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Community Sentinel Award for Environmental Stewardship

Four environmental stewards receive the 2018 Community Sentinel Award

WASHINGTON, DC – As oil and gas representatives descend on Pittsburgh this week for the annual Shale Insight conference, four advocates working to protect their communities from the harms of oil and gas development have been selected to receive the 2018 Community Sentinel Award for Environmental Stewardship, coordinated by FracTracker Alliance:

  • Ellen Gerhart – Pennsylvania
  • Natasha Léger – Colorado
  • Rebecca Roter – Pennsylvania, now Georgia
  • Youth award: Nalleli Cobo – California

This year’s recipients have founded grassroots organizations to protect communities from nearby drilling, paired traditional advocacy with scientific savvy, protested pipelines on land taken by eminent domain, and organized to stop urban drilling despite persistent health problems related to the drilling activity.

“The impacts of the oil and gas industry are visible across the United States, but hope abounds in the volunteers working in their communities and cherished places to document, report, and confront fossil fuel harms,” remarked Brook Lenker, Executive Director of FracTracker Alliance. “We are proud to honor Ellen, Natasha, Rebecca, and Nalleli this year, whose noble actions exemplify the transformative power of caring, committed, and engaged people.”

These four steadfast advocates were nominated by peers and selected by a committee of community defense leaders: Raina Rippel of Southwest Pennsylvania Environmental Health Project (Pennsylvania); Dan Shaffer of Allegheny-Blue Ridge Alliance and Dominion Pipeline Monitoring Coalition (Virginia); Dan Xie of Student PIRG (Florida); Jill Hunkler- Native American activist (Ohio); and Elena Sorokina of Crude Accountability (Washington, DC).

The award recipients will each receive $1,000 for their efforts and be recognized at an evening reception at the Renaissance Pittsburgh Hotel in Pittsburgh, Pennsylvania on Monday, November 26, 2018. The reception will also recognize heroes of the movement who recently passed away. Purchase tickets ($40).

This year’s major Community Sentinel sponsors include 11th Hour Project, The Heinz Endowments, and Foundation for Pennsylvania Watersheds. Award partners (to date) include Allegheny-Blue Ridge Alliance, Breathe Project, Center for Coalfield Justice, Crude Accountability, Earthworks, Food & Water Watch, Halt the Harm Network, Ohio Valley Environmental Coalition, Pipeline and Property Rights Center, Save the Hills Alliance, Sierra Club, Southwest Pennsylvania Environmental Health Project, and Viable Industries. View current sponsors and partners.

To learn more about the fourth annual Community Sentinel Award for Environmental Stewardship and to purchase tickets to the reception on November 26th, please visit: fractracker.org/sentinel-award.

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About FracTracker Alliance

FracTracker Alliance is a national non-profit with regional offices in California, New York, Ohio, Pennsylvania, Washington DC. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Learn more at fractracker.org.

Press Contact
For Release on October 24, 2018
Samantha Rubright
malone@fractracker.org (preferred)
(202) 630-6426

JOSHUA DOUBEK / WIKIMEDIA COMMONS

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

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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.

Methods

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.

co_classiipetition

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.

 

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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.

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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

http://digital.denverlibrary.org/cdm/ref/collection/p16079coll32/id/346073

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.

Heavy equipment moves debris from the site of a house explosion April 17 in Firestone, Colo., which killed two people. (David Kelly / For The Times)

Risks from Colorado’s Natural Gas Storage and Transmission Systems

Given recent concerns about underground natural gas storage wells (UGS), FracTracker mapped UGS wells and fields in Colorado, as well as midstream transmission pipelines of natural gas that transport the gas from well sites to facilities for processing. Results show that 6,673 Colorado residents in 2,607 households live within a 2.5 mile evacuation radius of a UGS well. Additionally, the UGS fields with the largest number of “single-point-of-failure” high-risk storage wells are also the two fields in Colorado nearest communities.

Worst Case Scenario

A house exploding from a natural gas leak sounds straight out of a 19th century period drama, but this tragedy just recently occurred in Firestone, Colorado. How could this happen in 2017? We have seen pictures and read reports of blowouts and explosions at well sites, and know of the fight against big oil and natural gas pipelines across the country. At the same time we take for granted the natural gas range that heats our food to feed our families. The risk of harm is seemingly far removed from our stove tops, although it may be much closer to home than we think – There are documented occupational hazards and compartmentalized risks in moving natural gas off site.

Natural gas is an explosive substance, yet the collection of the gas from well sites remains largely industry-regulated. Unfortunately, it has become clear that production states like Colorado are not able to provide oversight, much less know where small pipelines are even located. This is particularly dangerous, since the natural gas in its native state is ordorless, colorless, and tasteless. Flowing in the pipelines between well sites and processing stations, natural gas does not contain the mercaptan that gives commercial natural gas its tell-tale odor. In fact, much of the natural gas or “product” is merely lost to the atmosphere, or much worse, can collect in closed spaces and reach explosive levels. This means that high, potentially explosive levels of methane may go undetected until far too late.

Mapping Flow Lines

As a result of the house explosion in Firestone on April 17th CO regulators are now requiring oil and gas operators to report the location of their collection flow pipelines, as shown in Figure 1.

Figure 1. Map of Gathering Pipeline “Flowlines”

View map fullscreen

The locations of the collection of pipeline “flowlines”, like the uncapped pipeline that caused the house explosion in Firestone, have been mapped by FracTracker Alliance (above). The dataset is not complete, as not all operators complied with the reporting deadline set by the COGCC. For residents living in the midst of Colorado’s oil and gas production zones, addresses can be typed into the search bar in the upper left corner of the map. Users can see if their homes are located near or on top of these pipelines. The original mapping was done by Inside Energy’s Jordan Wirfs-Brock.

Underground Storage

When natural gas is mixed with mercaptan and ready for market, operators and utility companies store the product in UGS fields. (EDIT – Research shows that in most cases natural gas in UGS fields is not yet mixed with mercaptan. Therefore leaks may go undetected more easily. Aliso Canyon was a unique case where the gas was being stored AFTER being mixed with mercaptan. Odorization is not legally required until gas moves across state lines in an interstate pipeline or is piped into transmission lines for commercial distribution.) In August 2016, a natural gas storage well at the SoCal Gas Aliso Canyon natural gas storage field failed causing the largest methane leak in U.S. history. The Porter Ranch community experienced health impacts including nosebleeds, migraines, respiratory and other such symptoms. Thousands of residents were evacuated. While Aliso Canyon was the largest leak, it was by no means a unique case.

FracTracker has mapped the underground natural gas storage facilities in Colorado, and the wells that service the facilities. As can be seen below, there are 10 storage fields in Colorado, and an 11th one is planned. All the fields used for storage in Colorado are previously depleted oil and gas production fields. The majority of storage wells used to be production wells. All sites are shown in the map below (Figure 2).

Figure 2. Map of Natural Gas Underground Storage Facilities

View map fullscreen | How FracTracker maps work

Impacted Populations

Our analysis of Colorado natural gas storage facilities shows that 6,673 Colorado residents living in 2,607 households live within a 2.5 mile evacuation radius of a UGS well. The majority of those Coloradans (5,422) live in Morgan County, with 2,438 in or near the city of Fort Morgan. The city of Fort Morgan is surrounded by the Young Gas Storage Facility with a working capacity of 5,790,049 MCF and Colorado Interstate Gas Company with a working capacity of 8,496,000 MCF.

By comparison, the failure in Aliso Canyon leaked up to 5,659,000 MCF. A leak at either of these facilities could, therefore, result in a similar or larger release.

UGS Well Risk Assessment

A FracTracker co-founder and colleague at Harvard University recently completed a risk assessment of underground natural gas storage wells across the U.S. The analysis identified the storage wells shown in the map above (Figure 1) and defined a number of “design deficiencies” in wells, including “single-point-of-failure” designs that make the wells vulnerable to leaks and failures. Results showed that 2,715 of the total 14,138 active UGS wells across the country were constructed using similar techniques as the Aliso Canyon failed well.

Applying this assessment to the wells in Colorado, FracTracker finds the following:

  • There are a total of 357 UGS wells in Colorado.
  • 220 of which are currently active.
  • Of those 220 UGS wells, they were all drilled between 1949 and 1970.
  • 43 of the UGS wells are repurposed production wells.
  • 40 of those repurposed wells are the highest risk single barrier wells.

Specifically focusing on the UGS fields surrounding the city of Fort Morgan:

  • 21 single barrier wells are located in the Flank field 2.5 miles North of the city.
  • 13 single barrier wells are located in the Fort Morgan field 2.5 miles South of the city.

