we’re going to be covering this topic in a few upcoming blog posts. Stay tuned!

Liquid Waste Disposal

Drilling for oil and gas produces both liquid and solid waste that must be disposed of. The liquid waste from this industry is considered a “Class II waste” according to the US EPA. Aquifers are places underground capable of holding or transmitting groundwater. To dispose of Class II waste, operators are granted aquifer exemptions, by the EPA based on the state’s recommendations. The term “exemption,” specifically, refers to the Safe Drinking Water Act, which protects underground sources of drinking water (USDWs).

Therefore, these exemptions grant oil and gas operators the right to contaminate groundwaters, albeit many of the groundwater formations used for disposal in Class II wells are very deep.

Learn more about disposal well classes and aquifer exemptions on this story map by the US EPA

Aquifer Exemption Criteria

There are several qualifiers for a USDW to be granted exempt from the Safe Drinking Water Act. Aquifer exemptions are granted for underground formations that are not currently used as a source of drinking water and meet one of the following criteria:

  • The formation contains commercially producible minerals or hydrocarbons;
  • The formation is so deep that recovery of water for drinking water purposes is economically or technologically impractical; or,
  • The formation is so contaminated that it would be economically or technologically impractical to render the water fit for human consumption.
  • In some states, aquifer exemptions are not approved for formations with Total Dissolved Solids (TDS*) equal to or less than 3,000 mg/l TDS.

If an underground formation qualifies for an exemption, it does not mean that groundwater cannot be used for drinking water, just that it is not currently a source of drinking water. The most precarious criteria requirement, therefore, is the determination that a USDW is simply not “economically viable” or it is “technologically impractical,” meaning that the cost of drilling a groundwater well to the depth of the aquifer (under the condition of the current need for water) may make the investment impractical. In the near future, this water may be needed and highly valued, however.

TDS = Total dissolved solids are inorganic salts (e.g. calcium, magnesium, potassium, sodium, bicarbonates, chlorides, and sulfates), as well as some organic matter, dissolved in water.

The Lay of the Land

Below, we have put together a map of aquifer exemptions in the U.S. Click on the dots and shaded areas to learn more about a particular aquifer.

Map of all aquifer exemptions in the U.S.

View map fullscreen | How FracTracker maps work

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Radium Watersheds a Risk

By Greg Pace – Columbus Community Bill of Rights, and Julie Weatherington-Rice – Environmental Consultant


Figure 1. Map of Columbus, OH Watersheds and Class II Injection Wells

Most Ohio residents are unaware of the frack fluid deep underground injection occurring north of Columbus, underneath the region’s source water protection watersheds (Figure 1).

Materials injected are liquids that have as much as ten times the salt concentration of sea-water. Mixed with this “brine” solution is a combination from hundreds of chemicals that are used in different stages of horizontal hydraulic fracturing, the process used to extract natural gas, petroleum, and hydrocarbon liquids used to make industrial materials such as plastics. BTEX compounds including benzene are always present in the wastewater, along with formaldehyde, bromides, ethylene glycol (antifreeze), and arsenic, with many other carcinogenic and otherwise highly-toxic substances.

Radioactivity of Shale Gas Wastewater

One of the biggest questions in this mix of toxic disposal is how much radioactive content exists. Radium-226 is most worrisome, as it has a very long half-life (1,600 years). It is water-soluble and, once it enters the human body, seeks to find a home in our bones where it will emit its cell-formation-destabilizing effects for the remainder of our lifetime. This radionuclide is known to cause leukemia, bone cancers, blood disorders, and other diseases.

The state of Ohio does not monitor the content of materials that are injected into our Class II injection wells deep in the ground. This oil and gas waste can come from anywhere, including Pennsylvania’s Marcellus shale, which is the most highly-radioactive geology of all the shale plays in the country. Radium-226 readings as high as 15,000 pico-curies per liter have been read in Marcellus shale brines. The EPA drinking water limit for radium-226 is 5 pico-curies per liter, which puts the Marcellus reading at 3,000 times higher than the drinking water limit.

Exposure through drinking water is a pathway to human disease from radium-226. Once oil and gas waste is disposed of underground in a sandstone or limestone layer, the fluids are subject to down-gradient movement, wicking through capillary action, and seepage over time. This means that the highly radioactive wastewater could eventually end up in our underground drinking water sources, creating radium watersheds. This practice is putting our watersheds at risk from radioactive contamination for hundreds of years, at least.

Can injected fluids migrate?

Depending on whether you confer with a geologist who works with the oil and gas industry, or from an independent geologist, you will get a different opinion on the likelihood of such a pollution event occurring. Industry geologists mostly claim that deep injection leaves very low risk of water contamination because it will not migrate from the planned area of injection. On the other hand, independent geologists will tell you that it is not a matter of if the liquids will migrate, but how and when. The ability to confirm the geology of the underground area layer of injection “storage” is not exact, therefore accuracy in determining the probability for migration over time is poor.

Figure 2. Ohio Utica Brine Production and Class II Injection Well Disposal
View Map Fullscreen | How FracTracker maps work

We do know, however, that all underground systems in Ohio leak – Research by The Ohio State University and the US Geological Survey show that the age of the water in brine formations is far younger than the age of the rock deposits they are found in. See where wastewater is being created and disposed of in Ohio using the dynamic map above (Figure 2).

Spill Risks to Columbus, OH Water

According to area geologist, Dr. Julie Weatherington-Rice, the source for Columbus’s water to the north is mostly from surface water. This water comes from the Delaware and Morrow county watersheds that feed into sources such as the Hoover and Alum Creek reservoirs. The major threat from injection wells to our watershed is from spills, either from trucks or from storage at the injection well sites themselves.

Dead fish floating in Vienna area pond contaminated by injection well system spill Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

Figure 3. Dead fish floating in Vienna area pond contaminated by injection well system spill. Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

In April 2015, as much as 8,000 gallons of liquid leaked from a malfunctioning pipe in the storage apparatus of an oil/gas waste storage and injection well site in Vienna, OH. This caused a wildlife kill in two ponds (Figure 3), and the spill was not contained until 2/3 mile downstream in a tributary. The firm who owned the facility was found negligent in that they did not install a required containment liner for spills. The incident was discovered by neighboring residents, but apparently employees knew of the leak weeks before. Of note in this incident was that Ohio Department of Natural Resources, the regulatory agency that oversees all oil/gas production activity in Ohio including injection, stated that there was “minimal impact to wildlife.”

Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

Figure 4. Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

In March, 2016, a tanker truck carrying produced waste from a hydraulically fractured well pad overturned outside of the Village of Barnesville, Ohio (Figure 4). The truck spilled 5,000 gallons of liquid waste into a field that led into a tributary, leading the fluids to enter one of the city’s three drinking water supply reservoirs. The water source was shut down for more than two months while regulators determined if water levels were safe for consumption. There was a noted spike in radium-226 levels during water testing immediately after the spill.

Of greatest concern is that, although many millions of gallons of frack waste have been injected into the wells north of Columbus over the past few years, we expect that this activity will increase. For the first time, the United States began exporting its own natural gas in 2016, to regions such as Europe and South America. As the industry consolidates from the depression of oil prices over the past two years and begins to ramp up again, we expect the extraction activity in the Marcellus and especially Utica to increase to levels beyond what we have seen since 2011. The levels of injection will inevitably follow, so that injection wells in Ohio will receive much more than in the past. The probability of spills, underground migration, and human-induced earthquakes may increase steeply, as well.