We originally asked how something as terrible as Firestone could have occurred. Collectively we all want to believe this was an isolated incident. Sadly, the data suggest the risk is higher than originally thought: The fields with the largest number of “single-point-of-failure” high-risk UGS wells are also the two fields in Colorado nearest communities. While the incident in Firestone is certainly heartbreaking, we hope regulators and operators can use the information in this analysis to avoid future catastrophes.


By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Feature Image: Heavy equipment moves debris from the site of a house explosion April 17, 2017 in Firestone, Colorado, which killed two people. (David Kelly / For The Times)

US Farms and Agricultural Production near Drilling

Health vs. Power – Risking America’s Food for Energy

Over 50% of land in the United States is dedicated to agriculture. Oil and gas development, particularly hydraulic fracturing or “fracking,” is taking place near many of these farms.

Farms feed us, and unfortunately they are not protected from the impacts of fracking. Even if drilling can be done responsibly, accidents happen. In Colorado, for example, two spills occur on average per day, 15% of which result in water contamination. [1] Risking our food supply is not only a risk to our health – it’s a risk to national security.

Food Independence

Rocky Mountain Apple Orchard by Celia Roberts

Rocky Mountain apple orchard. Photo by Celia Roberts

Domestic oil and gas production has been promoted by the industry as a means to provide the U.S. with energy independence. The argument goes something like this: “We need to be a net exporter of energy so as to reduce our reliance on foreign countries for these resources, especially countries in the Middle East.” This ignores the point that for energy security we might want to keep rather than export fossil fuels.

However, energy independence and food independence are inextricably linked.

Considering that the basic human needs are clean water, food, shelter, and safety — along with energy — we need to think about self-reliance; we can’t be dependent on foreign countries for our food. The U.S. is currently a net exporter of agricultural products, and California produces 50% of the food consumed in the U.S. But what would happen if our foodsheds became contaminated?

Drilling Proximity – Why the concern?

Front Range, Colorado Working Landscape At Risk of Unconventional Oil & Gas Drilling by Rita Clagget

Front Range, Colorado working landscape at risk of unconventional oil & gas drilling. Photo by Rita Clagget

Over 58% of US agricultural market value and 74% of US farms – both conventional and organic – operate within shale basins, active shale plays, and the primary frac sand geologies.

Why is this so important? Why be concerned? Here are just a few reasons:

  1. People can be exposed to the compounds involved with oil and gas extraction through spills, emissions, and other processes. The top five health impacts associated with these chemicals are: respiratory, nervous system, birth defects, and reproductive problems, blood disorders, and cancer.[2]
  2. Rural gas gathering pipelines are unregulated; operators have no obligation to publicly report about incremental failures along the pipeline that may contaminate soil and water as long as they don’t require evacuations.[3]
  3. Oil and gas operators are exempt from certain provisions of several environmental laws designed to protect public health and safety, including the Safe Water Drinking Act, The Resource Conservation and Recovery Act, The Emergency Planning and Community Right-to-Know Act, The Clean Water Act, The Clean Air Act, and The Comprehensive Environmental Response, Compensation, and Liability Act. These exemptions, in a way, permit oil and gas operators to contaminate water supplies with chemicals from their operations, in particular hydraulic fracturing fluids and produced wastewater.[4]
  4. The gold standard of clean, chemical-free food is the USDA National Organic Program Standards, as governed by the Organic Foods Production Act. Unfortunately, organic certification does not require testing for oil and gas chemicals in water being used in organic production. The organic standard is satisfied as long as state, water, and food safety agencies deem the water safe. To our knowledge these agencies do not test for oil and gas chemicals.[5]
  5. Based on available data spills occur regularly. Recent research has identified that the mixture of chemicals from fracking fluid and produced wastewater interact in a way that can lead to soil accumulation of these chemicals. Potentially, then, the chemicals may be absorbed by plants.[6] Fifteen chemicals often used in fracking have been identified as toxic, persistent and fast-traveling.[7] Some farms – such as those in Southern California – are being irrigated with produced water from oil and gas operations. Additionally, every single farm in the San Jaoquin Valley is within eight miles of oil and gas operations.[8]
  6. There is significant Competition for water between natural gas production and agriculture. This includes growing commodity crops for energy, such as ethanol. Natural gas operations result in removing water quantity available for agriculture, and changing the water quality, which affects the agricultural product. In drought stricken areas, water scarcity is already an issue. In addition, extreme heat as a result of climate change is putting more stress on farmers operating in already depleted watersheds. Layered on all of this is the growing realization that precipitation regimes are gradually – and in many places dramatically – transitioning from many smaller and more predictable events to fewer, more intense, and less predictable rain and snow events which is are harder for the landscape to capture, process, and store for agricultural and/or other uses.
  7. Operating costs: Farmers are already operating under razor- thin margins, with the cost of inputs continually increasing and the resilience of the soils and watersheds they rely upon coming into question with unconventional oil and gas’ expansion across the Midwest and Great Plains.

Public Lands

Over 45% of lands in the Western United States are owned by the federal government. Opening up public lands—by the Bureau of Land Management, United State Forest Service in particular—is controversial on multiple levels. As it relates to food security and independence, the issue often missed is that many headwaters to prime farmland reside on federal lands, along with the majority of cattle grazing.

There isn’t enough private land in the West for oil and gas operators to reach their production goals. They have to drill on public lands in order to scale up production and develop an export market for domestic natural gas. This means that public lands, taxpayer funded public lands, could potentially be used to irreparably harm prime agricultural and grazing lands (foodsheds). More alarming, is that the Trump Administration is focused on unfettered development, extraction and distribution of natural gas resources, including opening up public lands to oil and gas leasing and gutting regulations that protect us from pollution and public health risks.

The map we have developed shows that many of the largest farms in the West are surrounded by public lands. Sixty-percent of Colorado farms are surrounded by public lands, which are within shale basins or active shale plays.  Four of the top natural gas producing counties in Colorado are also four of the top agricultural producing counties: Weld, Mesa, Montezuma, and LaPlata counties. The third, fifth, sixth, eighth and tenth agricultural producing counties in the State are surrounded by public lands within shale basins, respectively,: Larimer, Delta, El Paso, Montrose and Douglas counties. The 6,325 farms in these counties represent 17% of all Colorado farms, and 29% (nearly half) of Colorado at-risk farms for being surrounded by public lands and within shale basins.

Colorado: Public lands surround majority of farms.

Colorado: Public lands surround majority of farms.

Colorado: zoom into 3 of top agricultural producing and natural gas producing counties in Colorado, illustrating how they are surrounded by public lands.

Colorado: Map zoomed into 3 of top agricultural producing and natural gas producing counties in Colorado, illustrating how they are surrounded by public lands.

food-table

These farms, headwaters, and public lands need to be protected if we are to maintain food independence and security. Producing potentially contaminated food is neither food independence, nor food security.

Policy Implications

Why should policy makers and health insurers care? Chronic and terminal illnesses are on the rise. Healthcare costs have nowhere to go but up as long as the environment we live in, the food we eat, the water we drink, and the air we breathe continue to be polluted at such a large scale. Attempts to reduce healthcare costs by insuring all Americans will have no impact if they are all sick. The insurance model only works when there are more healthy people in the pool than unhealthy people.

Mapping Conventional & Organic U.S. Farms

Below is an interactive map showing agricultural production in the U.S. You can use the map to zoom in at the county level to understand better the type of agricultural production taking place, as well as the value of the agricultural products at the county level.

U.S. Conventional and Organic Farms and Their Productivity Near Shale Plays and Basins

View map fullscreen | How FracTracker maps work

This map excludes Alaska for a variety of reasons[9]. We include over 180 unique data points for each county across five categories: 1) Crops and Plants, 2) Economics, 3) Farms, 4) Livestock and Animals, and 5) Operators. We then break these major categories into 20 subcategories.

Table 1. Subcategories Utilized in the “US Shale Plays and Basins Along with Agricultural Productivity By County” map above

Categories Subcategories
Crops and Plants Field Crops Harvested
Fruits, Tree Nuts, Berries, Nursery and Greenhouse
Hay and Forage Crops Harvested
Seed Crops Harvested
Vegetables and Melons Harvested
Economics Buildings, Machinery and Equipment on Operation
Farm Production Expenses
Farm-Related Income and Direct Sales
Farms by Value of Sales
Market Value of Agricultural Products Sold
Farms Agricultural Chemicals Used
Farms
Farms by Size
Farms by Type of Organization
Land in Farms and Land Use
Livestock and Animals Livestock, Poultry, and Other Animals
Operators Characteristics of Farm Operators
Hired Farm Labor
Primary Occupation of Operator
Tenure of Farm Operators and Farm Operations

Analysis Results

In total, there are 589,922 and 1,369,961 farms in US Shale Plays and Basins, respectively, averaging between 589 and 646 acres in size and spread across 2,146 counties (Figure 1). These farm counties produce roughly $87.31- 218.32 billion in agricultural products each year with the highest value per-acre being the Monterey and Monterey-Temblor Formations of Southern California, the Niobrara Formation in North Central Colorado, Eastern Barnett in North Central Texas, the Antrim in Michigan, and the Northern Appalachian Shale Basins of Pennsylvania, New York, and Ohio (Figures 2a/2b). Roughly 52% of all agricultural revenue generated in US Shale Play counties comes from livestock, poultry, and derivative products vs. a national average of 44% (Figure 3).

Put another way, the value of US Shale Basin agricultural infrastructure would rank as the 9th largest economy worldwide, between Italy and Brazil.

Family-owned farms are at the greatest risk. While corporations tend to own larger acreage farms, only 8.2% of US farms are owned by corporations. This figure is nearly halved in US Shale Plays, with 4.5% of farms owned by corporations, or 95% owned by families or individuals.


Figures 1, 2a, 2b, and 3 above show the number of farms near drilling, as well as variations in the value of agricultural products produced in those regions.

Risk vs. Benefits in CO

Oil and gas activity is regulated on a somewhat patchwork basis, but generally it is overseen at the state level subject to federal laws. New York and Maryland are the only two states that ban fracking, while communities around the country have invoked zoning laws to ban fracking or impose moratoriums on a smaller scale. However, in Colorado, the Colorado Oil and Gas Conservation Commission has exclusive jurisdiction over oil and gas regulation in the State. There, fracking bans imposed by local communities, with a large number of farms, have been found to be unconstitutional by the Colorado Supreme Court.

Weld County is Colorado’s leading producer of cattle, grain, and sugar beets. Weld is the richest agricultural county in the U.S. east of the Rocky Mountains, the fourth richest overall nationally, and the largest natural gas producer in CO. Compare this to the North Fork Valley on the Western Slope of CO, which is home to the largest concentration of organic farms in the state, one of two viticultural (wine making) areas in the state, and has a reputation for being a farm-to-table hub. Delta County, in which the North Fork Valley is located, is known for its sustainable agriculture initiatives. Uniquely, Delta County is one of the few agricultural areas in the country so far untouched by the fracking boom – but that could all change. The Bureau of Land Management is considering opening 95% of BLM lands and minerals within and surrounding Delta County to oil and gas leasing.

Protecting Food Supplies

Oil and gas extraction is taking place on both private and public lands across the country. Prime and unique agricultural lands need to be protected from these industrial activities if we are to maintain food independence and ensure a healthy food supply. As demonstrated by the map above, agricultural communities in active shale plays may already in trouble. To prevent further damages on day-to-day food staples, it is imperative to increase awareness about this consequential issue.

How can people trust that the food they eat is safe to consume? Families trust farmers, food brands, school and office cafeterias, and restaurants to the extent that the food supply chain is regulated and maintained. If most of the food produced in the U.S. is within active shale plays, and the water/soil is not being tested for oil and gas chemicals, that supply chain is at risk. The secure production of our food – via clean air, water, and soil – is tantamount to lasting food independence.

Farming Testimonials

I am the leader of Slow Food Western Slope, which functions as a chapter of Slow Food USA. We envision a world in which all people can eat food that is good for them, good for the people who grow it and good for the planet: good, clean and fair food for all. Our chapter promotes and supports over 70 farmers, orchardists, ranchers, agricultural businesses and winemakers of the North Fork Valley – all of which depend on good and clean water, air and soil. With its industrial footprint and potential damage to landscape, air, water, soil and human health, extraction industries have no place in the future of the North Fork Valley. We can build a new economy around clean food, outdoor recreation, healthy lifestyle and small nonthreatening businesses.

Jim BrettSlow Food Western Slope

Agricultural land is much more valuable in the long-run than the short-term gains promised from oil and gas extraction… As farmers we are attuned to crop, soil, and water conditions especially as a result of weather. If it’s too hot, too dry, too wet, too cold then there is no food. Natural gas extraction is an undeniable factor in changing climate and is incompatible with the practice of sustainable agriculture.

Mark WaltermireOwner of Thistle Whistle Farm in Hotchkiss, CO

References and More Information

FracTracker Alliance raised awareness of this issue in 2015 when it mapped the proximity of organic farms to oil and gas wells. In that mapping analysis, it was discovered that 11% of organic farms are within ½ mile of oil and gas development. Did you know that less than 1% of agricultural lands in the United States are used to grow crops without chemicals, and that 42% of those organic farms produce food for human consumption?

Organic Farms Near Drilling Activity in the U.S.

View map fullscreen | How FracTracker maps work

This research prompted the question of what about the other 99% of agricultural lands used to grow crops and raise livestock utilizing chemicals and other conventional methods in the United States. The majority of dairy, grains, beef, poultry, fruits, vegetables, and animal feed for livestock are produced on conventional farms. Where are they located, and do we know how they are being impacted by oil and gas development?

The majority of the US population lives in urban centers and is disconnected from the American farm, including how and where food is produced. People trust their farmer, food brands, school and office cafeterias, and restaurants to the extent that they trust their supply chain, and to the extent that the farmers trust their water supply and soils. If the majority of the food produced in the U.S. is within active shale plays, and the water and soil are not being tested for oil and gas chemicals, this research questions how people can trust that their food is safe to consume. If we are to maintain our food independence and health, not only do consumers need to understand that the food supply is at risk in order to exercise their rights to protect it at the local, state, and federal levels, but policymakers need to be informed with this data to make better decisions around oil and gas development regulations and development proposals that impact our foodsheds.

References/Footnotes:

  1. 2015 Colorado Oil and Gas Toxic Release Tracker, Center for Western Priorities
  2. COMPENDIUM OF SCIENTIFIC, MEDICAL, AND MEDIA FINDINGS DEMONSTRATING RISKS AND HARMS OF FRACKING (UNCONVENTIONAL GAS AND OIL EXTRACTION), Fourth Edition, Physicians for Social Responsibility, November 17, 2016; Colborn T, Kwiatkowski C, Schultz K, Bachran M., Natural gas operations from a public health perspective, Human and Ecological Risk Assessment, 2011 17(5):1039-1056; Fracking Fumes: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities, NRDC Issue Brief, December 2014
  3. 49 CFR §192
  4. Brady, William J., Hydraulic Fracturing Regulation in the United States: The Laissez-Faire Approach of the Federal Government and Varying State Regulations, Vermont Journal of Environmental Law, Vol. 14 2012
  5. National Organic Program Standards, 7 CFR Part 205. Organic Foods Production Act, 7 U.S.C. Ch. 94
  6. Molly C. McLaughlin, Thomas Borch,, and Jens Blotevogel, Spills of Hydraulic Fracturing Chemicals on Agricultural Topsoil: Biodegradation, Sorption, and Co-contaminant Interactions, Environ. Sci. Technol. 2016, 50, 6071−6078
  7. AirWaterGas Sustainability Research Network, November 2016.
  8. Matthew Heberger and Kristina Donnelly, OIL, FOOD, AND WATER: Challenges and Opportunities for California Agriculture, Pacific Institute, December 2015.
  9. Issues with Alaskan agricultural data include incomplete reporting and large degrees of uncertainty in the data relative to the Lower 48.

By Natasha Léger, Interim Executive Director, Citizens for a Healthy Community and Ted Auch, Great Lakes Program Director, FracTracker Alliance

Oil and Gas Wastes are Radioactive – and Lack Regulatory Oversight

Highlighting the maps of radioactive oil and gas exploration and production wastes created in collaboration with the Western Organization of Research Councils

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
Scott Skokos, Western Organization of Research Councils

Oil and gas waste can be radioactive, but it is not considered “hazardous,” at least according to the federal government. In this article, we summarize several of the hazardous risks resulting from the current federal policy that fails to regulate this massive waste stream, and the gaps left by states. Of the six states mapped in this assessment, only the state of Montana has initiated any type of rule-making process to manage the waste.