An Aging Disposal Infrastructure

On our Columbus Community Bill of Rights website, we show pictures of some of the Class II injection wells in Morrow County, most of them converted from legacy production wells. These old wells are located in played out oil/gas fields that may still be producing or have abandoned but not plugged (closed) wells, allowing other routes for injected liquids to migrate into shallow ground water and to the surface. The dilapidated condition of these converted Class II wells makes it hard to believe that they are used to inject millions of gallons of wastewater under high pressure. While many of the wells in the state are as deep as 9,000 feet, all of the injection wells we have seen in Morrow County are only 3,000-4,000 feet deep. This situation puts surface water at greater risk over time, as it is probable that, over the generations, some of the fluids will migrate and wick into the higher subterranean strata.

Figure 5. Ohio Class II Injection Wells by Type
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One well (Power Fishburn unit, photo below) showed signs of poor spill control when we took our October 2015 injection well tour. While we were there, a brine tanker arrived and began pumping their load into the well. The driver took pictures of our license plates while we were there watching him. A year later, there is a whole new structure at the well, including a new storage tower, and an extensively beefed-up spill control berm. Maybe we need to visit all of the facilities when they come by to use them!

Another well (Mosher unit, photo below) which hadn’t been used since 2014 according to available records, showed signs of a spill around the well. The spill control berms look as if they probably had flooded at some point. This well sits on the edge of a large crop field.

Figures 6a and 6b. Photos of Class II injection wells. Click on the images to expand them.

North of Columbus, the city of Delaware’s underground source water is at risk of becoming contaminated from underground migration of disposed wastewater over time, through wicking and seepage effects (as explained earlier in this article). They are also vulnerable to their reservoir being contaminated from surface spill migration through their watershed.

Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

Figure 7. Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

South of Columbus is another threat – drill cuttings from the drilling process have been authorized for disposal at a “remediation” landfill adjacent to the Alum Creek (Figure 7). The bioremediation treatment used is not indicated to solve the problem of removing radionuclides from the materials. This landfill had been remediated under the Ohio EPA twice when it was a toxic drum dump, after toxins were found to have been leaching into the watershed creek. Columbus’s Alum Creek well, as well as Circleville, are at risk of contamination in their drinking water if radionuclides from the cuttings leach into Alum Creek. Again, this is a long-term legacy of risk to their water.

Radiation Regulatory and Monitoring Gaps

Since The Ohio legislature deemed the radioactive content of shale cuttings to be similar to background levels in the 2013 state budget bill, cuttings can be spread around to all licensed landfills in Ohio with absolutely no accountability for the radium and other heavy metal levels in them. Unfortunately, the measuring protocol used in the pilot study for the Columbus facility to demonstrate to Ohio EPA that radium-226 was below EPA drinking water limits has been shown in a University of Iowa study to be unreliable.  The inadequate protocol was shown to indicate as little as 1% of the radium levels in shale waste samples tested.

As such, there have been hundreds of incidents where truckloads of cuttings have been turned away at landfills with crude radiation monitors. In 2013 alone, 2 loads were turned away in Ohio landfills, and over 220 were turned away from Pennsylvania landfills.

Ohio has a long way to go before it can be considered a clean energy state. The coal industry polluted significant water sources in the past. The fracking industry seems to be following suit, where contaminations will surprise us long into the future and in broader areas.

Map Data for Download

For schools and hospitals analysis, 2017

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

Utica Class II Injection
Well Distance (Miles) Schools Medical Facilities Schools Medical Facilities
0.5 3 1 9 0
0.5-1 19 (22) 9 (10) 16 (25) 13 (13)
1-2 79 (101)  41 (51) 88 (113) 79 (92)
2-3 84 (185) 49 (100) 165 (278) 122 (214)
3-4 85 (270) 79 (179) 168 (446) 112 (326)
4-5 92 (362) 63 (242) 196 (642) 166 (492)
5-10 388 (750) 338 (580) 796 (1,438) 584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.

Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).

Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

Utica Class II Injection
Well Distance (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 3 1,360 453 7 3,312 473
<1 21 7,910 377 19 7,984 420
<2 96 35,390 376 90 41,565 462
<3 169 67,713 401 215 104,752 487
<4 241 97,448 404 350 176,067 503
<5 317 137,911 435 505 254,406 504
<10 600 280,330 467 1,126 569,343 506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.

Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

Utica Class II Injection
Distance from Well (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 . . . 1 . .
<1 . . . 2 25 13
<2 2 22 11 9 186 21
<3 7 874 125 30 4,460 149
<4 12 1,912 159 45 6,303 140
<5 21 2,471 118 61 9,610 158
<10 60 6,727 112 135 20,836 154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.


Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

Marcellus Class II Injection
Distance from Well (Miles) # Sum Avg # Sum Avg
0.5 19 5,674 299 1 . .
<1 52 (71) 16,992 (22,666) 319 5 (6) 1,544 257
<2 169 (240) 52,737 (75,403) 314 16 (22) 5,032 (6,576) 299
<3 133 (373) 36,112 (111,515) 299 18 (40) 6,132 (12,708) 318
<4 88 (461) 25,037 (136,552) 296 21 (61) 5,235 (17,943) 294
<5 56 (517) 15,685 (152,237) 295 26 (87) 8,913 (26,856) 309
<10 118 (635) 37,131 (189,368) 298 228 (315) 69,339 (96,195) 305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.


A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

  1. their role in induced seismicity,
  2. potential water and air quality issues, and
  3. concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Koontz Class II Injection Well, Trumbull County, Ohio, (41.22806065, -80.87669281) with 260,278 barrels (10,020,704 gallons) of fracking waste having been processed between Q3-2010 and Q3-2012 (Note: Q1-2016 volumes have yet to be reported!).

Ohio Shale Activity, Waste Disposal, and Public Water Supplies

Ohio is unique relative to its Appalachian neighbors in the Marcellus and Utica Shale Basins in that The Buckeye State chose to “diversify” when it came to planning for the hydraulic fracturing revolution. One of the first things financial advisers tell their clients is to “diversify, diversify, diversify.” However, this strategy is usually meant to buffer investors when certain sectors of the economy underperform. Columbus legislators took this strategy to mean that we should drill and hydraulically fracture our geology to extract oil and gas (O&G), as well as taking in vast quantities of liquid and solid O&G waste from Pennsylvania and West Virginia.

Accepting significant quantities of out-of-state waste raises several critical questions, however. How will these materials will be contained? Will such volumes require more and larger waste landfills? And will the injection of liquid brine waste into our geology (photo below) make Ohio the “Oklahoma of Appalachia” with respect to induced seismicity?

Above: Example Class II salt water disposal (SWD) wells in Ohio

Risks to Public Water Supplies

There are also mounting concerns about public water supply (PWS) security, quality, and resilience. These concerns stem from the growing uncertainty surrounding the containment of hydraulically fractured and Class II injection wells.

To begin to assess the risks involved in locating these wells near PWS’s, we compiled and incorporated as many of the state’s PWS’s into our primary Ohio maps. In this post, we explore PWS proximity to Utica drilling activity and Class II salt water disposal (SWD) wells in Ohio.

Waste Disposal & Drilling Near PWS’s

Public water chartJust how close are public water supplies to Class II waste disposal wells and permitted Utica wells? As of January 15, 2017, there are 13 PWS’s within a half-mile of Ohio’s Class II SWD wells, and 18 within a half-mile of permitted Utica wells. These facilities serve approximately 2,000 Ohioans each, with an average of 112-153 people per PWS (Tables 1 and 5). Within one mile from these wells there are 64 to 66 PWSs serving 18 to 61 thousand Ohioans. That’s an average of 285-925 residents.

Above: Photos of SWD wells from the sky

While PWSs on the 5-mile perimeter of our analysis don’t immediately conjure up water quality/quantity concerns, they may in the future; the rate of Utica and Class II permitting is likely to accelerate under a new White House administration more friendly to industry and averse to enforcing or enhancing regulatory hurdles.