When it comes to unconventional oil and gas waste streams:

Nobody can say how much of any type of waste is being produced, what it is, and where it’s ending up. – Nadia Steinzor, Earthworks

To address some of these gaps, FracTracker Alliance has been working with the Western Organization of Resources Councils (WORC) to map out exactly where radioactive oil and wastes are being dumped, stored, and injected into the ground for disposal. The work is an extension to WORC’s comprehensive No Time to Waste report.

Why is accurate waste data so hard to come by? The Earthworks report, Wasting Away explains that the U.S. EPA intentionally exempted oil and gas exploration and production wastes from the federal regulations known as the Resource Conservation and Recovery Act (RCRA) despite concluding that such wastes “contain a wide variety of hazardous constituents.” As a result, there is very little waste tracking and reporting of oil and gas waste data nationally.

State Waste Management Maps

Some data is available at the state level, so we at FracTracker have compiled, cleaned, and mapped what little data we could find.

State-specific maps have been created for Montana, North Dakota, Colorado, and Wyoming – see below:

ND Radioactive Waste mapNorth Dakota – View map fullscreen

co-radioactive-featureColorado – View map fullscreen

Sources of Radioactivity

When we hear about “radioactive waste” associated with the energy industry, nuclear power stations and fission reactors are usually what come to mind. But, as the EPA explains, fracking has transformed the nature of the oil and gas waste stream. Components of fracking waste differ from conventional oil and gas exploration and production wastes in a number of ways:

  • In general, the waste stream has additional hazardous components, and that transformation includes increased radioactivity.
  • Fracking has allowed for more intrusive drilling, penetrating deep sedimentary formations using millions of gallons of fluid.
  • Drilling deeper produces more drill cuttings.
  • The process of hydraulic fracking introduces millions more gallons of fluid into the ground that then return to the surface. These returns are ultimately contaminated and require disposal.
  • The formations targeted for unconventional development are mostly ancient seabeds still filled with salty “brines” known as “formation waters.”
  • In addition to the hazardous chemicals in the fracking fluid pumped into the wells for fracking, these unconventional formations contain larger amounts of heavy metals, carcinogens and other toxics. This also includes more radioisotopes such as Uranium, Thorium, Radium, Potassium-40, Lead-210, and Polonium-210 than the conventional formations that have supplied the majority of oil and gas prior to the shale boom.

A variety of waste products make up the waste stream of oil and gas development, and each is enhanced with naturally occurring radioactive materials (NORM). This waste stream must be treated and disposed of properly. All the oil and gas equipment – such as production equipment, processing equipment, produced water handing equipment, and waste management equipment – also need to be considered as sources of radioactive exposure.

Figure 1 below explains where the waste from fracking goes after it leaves the well pad.

Radioactive Oil and Gas Pathway Life Cycle

Figure 1. Breakdown of the radioactive oil and gas waste life-cycle

Three facets of the waste stream particularly enhanced with NORMs by fracking include scales, produced waters, and sludges.

A. Scales

When injected into the ground, fracking fluid mixes with formation waters, dissolving metals, radioisotopes and other inorganic compounds. Additionally the fracking liquids are often supplemented with strong acids to reduce “scaling” from precipitate build up (to prevent clogging up the well). Regardless, each oil well generates approximately 100 tons of radioactive scale annually. As each oil and gas reservoir is drained, the amount of scale increases. The EPA reports that lead-210 and polonium-210 are commonly found in scales along with their decay product radon at concentrations estimated to be anywhere from 480 picocuries per gram (pCi/g) to 400,000 pCi/g). Scale can be disposed of as a solid waste, or dissolved using “scale inhibitors.” These radioactive elements then end up in the liquid waste portion of the waste stream, known as produced waters.

B. Produced Waters

In California, strong acids are used to further dissolve formations to stimulate additional oil production. Acidic liquids are able to dissolve more inorganic elements and compounds such as radioisotopes. While uranium and thorium are not soluble in water, their radioactive decay products such as radium dissolve in the brines. The brines return to the surface as “produced water.” As the oil and gas in the formation are removed, much of what is pumped to the surface is formation water.

Consequently, declining oil and gas fields generate more produced water. The ratio of produced water to oil in conventional well was approximately 10 barrels of produced water per barrel of oil. According to the American Petroleum Institute (API), more than 18 billion barrels of waste fluids from oil and gas production are generated annually in the United States. There are several options for managing the liquid waste stream. The waste could be treated using waste treatment facilities, reinjected into other wells to enhance production (a cheaper option), or injected for disposal. Before disposal of the liquid portion, all the solids in the solution must be removed, resulting in a “sludge.”

C. Sludges

The U.S. EPA reports that conventional oil production alone produces 230,000 million tons – or five million ft3 (141 cubic meters) – of TENORM sludge each year. Unconventional processes produce much more sludge waste than conventional processes. The average concentration of radium in sludges is estimated to be 75 pCi/g, while the concentration of lead-210 can be over 27,000 pCi/g. Sludges present a high risk to the environment and a higher risk of exposure for people and other receptors in those environments because sludges are typically very water soluble.

Federal Exemptions

According to the EPA, “because the extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact, these wastes are classified as Technologically Enhanced Naturally Occurring Radioactive Material (TENORM).” Despite the conclusions that oil and gas TENORM pose a risk to the environment and humans, the EPA exempts oil and gas exploration and production wastes from the definition of “hazardous” under Resource Conservation and Recovery Act (RCRA) law. In fact, most wastes from all of the U.S. fossil fuel energy industry, including coal-burning and natural gas, are exempt from the disposal standards that hazardous waste normally requires.

The Center for Public Integrity calls this radioactive waste stream “orphan waste,” because no single government agency is fully managing it.

Fortunately, the EPA has acknowledged that federal regulations are currently inadequate, though this is nothing new. A U.S. EPA report from the 1980’s reported as much, and gave explicit recommendations to address the issue. For 30 years nothing happened! Then in August, 2015, a coalition of environmental groups (including the Environmental Integrity ProjectNatural Resources Defense CouncilEarthworksResponsible Drilling AllianceWest Virginia Surface Owners’ Rights Organization, and the Center for Health, Environment and Justice) filed a lawsuit against the EPA, and has since reached a settlement.

Just last month (January 10, 2017) the U.S. EPA agreed to review federal regulations of oil and gas waste – a process they were meant to do every 3 years for the last 30 years. The EPA has until March 15, 2019, to determine whether or not regulatory changes are warranted for “wastes associated with the exploration, development, or production of crude oil, natural gas, or geothermal energy.” With the recent freeze on all U.S. EPA grants, however, it is not clear whether these regulations will receive the review they need.

State Regulations

Regulation of this waste stream is left up to the states, but most states do not require operators to manage the radioactivity in oil and gas wastes, either. Because of the federal RCRA exemptions most state policies ignore the radioactive issue altogether. Operators are free to dispose of the waste at any landfill facility, unless the landfill tells them otherwise. For detailed analyses of state policies, see pages 10-45 of the No Time to Waste report. FracTracker has also covered these issues in Pennsylvania and Ohio.

Another issue that screams for federal consideration of this waste stream is that states do not have the authority to determine whether or not the wastes can cross their borders. States also do not have the jurisdiction to decide whether or not facilities in their state can accept waste from across state lines. That determination is reserved for federal jurisdiction, and there are not any federal laws regulating such wastes. In fact, these wastes are strategically exempt from federal regulation for just these reasons.

Why can’t the waste be treated?

This type of industrial waste actually cannot be treated, at least not entirely. Unlike organic pollutants that can be broken down, inorganic constituents of the waste cannot be simply disintegrated out of existence. Inorganic components include heavy metals like arsenic and bromides, as well as radioactive isotopes of radium, lead, and uranium. Such elements will continue to emit radiation for hundreds-to-thousands of years. The best option available is to find a location to “isolate” and dispose of these wastes – a sacrifice zone.

Current management practices do their best to separate the liquid portions from the solid portions, but that’s about it. Each portion can then be disposed independently of each other. Liquids are injected into the ground, which is the cheapest option where it is available. If enough of the dissolved components (heavy metals, salts, and radioisotopes) can be removed, wastewaters are discharged into surface waters. The compounds and elements that are removed from the liquid waste stream are hyper-concentrated in the solid portion of the waste, described as “sludge” in the graphic above. This hazardous material can be disposed of in municipal or solid waste landfills if the state regulators do not require the radioactivity or toxicity of this material to be a consideration for disposal. There are not federal requirements, so unless there is a specific state policy regarding the disposal, it can end up almost anywhere with little oversight. These chemicals do not magically disappear. They never disappear.

Risks

There are multiple pathways for contamination from facilities that are not qualified to manage radioactive and hazardous wastes. At least seven different environmental pathways provide potential risks for human exposure. They include:

  1. Radon inhalation,
  2. External gamma exposure,
  3. Groundwater ingestion,
  4. Surface water ingestion,
  5. Dust inhalation,
  6. Food ingestion, and
  7. Skin beta exposure from particles containing the radioisotopes.

According to the EPA, the low-level radioactive materials in drilling waste present a definitive risk to those exposed. High risk examples include dust suppression and leaching. If dust is not continuously suppressed, radioactive materials in dust pose a risk to people at these facilities or those receptors or secondary pathways located downwind of the facilities. Radioactive leachate entering surface waters and groundwaters is also a significant threat. A major consideration is that radioactive waste can last in these landfills far longer than the engineered lifespans of landfills, particularly those that are not designed to retain hazardous wastes.

Cases of Contamination

North Dakota

In North Dakota, the epicenter of the Bakken Oil Fields, regulators were not ready for the massive waste streams that came from the fast growing oil fields. This  allowed thousands of wastewater disposal wells be drilled to dispose of salty wastewater without much oversight, and no places in state for companies to dispose of radioactive solid waste. Many of the wastewater disposal wells were drilled haphazardly, and as a result many contaminated surrounding farmland with wastewater. With regard to radioactive solid waste, the state until recently had a de facto ban on solid radioactive waste disposal due to their radioactivity limit being 5 picocuries per gram. The result of this de facto ban made it so companies either had to make one of two decisions: 1. Haul their radioactive solid waste above the limit out of state to facilities in Idaho or Colorado; or 2. Risk getting caught illegally dumping waste in municipal landfills or just plain illegal dumping in roadsides, buildings, or farmland.

In 2014, a massive illegal dumping site was discovered in Noonan, ND when North Dakota regulators found a gas station full of radioactive waste and filter socks (the socks used to filter out solid waste from wastewater, which contain high levels of radioactivity). Following the Noonan, ND incident North Dakota regulators and politicians began discussions regarding the need for new regulations to address radioactive solid waste.

In 2015, North Dakota moved to create rules for the disposal of solid radioactive waste. Its new regulations increase the radioactivity limit from 5 picocuries per gram to 50 picocuries per gram, and sets up new requirements for the permitting of waste facilities accepting radioactive waste and the disposal of radioactive waste in the waste facilities. Dakota Resource Council, a member group of WORC, challenged the rules in the courts, arguing the rules are not protective enough and that the agency responsible for the rules pushed through the rules without following the proper procedures. Currently the rules are not in effect until the litigation is settled.

Pennsylvania

In Pennsylvania, the hotbed of activity for Marcellus Shale gas extraction, the regulatory body was ill equipped and uninformed for dealing with the new massive waste stream when it first arrived on scene. Through 2013, the majority of wastewater was disposed of in commercial and municipal wastewater treatment facilities that discharge to surface waters. Numerous facilities engaged in this practice without amending their federal discharge permits to include this new waste stream.

Waste treatment facilities in Pennsylvania tried to make the waste streams less innocuous by diluting the concentrations of these hazardous pollutants. They did this by mixing the fracking wastes with other waste streams, including industrial discharges and municipal waste. Other specialized facilities also tried to remove these dissolved inorganic elements and filter them from the discharge stream.

As a result of site assessments by yours-truly and additional academic research, these facilities realized that such hazardous compounds do not simply dilute into receiving waters such as the Allegheny, Monongahela, and Ohio rivers. Instead, they partition (settle) into sediments where they are hyper-concentrated. As a result of the lawsuits that followed the research, entire river bottoms in Pennsylvania had to be entirely dug up, removed, and disposed of in hazardous waste landfills.

Action Plans Needed

Massive amounts of solid and liquid wastes are still generated during drilling exploration and production from the Marcellus Shale. There is so much waste, operators don’t know what to do with it. In Pennsylvania, there is not much they can do with it, but it is not just Pennsylvania. Throughout the Ohio River Valley, operators struggle to dispose of this incredibly large waste stream.

Ohio, West Virginia, and Pennsylvania have all learned that this waste should not be allowed to be discharged to surface waters even after treatment. So it goes to other states – those without production or the regulatory framework to manage the wastes. Like every phase of production in the oil and gas industry, operators (drillers) shop around for the lowest disposal costs. In Estill County, Kentucky, the State Energy and Environment Department just recently cited the disposal company Advance Disposal Services Blue Ridge Landfill for illegally dumping hydraulic fracturing waste. The waste had traveled from West Virginia Marcellus wells, and ended up at an ignorant or willfully negligent waste facility.

In summary, there is inadequate federal oversight of potentially hazardous waste coming from the oil and gas industry, and there are serious regulatory gaps within and between states. Data management practices, too, are lacking. How then, is the public health community supposed to assess the risk that the waste stream poses to people? Obviously, a more thorough action plan is needed to address this issue.


Feature image: Drill cuttings being prepared to be hauled away from the well pad. Photo by Bill Hughes, OVEC

Oil and gas production on public lands

Interactive maps show nearness of oil and gas wells to communities in 5 states

As an American, you are part owner of 640 million acres of our nation’s shared public lands managed by the federal government. And chances are, you’ve enjoyed a few of these lands on family picnics, weekend hikes or summer camping trips. But did you know that some of your lands may also be leading to toxic air pollution and poor health for you or your neighbors, especially in 5 western states that have high oil and gas drilling activity?

A set of new interactive maps created by FracTracker, The Wilderness Society, and partner groups show the threatened populations who live within a half mile of  federal oil and gas wells – people who may be breathing in toxic pollution on a regular basis.

Altogether, air pollution from oil and gas development on public lands threatens at least 73,900 people in the 5 western states we examined. The states, all of which are heavy oil and gas leasing areas, include ColoradoNew MexicoNorth DakotaUtah and Wyoming.

Close up of threat map in Colorado

Figure 1. Close up of threat map in Colorado

In each state, the data show populations living near heavy concentrations of wells. For example just northeast of Denver, Colorado, in the heavily populated Weld County, at least 11,000 people are threatened by oil and gas development on public lands (Figure 1).

Western cities, like Farmington, New Mexico; Gillette, Wyoming; and Grand Junction, Colorado are at highest risk of exposure from air pollution. In New Mexico, especially, concentrated oil and gas activity disproportionately affects the disadvantaged and minorities. Many wells can be found near population centers, neighborhoods and even schools.

Colorado: Wells concentrated on Western Slope, Front Range

Note: The threatened population in states are a conservative estimate. It is likely that the numbers affected by air pollution are higher.

In 2014, Colorado became the first state in the nation to try to curb methane pollution from oil and gas operations through comprehensive regulations that included inspections of oil and gas operations and an upgrade in oil and gas infrastructure technology. Colorado’s new regulations are already showing both environmental and financial benefits.

But nearly 16,000 people – the majority living in the northwestern and northeastern part of the state – are still threatened by pollution from oil and gas on public lands.

Many of the people whose health is endangered from pollution are concentrated in the fossil-fuel rich area of the Western Slope, near Grand Junction. In that area, three counties make up 65% of the total area in Colorado threatened by oil and gas development.

In Weld County, just northeast of Denver, more than 11,000 residents are threatened by air pollution from oil and gas production on federal lands. But what’s even more alarming is that five schools are within a half mile radius of wells, putting children at risk on a daily basis of breathing in toxins that are known to increase asthma attacks. Recent studies have shown children miss 500,000 days of school nationally each year due to smog related to oil and gas production.

State regulations in Colorado have helped improve air quality, reduce methane emissions and promote worker care and safety in the past two years, but federal regulations expected by the end of 2016 will have a broader impact by regulating pollution from all states.

New Mexico: Pollution seen from space threatens 50,000 people

With more than 30,000 wells covering 4.6 million acres, New Mexico is one of the top states for oil and gas wells on public lands. Emissions from oil and gas infrastructure in the Four Corners region are so great, they have formed a methane hot spot that has been extensively studied by NASA and is clearly visible from space.

Nearly 50,000 people in northwestern New Mexico – 40% of the population in San Juan County – live within a half mile of a well. 

Dangerous emissions from those wells in San Juan County disproportionately affect minorities and disadvantaged populations, with about 20% Hispanic, almost 40% Native American, and over 20% living in poverty.