A total of 960 and 699 PWSs are currently within five miles of Ohio Class II and Utica wells. These facilities service roughly 1.5 million and one-half million Ohioans each day, which is ~13% and 4% of the state, respectively. The average PWS within range of Class II wells is 37% to 330 times the average PWS within range of Utica wells.

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Fifty-eight (58%) to 69% of the PWSs within range of Class II wells are what the Ohio EPA calls Transient Non-Community (TNC) (Table 2). TNC’s are defined by the OH EPA and OH Department of Agriculture as serving[1]:

…at least 25 different persons over 60 days per year. Examples include campgrounds, restaurants and gas stations. In addition, drinking water systems associated with agricultural migrant labor camps, as defined by the Ohio Department of Agriculture, are regulated even though they may not meet the minimum number of people or service connections.

Meanwhile 60-89% of PWS’s in the shadow of Ohio’s permitted Utica wells are of the TNC variety. Even larger percentages of these PWS’s are either Groundwater or Purchased Groundwater types. Most of the PWS’s within the range gradient we looked at are privately owned, with only handful owned by federal or state agencies (Table 6).

Above: Example Class II salt water disposal (SWD) wells in Ohio

Of the 24 hydrologic unit codes (HUCs)/watersheds that contain Class II SWD wells, the lion’s share of PWS’s within the shadow of injection wells are the Tuscarawas, Mahoning, and Walhonding (Table 3). Even the Cuyahoga River, which feeds directly in the Great Lakes, is home to up to 138 PWS’s within 5 miles of Class II SWD wells. Conversely, only 13 HUCs currently contain Ohio’s Utica wells. Like Class II-affected HUCs, we see that the Mahoning, Tuscarawas, and Cuyahoga PSW’s contain most of the PWSs of interest (Table 7).


Watershed security/resilience concerns are growing in Eastern Ohio. Residential and agricultural water demands are increasingly coming into conflict with the drilling industry’s growing freshwater demand. Additionally, as oil and gas drilling uses more water, we will see more brine produced (Figures 1 and 2).

This, in turn, will create more demand – on top of an already exponential trend (Figure 3) – for Ohio’s existing Class II wells from across Northern Appalachia, stretching from Southeast Ohio and West Virginia to North Central Pennsylvania.

An understanding of the links between watershed security, O&G freshwater demand, brine production, and frack waste disposal is even more critical in areas like Southeast Ohio’s Muskingum River Watershed (Figure 4).

A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz, E. 2015

Figure 4. A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz and Auch 2015

This is a region of the state where we have seen new water withdrawal agreements like the one below between the Muskingum River Watershed Conservancy District (MWCD) and Antero described in last week’s Caldwell Journal-Leader, Noble County, Ohio:

The [MWCD], which oversees 10 lakes in east central Ohio, approved a second short-term water sale from Seneca Lake last week. The deal, with Antero Resources, Inc., could net the district up to $9,000 a day over about a three month period, and allows Antero to draw up to 1.5 million gallons of water a day during the months of August, September and October for a total of 135 million gallons; less than one percent of the lake’s estimated volume of 14.2 billion gallons. Antero plans to use the water in its fracking operations in the area and will pay $6 per 1000 gallons drawn.

Consol Energy's Cowgill Road Impoundment, Sarahsville, Wills Creek, Noble County, Ohio, 39.8212, -81.4061

Consol Energy’s Cowgill Road Impoundment, Sarahsville, Wills Creek, Muskingum River Watershed, Noble County, Ohio, 39.8212, -81.4061

This agreement will mean an increase in new Class II SWD permits and/or discussion about converting Ohio’s thousands of other Class II wells into SWD wells. What does this change means for communities that have already seen the industry extract the equivalent of nearly 14% – and even 25-80% in several counties – of residential water from their watersheds, only to inject it 6,000+ feet into the state’s geology is unknown? (Figure 5)

It is critical that we establish and frequently revisit the spatial relationship between oil and gas infrastructure the water supplies of Appalachian Ohio. The state of national politics, federal agency oversight and administrations, growing concerns around climate change, and the fact that Southeast Ohio is experiencing more intense and infrequent precipitation events are testaments to that fact. We will be tracking these changes to Ohio’s landscape as they develop. Stay tuned.

Kleese Disposal Class II Salt Water Disposal Well, Trumbull County, Shenango/Mahoning River, 41.244, -80.641, 3,548,104 Barrels of Waste Disposed Between 2010 and Q3-2016

Kleese Disposal Class II Salt Water Disposal well from the sky, Trumbull County, Shenango/Mahoning River, 41.244, -80.641. Data suggest 3,548,104 barrels of waste have been disposed of there between 2010 and Q3-2016.

Supplemental Tables

Public Water and Class II Wells

Table 1. Number of Ohio public water supplies and population served at several intervals from Class II Injection wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 13 1,992 153 (±120) 446
<1 66 60,539 917 (±4,702) 37,456
<2 198 278,402 1,406 (±4,374) 37,456
<3 426 681,969 1,601(±8,187) 148,000
<4 681 1,086,463 1,596 (±8,284) 148,000
<5 960 1,450,865 1,511 (±7,529) 148,000


Table 2. Ohio public water supplies by system type, source, and ownership at several intervals from Class II Injection wells


Well Distance (Miles)

System Type† Source†† Ownership






















0.5 3 9 1 13 13
<1 11 47 8 65 1 61 5
<2 30 118 50 177 16 5 164 34
<3 76 245 105 385 32 8 351 75
<4 122 392 167 628 40 12 574 106 1
<5 162 564 234 878 30 32 19 823 135 1 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water


Table 3. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from Class II Injection wells


HUC Name

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula-Chagrin, 799 1 5 18 18 22
Black-Rocky, 859 1 1 2 2 9
Cuyahoga, 832 1 8 20 92 92 138
Grand, 811 12 30 71 71 81
Hocking, 1081 4 18 18 22
Licking, 1010 1 2 17 17 29
Little Muskingum-Middle Island, 1062 1 2 2 6
Lower Maumee, 856 2 2 4
Lower Scioto, 1091 6 6 9
Mahoning, 831 9 17 48 129 129 161
Mohican, 919 1 3 3 4
Muskingum, 1006 1 3 15 15 33
Raccoon-Symmes, 1128 1
Sandusky, 862 3 19 19 27
Shenango, 815 1 2 6 10 10 11
St. Mary’s, 934 3 5 5 7
Tiffin, 837 4 4 7
Tuscarawas, 889 1 9 76 147 147 213
Upper Ohio, 901 3 15 15 23
Upper Ohio-Shade, 1120 4 8 8 9
Upper Ohio-Wheeling, 984 1 1 4 4 5
Upper Scioto, 959 5 13 13 23
Walhonding, 906 1 11 26 69 69 101
Wills, 1009 2 3 12 12 14


Table 4. Ohio public water supplies by county at several intervals from Class II Injection wells



Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 4 9 16 19 22
Athens 1 2 2 3
Auglaize 3 5 5 7
Belmont 1 4 5 6
Carroll 2 9 20
Columbiana 1 2 6 13 20 32
Coshocton 7 8 10 13
Crawford 1
Cuyahoga 1
Delaware 1
Fairfield 4
Franklin 1 3 7
Fulton 2 4 8
Gallia 1
Geauga 8 19 33 60 71
Guernsey 2 4 10 11 11
Harrison 1 1
Henry 2 3 3
Henry 2 3
Hocking 3 10 11 13
Holmes 1 11 34 25 38 47
Jefferson 1 3 3 5
Knox 2 6 8 9
Lake 1 4 7 17 18
Licking 1 2 10 14 26
Lorain 1 4
Mahoning 3 4 13 25 37 48
Medina 1 1 1 2 5
Meigs 4 5 6 7
Morgan 1 1 1 6 17
Morrow 3 8 11 11
Muskingum 3 8 15
Noble 1 2 2 3
Perry 5 6 8
Pickaway 2 3 7 10
Portage 3 12 41 62 90 113
Seneca 1 12 17 21
Stark 1 4 20 52 121 161
Summit 2 12 26 51
Trumbull 3 7 24 32 45 61
Tuscarawas 6 10 22 24 26
Washington 1 2 4 9
Wayne 1 1 9 18 24 54
Wyandot 2 2 2 3