Another hot spot of oil and activity is in southeastern New Mexico stretching from the lands surrounding Roswell to the southern border with Texas. Wells in this region also cover the lands outside of Carlsbad Caverns National Park, potentially affecting the air quality and visibility for park visitors. Although less densely populated, another 4,000 people in two counties – with around 50% of the population Hispanic – are threatened by toxic air pollution.

Wyoming: Oil and gas emissions add to coal mining pollution

Pollution from oil and gas development in Wyoming, which has about as many wells as New Mexico, is focused in the Powder River Basin. This region in the northeast of the state provides 40% of the coal produced in the United States.

Oil and gas pollution threatens approximately 4,000 people in this region where scarred landscapes and polluted waterways are also prevalent from coal mining. 

With the Obama administration’s current pause on federal coal leasing and a review of the federal coal program underway, stopping pollution from oil and gas on public lands in Wyoming would be a major step in achieving climate goals and preserving the health of local communities.

Utah: Air quality far below federal standards

Utah has almost 9,000 active wells on public lands. Oil and gas activity in Utah has created air quality below federal standards in one-third of Utah’s counties, heightening the risk of asthma and respiratory illnesses. Especially in the Uintah Basin in northeastern Utah – where the majority of oil and development occurs – a 2014 NOAA-led study found oil and gas activity can lead to high levels of ozone in the wintertime that exceed federal standards.

North Dakota: Dark skies threatened by oil and gas activity

The geology of western North Dakota includes the Bakken Formation, one of the largest deposits of oil and gas in the United States. As a result, high oil and gas production occurs on both private and public lands in the western part of the state.

Nearly 650 wells on public lands are clustered together here, directly impacting popular recreational lands like Theodore Roosevelt National Park.

The 70,000-plus-acre park – named after our president who first visited in 1883 and fell in love with the incredible western landscape – is completely surrounded by high oil and gas activity. Although drilling is not allowed in the park, nearby private and public lands are filled with active wells, producing pollution, traffic and noise that can be experienced from the park. Due to its remote location, the park is known for its incredible night sky, but oil and gas development increases air and light pollution, threatening visibility of the Milky Way and other astronomical wonders.

You own public lands, but they may be hurting you

Pollution from oil and gas wells on public lands is only a part of a larger problem. Toxic emissions from oil and gas development on both public and private lands threaten 12.4 million people living within a half mile of wells, according to an oil and gas threat map created by FracTracker for a project by Earthworks and the Clean Air Task Force.

Now that we can see how many thousands of people are threatened by harmful emissions from our public lands, it is more important than ever that we finalize strong federal regulations that will help curb the main pollutant of natural gas – methane – from being leaked, vented, and flared from oil and gas infrastructure on public lands.

Federal oil and gas wells in western states produce unseen pollution that threatens populations at least a half mile away. Photo: WildEarth Guardians, flickr.

Federal oil and gas wells in western states produce unseen pollution that threatens populations at least a half mile away. Photo: WildEarth Guardians, flickr.

We need to clean up our air now

With U.S. public lands accounting for 1/5 of the greenhouse gas footprint in the United States, we need better regulations to reduce polluting methane emissions from the 96,000 active oil and gas wells on public lands.

Right now, the Bureau of Land Management is finalizing federal regulations that are expected by the end of 2016. These regulations are expected to curb emissions from existing sources – wells already in production – that are a significant source of methane pollution on public lands. This is crucial, since by 2018, it is estimated that nearly 90% of methane emissions will come from sources that existed in 2011.

Federal regulations by the BLM should also help decrease the risk to communities living near oil and gas wells and helping cut methane emissions by 40 to 45% by 2025 to meet climate change reduction goals.

Final regulations from the Bureau of Land Management will also add to other regulations from the EPA and guidance from the Obama administration to modernize energy development on public lands for the benefit of the American people, landscapes and the climate. In the face of a changing climate, we need to continue to monitor fossil fuel development on public lands and continue to push the government towards better protections for land, air, wildlife and local communities.


By The Wilderness Society – The Wilderness Society is the leading conservation organization working to protect wilderness and inspire Americans to care for our wild places. Founded in 1935, and now with more than 700,000 members and supporters, The Wilderness Society has led the effort to permanently protect 109 million acres of wilderness and to ensure sound management of our shared national lands.

Screenshot from Vulnerable Populations Map

Sensitive Receptors near Fracked Oil & Gas Wells

EnvironmentAmerica_reportcover

Cover of Dangerous and Close report. Click to view report

FracTracker Alliance has been working with the Frontier Group and Environment America on a nationwide assessment of “fracked” oil and gas wells. The report is titled Dangerous and Close, Fracking Puts the Nation’s Most Vulnerable People at Risk. The assessment analyzed the locations of fracked wells and identified where the fracking has occurred near locations where sensitive populations are commonly located. These sensitive sites include schools and daycare facilities because they house children, hospitals because the sick are not able to fight off pollution as effectively, and nursing homes where the elderly need and deserve clean environments so that they can be healthy, as well. The analysis used data on fracked wells from regulatory agencies and FracFocus in nine states. Maps of these nine states, as well as a full national map are shown below.

No one deserves to suffer the environmental degradation that can accompany oil and gas development – particularly “fracking” – in their neighborhoods. Fracked oil and gas wells are shown to have contaminated drinking water, degrade air quality, and sicken both aquatic and terrestrial ecosystems. Additionally, everybody responds differently to environmental pollutants, and some people are much more sensitive than others. In fact, certain sects of the population are known to be more sensitive in general, and exposure to pollution is much more dangerous for them. These communities and populations need to be protected from the burdens of industries, such as fracking for oil and gas, that have a negative effect on their environment. Commonly identified sensitive groups or “receptors” include children, the immuno-compromised and ill, and the elderly.  These groups are the focus of this new research.

 

National Map

National interactive map of sensitive receptors near fracked wells

View Map Fullscreen | How Our Maps Work

State-By-State Maps in Dangerous and Close Report

Click to view interactive maps associated with each state

Wastewater Disposal Facility in Colorado

Groundwater Threats in Colorado

FracTracker has been increasingly looking at oil and gas drilling in Colorado, and we’re finding some interesting and concerning issues to highlight. Firstly, operators in Colorado are not required to report volumes of water use or freshwater sources. Additionally, this analysis looked at how wastewater in Colorado is injected, and found that the majority is injected into Class II disposal wells (85%) while recycling wastewater is not common. Open-air pits for evaporation and percolation of wastewater is still a common practice. Colorado has at least 340 zones granted aquifer exemptions from the Clean Water Act for injecting wastewater into groundwater. The analysis also found that Weld County produces the most oil and gas in the state, while Rio Blanco and Las Animas counties produce more wastewater. And finally, Rio Blanco injects the most wastewater of all Colorado counties. Learn more about groundwater threats in Colorado below:

Introduction

Working directly with communities in Weld County, Colorado the FracTracker Alliance has identified issues concerning oil and gas exploration and production in Colorado that are of particular concern to community stakeholder groups. The issues include air quality degradation, environmental justice concerns for communities most impacted by oil and gas extraction, and leasing of federal mineral estates. Analysis of data for Colorado’s Front Range has identified areas where setback regulations are not followed or are inadequate to provide sufficient protections for individuals and communities and our analysis of floodplains shows where oil and gas operations pose a significant risk to watersheds. In this article we focus on the specific threat to groundwater resources as a result of particular waste disposal methods, namely underground injection and land application in disposal pits and sumps. We also focus on the sources of the immense amount of water necessary for fracking and other extraction processes.

Groundwater Threats

Numerous threats to groundwater are associated with oil and gas drilling, including hydraulic fracturing. Research from other regions shows that the majority of groundwater contamination events actually occur from on-site spills and poor management and disposal of wastes. Disposal and storage sites and spill events can allow the liquid and solid wastes to leach and seep into groundwater sources. There have been many groundwater contamination events documented to have occurred in this manner. For example, in 2013, flooding in Colorado inundated a main center of the state’s drilling industry causing over 37,380 gallons of oil to be spilled from ruptured pipelines and damaged storage tanks that were located in flood-prone areas. There are serious concerns that the oil-laced floodwaters have permanently contaminated groundwater, soil, and rivers.

Waste Management

In Colorado, wastes are managed several ways. If the wastewater is not recycled and used again in other production processes such as hydraulic fracturing, drilling fluids disposal must follow one of three rules:

  1. Treated at commercial facilities and discharged to surface water,
  2. Injected in Class II injection wells, or
  3. Stored and applied to the land and disposal pits at centralized exploration and production waste management facilities.