Public Water and Hydraulically Fractured Wells

Table 5. The number of Ohio public water supplies and population served at several intervals from hydraulically fractured Utica Wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 18 2,010 112 (±72) 31
<1 64 17,879 279 (±456) 2,598
<2 235 116,682 497 (±1,237) 8,728
<3 433 257,292 594 (±2,086) 29,787
<4 572 380,939 666 (±2,404) 29,787
<5 699 496,740 711 (±2,862) 47,348


Table 6. Ohio public water supplies by system type, source, and ownership at several intervals from hydraulically fractured Utica Wells


Well Distance (Miles)

System Type† Source†† Ownership






















0.5 1 16 1 17 1 18
<1 9 45 10 59 3 1 1 58 6
<2 50 137 48 216 6 3 10 206 29
<3 83 265 85 400 14 5 14 381 51 1
<4 109 352 111 534 16 7 15 504 67 1
<5 141 421 137 652 19 9 18 621 77 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water



Table 7. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from hydraulically fractured Utica wells


HUC Name

Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Black-Rocky, 859 1 4 4 4
Cuyahoga, 832 2 12 31 54 82
Grand, 811 1 15 18 23
Licking, 1010 2 2 3 3
Little Muskingum-Middle Island, 1062 2 5 10 11 11
Mahoning, 831 2 5 48 105 142 175
Muskingum, 1006 3 7 9 11
Shenango, 815 2 5 10 13 14
Tuscarawas, 889 8 28 87 140 178 220
Upper Ohio, 901 7 20 45 66 72 73
Upper Ohio-Wheeling, 984 1 13 23 27 28
Walhonding, 906 10 15 34 47
Wills, 1009 2 3 5 7 8



Table 8. Ohio public water supplies by county at several intervals from hydraulically fractured Utica wells



Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 1 1
Belmont 1 2 7 14 15 16
Carroll 6 20 36 43 43 43
Columbiana 4 15 45 72 80 81
Coshocton 7 10 10
Geauga 14 20 25
Guernsey 1 1 2 4 5
Harrison 2 6 16 16 16 16
Holmes 5 13 31 43
Jefferson 2 3 11 22 25 25
Knox 1 1 2 2
Licking 1 1 1 1
Mahoning 2 10 32 44 55
Medina 1 4 5 7
Monroe 2 4 6 6 6
Muskingum 1 1 1 2 3
Noble 2 2 2 2
Portage 2 8 25 49 84
Stark 2 5 40 85 110 122
Summit 6 10
Trumbull 3 23 36 53 65
Tuscarawas 1 2 15 22 28 43
Washington 3 10 12 13
Wayne 5 5 7 21


  1. Community (C) = serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. Examples include cities, mobile home parks and nursing homes; Non-Transient, Non-Community (NTNC) = serve at least 25 of the same persons over six months per year. Examples include schools, hospitals and factories.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Power Plants & Other Facilities Now on Ohio Oil & Gas Map

Over the last few months we’ve been busy working on some updates to our Ohio Oil & Gas Map. Check out what we’ve added recently and explore the map below!

New: Power Plants & ATEX Pipeline

We now have the locations of eight of the credible natural gas power plants proposed in Ohio, along with the jobs they cite during construction and operations. We also now have a complete inventory of 118 existing power plants, including 25 natural gas facilities. Together, these plants would produce 7,660 megawatts, around 957 per facility.