Additionally the wastes can be dried and buried in additional drilling pits, with restrictions for crop land. For oily wastes, those containing crude oil, condensate or other “hydrocarbon-containing exploration and production waste,” there are additional land application restrictions that mostly require prior removal of free oil. These various sites and facilities are mapped below, along with aquifer exemptions and other map layers related to water quality.

Figure 1. Interactive map of groundwater threats in Colorado

View Map Fullscreen | How Our Maps Work

Injection Wells

In 2015, Colorado injected a total of 649,370,514 barrels of oil and gas wastewater back into the ground. That is 27,273,561,588 gallons, which would fill over 41,000 Olympic sized swimming pools. Injected into the ground in deep formations, this water is forever removed from the water cycle.

Allowable injection fluids include a variety of things you do not want to drink:

  • Produced Water
  • Drilling Fluids
  • Spent Well Treatment or Stimulation Fluids
  • Pigging (Pipeline Cleaning) Wastes
  • Rig Wash
  • Gas Plant Wastes such as:
    • Amine
    • Cooling Tower Blowdown
    • Tank Bottoms

This means that federal exemptions to Underground Injection Control (UIC) regulations for oil and gas exploration and production have nothing to do with environmental chemistry and risk, and only consider fluid source.

Why the concern?

Why are we concerned about these wastes? To quote the regulation, “it is possible for an exempt waste and a non-exempt hazardous waste to be chemically very similar” (RCRA). Since oil and gas development is considered part of the United State’s strategic energy policy, the entire industry is exempt from many federal regulations, such as the Safe Drinking Water Act (SDWA), which protects underground sources of drinking water (USDW).

The Colorado Oil and Gas Conservation Commission has primacy over the UIC permits and the Colorado Department of Public Health and Environment (CDPHE) administers the environmental protection laws related to air quality, waste discharge to surface water, and commercial disposal facilities. Under the UIC program, operators are legally allowed to inject wastewater containing heavy metals, hydrocarbons, radioactive elements, and other toxic and carcinogenic chemicals into groundwater aquifers.

The State of CO Injection Wells

According to the COGCC production reports for the year 2015, there are 9,591 active injection wells with volumes reported to the regulatory agency. Additionally, there are of course distinctions within the UIC rules for different types of injection wells, although the COGCC does not provide comprehensive data to distinguish between these types.

Injecting into the same geological formation or “zone” as producing wells is typically considered EOR, although some of the injected water will ultimately remain in the ground. Injecting into a producing formation is an immediate qualification for receiving an aquifer exemption.

EOR operations require considerably more energy and resources than conventional wells, and therefore have a higher water carbon footprint. If the wastewater is “recycled” as hydraulic fracturing fluid, the injections are exempt from all UIC regulations regardless. These are two options for the elimination of produced wastewater, although much of it will return to the surface in the future along with other formation waters. When the produced waters reach a certain level of salinity the fluid can no longer be used in enhanced recovery or stimulation, so final disposal of wastewater is typically necessary. These liquid wastes may then go to UIC Class II Disposal Wells.

Class II Injection Wells

The wells injecting into non-producing formations are therefore disposal wells, since they are not “enhancing production.” Of the almost 10,000 active injection wells in Colorado there are OVER 670 class II disposal well facilities; 402 facilities are listed as currently active. These facilities may or may not host multiple wells. By filtering the COGCC production and injection well database by target formation, we find that there are over 1,070 wells injecting into non-producing formations. These disposal wells injected at least 66,193,874 barrels (2,780,142,708 gallons) of wastewater in 2015 alone.

Where is the waste going?

A simple life-cycle assessment of wastewater in Colorado shows that the majority of produced water is injected back underground into class II disposal and EOR wells. The percentage of injected produced waters has been increasing since 2012, and in 2015 85% of the total volume of produced water in 2015 was injected.

If we assume that all the volume injected was produced wastewater, this still leaves 60 million barrels of produced water unaccounted for. Some of this volume may have been recycled and used for hydraulic fracturing, but this is rarely the case. Other options for disposal include commercial oilfield wastewater disposal facilities (COWDF) that use wastewater sumps (pits) for evaporation and percolation, as well as land application, to dilute the solid and liquid wastes by mixing them into soil.

Centralized Exploration and Production Waste Management Facilities

Photo by COGCC

Figure 2. Chevron Wastewater Land Application and Pit “Disposal” Facility. Photo by COGCC

According to the COGCC, there are 40 active and 71 total “centralized exploration and production waste management facilities” in Colorado. These facilities, mapped in Figure 1 above, are mostly open-air pits used for storage or disposal, or land-application sites.

As can be seen in the Figure 2 to the right, land application sites are little more than farms that don’t grow anything, where wastewater is mixed with soil. Groundwater monitoring wells around these sites measure the levels of some contaminants. Inspection reports show that sampling of the wastewater is not usually – if ever – conducted. The only regulatory requirement is that oil is not visibly noticeable as a sheen on the wastewater fluids in impoundments, such as the one in Figure 3 below, operated by Linn Operating Inc., which is covered in an oily sheen.

In most other hydrocarbon producing states, open-air pits or sumps are not allowed for a variety of reasons. At FracTracker, we have covered this issue in other states, as well. In New Mexico, for example, the regulatory agency outlawed the use of pits after finding cased where 369 pits were documented to have contaminated groundwater. California is another state that still uses above ground pits for disposal. At sites in California, plumes of contaminants are being monitored as they spread from the facilities into surrounding regions of groundwater. Additionally, these wastewater pit disposal sites present hazards for birds and wildlife. There have been a number of papers documenting bird deaths in pits, and the risk for migratory bird species is of high concern. Other states like California are struggling with the issue of closing these types of open-air pit facilities. Closing these facilities means that more wastewater will be injected in Class II disposal wells.

Linnoilypit

Figure 3. Linn energy oily wastewater disposal pit

Production and Injection Volumes

The data published by the COGCC for well production and injection volumes shows some unique trends. An analysis of injection and production well volumes shows Class II Injection is tightly connected to exploration and production activities. This finding is not surprising. Class II injection wells are considered a support operation for the production wells, and therefore should be expected to be similarly related. Wastewater injection wells are needed where oil and gas extraction is occurring, particularly during the exploration and drilling phases.

Looking at the graphs in Figures 4-6 below, it is obvious that injection volumes have been consistently tied to production of wastewater. It is also clear that the trend since 2012 shows that an increasingly larger percentage of wastewater is being injected each year. This trend follows the sharp increase in high volume hydraulic fracturing activity that occurred in 2012. During this boom in exploration and drilling activity, recycling of flowback for additional hydraulic fracturing activities most likely accounts for some of the discrepancy in accounting for the fact that 200% more wastewater was produced than was injected in 2012.

When Figure 4 (below) is compared to the graphs in Figures 5 and 6 (further below) it is also interesting to note that produced water volumes in 2015 are at a 5-year low as of 2015, while production volumes of both natural gas and oil are at a 5-year high. Wastewater volumes are linked to production volumes, but there are many other factors, including geological conditions and types of extraction technologies being used, that have a massive affect on wastewater volumes.

CO wastewater Volumes by year

Figure 4. Colorado wastewater volumes by year (barrels)

The graphs in Figures 5 and 6 below show different trends. Gas production in Colorado has remained relatively constant over the last five years with a sharp increase in 2015, while oil production volumes have been continually increasing, with the largest increase of 49% from 2014 to 2015, and 46% the year prior.

Figures 5-6

Colorado’s Front Range, specifically Weld County, is increasing oil production at a fast rate. New multi-well well-pads are being permitted in neighborhoods and urban and suburban communities without consideration for even elementary schools. Weld County currently has 2,169 new wells permitted within the county. The figure is higher than the next 9 counties combined. The other top three counties with the most well permits are 2. Garfield (1,130) and 3. Rio Blanco (189), for perspective. Additionally, 74% of pending permits for new wells are located in Weld County.

How Counties Compare

The top 10 counties for oil production are very similar to the top 10 counties for both produced and injected volumes, although there are some inconsistencies (Table 1). For example, Las Animas County produces the second largest amount of produced wastewater, but is not in the top 10 of oil producing counties. This is because the majority of wells in Las Animas County produce natural gas. Natural gas wells do not typically produce as much wastewater as oil wells. The counties and areas with the most oil and gas production are also the regions with the most injection and surface waste disposal, and therefore surface water and groundwater degradation.

Table 1. Top 10 CO counties for gas production, oil production, wastewater production, and injection volumes in 2015.