Six of these plants are either in the heart of Ohio’s Utica Shale or within several miles of the 1,200+ mile Appalachia-to-Texas (ATEX) pipeline. ATEX was installed to transport 190,000 barrels per day (BPD) of natural gas liquids (NGLs) from the Marcellus and Utica region to the Texas and Louisiana Gulf Goast refinery corridor. The 360 mile segment of this pipeline that runs from Pennsylvania to south central Jackson County, Indiana is also now shown on the Ohio Oil & Gas Map.

Late Permitting Increases

Cumulative and Monthly Ohio Utica Hydraulic Fracturing Well Permits

Figure 1. Cumulative and monthly hydraulic fracturing well permits in Ohio’s Utica Shale

While many shale plays across the United States are experiencing a period of contraction (with low gas prices often cited as the primary reason), drilling activity in Ohio’s Utica Shale has been experiencing a slow and steady expansion. The region has seen more than 2,700 permitted wells as of the end of January 2017. Incidentally, roughly 59% of these wells are producing either oil or gas as of Q3-2016. For more information on that subject, explore our production map.

The permitting trajectory hit a low of 13-16 permits per month between February and January of 2016. Since the presidential election in November, however, permitting rates have more than doubled (Figure 1).

Ohio Oil & Gas Map

Ohio sits on the western edge of both the Utica and Marcellus Shale formations, but conditions are such that the Marcellus Shale is all but being ignored in Ohio. Explore our updated map of OH drilling activity and related facilities below:

View map fullscreen | How FracTracker maps work

Map Layers

The map above is made up of various datasets, from the location of permits to compressor stations. These “map layers” make up the legend. Below we describe each layer on the map, as well as the data source and date range.

Horizontal Marcellus Permits, Laterals
There have been 40+ permits issued for horizontal wells in Ohio’s Marcellus Shale.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

Horizontal Utica Permits
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time Ohio is home to 2,160+ permitted Utica Wells with the wells broken out by status. Additionally this layer contains depth, water usage, sand usage, HCl, and Gelling Agent percentage for 249 wells based on data provided to FracFocus. Finally, we have incorporated production in various units from individual industry press releases and the ODNR annual report.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

Horizontal Utica Permits actual and straight line laterals
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time we have straight line laterals for all drilled, drilling, and producing wells as well as actual PLAT laterals for 341 of the wells.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

High Volume Hydraulic Fracturing Gathering Lines
All gathering lines servicing Ohio’s inventory of High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

High Volume Hydraulic Fracturing Well Pads
The well-pads of all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

High Volume Hydraulic Fracturing Well Pad’s Limits Of Disturbance (LOD)
Limits Of Disturbance (LOD) for all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) well-pads.

Source: Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

Compressor Stations and Cracking Facilities
Boundaries of several confirmed High Volume Hydraulic Fracturing (HVHF) servicing cracking and compressor station facilities.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

Ohio Active Class II Injection Wells
This data speaks to the state’s “Active” Class II Injection wells able to accept hydraulic fracturing waste. There are 240+ Active Wells with 51 having yet to receive waste from hydraulic fracturing. For more on Ohio’s Class II Inventory in depth refer to our recent Ohio Fracking Waste Transport & Disposal Network article.

Source:   Ohio Department of Natural Resources
Date Range:  Historical to October, 2015

Earthquakes of >2.0 Magnitude
This data speaks to the state’s 258 earthquakes with current updates from the Ohio Seismic Network and historical quakes – all >2.0 magnitude. These data come from the department’s inventory. Additionally, we present Ohio earthquakes with <2.0 magnitude courtesy of Environment Canada’s Search the Earthquake Database platform.

Source: Ohio Department of Natural Resources, Division of Geological Survey, The Ohio Seismic Network
Date Range:  Historical to Present


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