Gas Production Oil Production Wastewater Production Injection Volumes
Rank County Gas1 County Oil2 County Water2 County Water2
1 Weld 568,919,168 Weld 112,898,400 Rio Blanco 113,132,037 Rio Blanco 138,502,742
2 Garfield 556,855,359 Rio Blanco 4,412,578 Las Animas 45,868,907 Weld 50,360,796
3 La Plata 322,029,940 Gardield 1,744,900 Weld 37,665,571 Garfield 29,022,147
4 Las Animas 78,947,042 Araahoe 1,661,204 Garfield 34,704,673 La Plata 23,211,646
5 Rio Blanco 57,284,876 Lincoln 1,194,435 Washington 25,075,998 Washington 15,105,886
6 Mesa 32,200,936 Cheyenne 1,192,162 La Plata 23,352,861 Las Animas 13,706,555
7 Yuma 25,960,947 Adams 664,530 Cheyenne 9,326,944 Cheyenne 10,309,413
8 Archuleta 13,648,006 Moffat 419,893 Moffat 7,712,323 Logan 5,930,937
9 Moffat 13,610,219 Washington 413,603 Logan 5,606,828 Mesa 5,611,075
10 Gunnison 4,805,541 Jackson 407,537 Morgan 4,197,849 La Plata 4,992,391
1. Units are in MCF = Thousand cubic feet of natural gas;
2. Units are in Barrels

Aquifer Exemptions

Operators are given permission by the U.S. EPA to inject wastewater into groundwater aquifers in certain locations where groundwater formations are particularly degraded or when operators are granted aquifer exemptions. Aquifer exemptions are not regions where the groundwater is not suitable for use as drinking water. Quite the contrary, as any aquifer with groundwaters above a 10,000 ppm total dissolved solids (TDS) threshold are fast-tracked for injection permits. When the TDS is below 10,000 ppm operators can apply for an exemption from SDWA (safe drinking water act) for USDWs (underground sources of drinking water), which otherwise protects these groundwater sources. An exemption can be granted for any of the following three reasons. The formation is:

  • hydrocarbon producing,
  • too deep to economically access, or
  • too “contaminated” to economically treat.

Since the first requirement is enough to satisfy an exemption, most class II wells are located within oil and gas fields. Other considerations include approval of mineral owners’ permissions within ¼ mile of the well. On the map above, you can see the ¼ mile buffers around active injection wells. If you live in Colorado, and suspect you live within the ¼ mile buffer of an injection well, you can input an address into the search field in the top-right corner of the map to fly to that location.

Sources of Water

The economic driver for increasing wastewater recycling is mostly influenced by two factors. First, states with many class II disposal wells, like Colorado, have much lower costs for wastewater disposal than states like Pennsylvania, for example. Additionally, the cost of water in drought-stricken states makes re-use more economically advantageous.

These two factors are not weighted evenly, though. On the Colorado front range, water scarcity should make recycling and reuse of treated wastewater a common practice. The stress of sourcing fresh water has not yet become a finanacial restraint for exploration and production. Water scarcity is an issue, but not enough to motivate operators to recycle. According to an article by Small, Xochitl T (2015) “Geologic factors that impact cost, such as water quality and availability of disposal methods, have a greater impact on decisions to recycle wastewater from hydraulic fracturing than water scarcity.” As long as it is cheaper to permit new injection wells and contaminate potential USDW’s than to treat the wastewater, recycling practices will be largely ignored. Even in Colorado’s arid Front Range where the demand for freshwater frequently outpaces supply, recycling is still not common.

Fresh Water Use

The majority of water used for hydraulic fracturing is freshwater, and much of it is supplied from municipal water systems. There are several proposals for engineering projects in Colorado to redirect flows from rivers to the specific municipalities that are selling water to oil and gas operators. These projects will divert more water from the already stressed watersheds, and permanently remove it from the water cycle.

The Windy Gap Firming Project, for example, plans to dam the Upper Colorado River to divert almost 10 billion gallons to six Front Range cities including Loveland, Longmont, and Greeley. These three cities have sold water to operators for fracking operations. Greeley in particular began selling 1,500 acre-feet (500 million gallons) to operators in 2011 and that has only increased . The same thing is happening in Fort Lupton, Frederick, Firestone, and in other communities. Additionally, the Northern Integrated Supply Project proposes to drain an additional 40,000 acre feet/year (13 billion gallons) out of the Cache la Poudre River northwest of Fort Collins. The Seaman Reservoir Project by the City of Greeley on the North Fork of the Cache la Poudre River proposes to drain several thousand acre feet of water out of the North Fork and the main stem of the Cache la Poudre. And finally, the Flaming Gorge Pipeline would take up to 250,000 acre feet/year (81 billion gallons) out of the Green and Colorado Rivers systems, among others.

Other Water Sources

Unfortunately, not much more is known about sources and amounts of water for used for fracking or other oil and gas development operations. Such a data gap seems ridiculous considering the strain on freshwater sources in eastern Colorado and the Front Range, but regulators do not require operators to obtain permits or even report the sources of water they use. Legislative efforts to require such reporting were unsuccessful in 2012.

Now that development and fracking operations are continuously moving into urban and residential areas and neighborhoods, sourcing water will be as easy as going to the nearest fire hydrant. Allowing oil and gas operators to use municipal water sources raises concerns of conflicts of interest and governmental corruption considering public water systems are subsidized by local taxpayers, not well sites.

Conclusions

In Colorado, exploration and drilling for oil and natural gas continues to increase at a fast pace, while the increase in oil production is quite staggering. As this trend continues, the waste stream will continue to grow with production. This means more Class II injection wells and other treatment and disposal options will be necessary.

While other states are working to end the practices that have a track record of surface water and groundwater contamination, Colorado is issuing new permits. Colorado has issued 7 permits for CEPWMF’s in 2016 alone, some of them renewals. While there aren’t any eco-friendly methods of dealing with all the wastewater, the use of pits and land application presents high risk for shallow groundwater aquifers. In addition, sacrificing deep groundwater aquifers with aquifer exemptions is not a sustainable solution. These are important considerations beyond the obvious contribution of carbon dioxide and methane to the issue of climate change when considering the many reasons why hydrocarbon fuels need to be eliminated in favor of clean energy alternatives.


By Kyle Ferrar, Western Program Coordinator & Kirk Jalbert, Manager of Community Based Research & Engagement, FracTracker Alliance

Cover photo by COGCC

The BP Whiting, IN Oil Refinery

US Oil Refineries and Economic Justice

How annual incomes in the shadow of oil refineries compare to state and regional prosperity

North American Oil Refinery Capacity (Barrels Per Day (BPD))

Figure 1. North American Oil Refinery Capacity

Typically, we analyze the potential economic impacts of oil refineries by simply quantifying potential and/or actual capacity on an annual or daily basis. Using this method, we find that the 126 refineries operating in the U.S. produce an average of 100,000-133,645 barrels per day (BPD) of oil – or 258 billion gallons per year.

In all of North America, there are 158 refineries. When you include the 21 and 27 billion gallons per year produced by our neighbors to the south and north, respectively, North American refineries account for 23-24% of the global refining capacity. That is, of course, if you believe the $113 dollar International Energy Agency’s 2016 “Medium-Term Oil Market Report” 4.03 billion gallon annual estimates (Table 1 and Figure 1).

Table 1. Oil Refinery Capacity in the United States and Canada (Barrels Per Day (BPD))

United States Canada Mexico Total
Refinery Count 126 17 6 158
Average Capacity 133,645 BPD 104,471 BPD 228,417 BPD 139,619 BPD
Low Foreland & Silver Eagle Refining in NV & WY, 2-3K BPD Prince George & Moose Jaw Refining in BC and SK, 12-15K BPD Pemex’s Ciudad Madero Refinery, 152K BPD
High Exxon Mobil in TX & LA, 502-560K BPD Valero and Irving Oil Refining in QC & NS, 265-300K BPD Pemex’s Tula Refinery, 340K BPD
Median 100,000 BPD 85,000 BPD 226,500 109,000
Total Capacity 16.8 MBPD 1.8 MBPD 1.4 MBPD 22.1 MBPD

Census Tract Income Disparities

However, we would propose that an alternative measure of a given oil refinery’s impact would be neighborhood prosperity in the census tract(s) where the refinery is located. We believe this figure serves as a proxy for economic justice. As such, we recently used the above refinery location and capacity data in combination with US Census Bureau Cartographic Boundaries (i.e., Census Tracts) and the Census’ American FactFinder clearinghouse to estimate neighborhood prosperity near refineries.

Methods

Our analysis involved merging oil refineries to their respective census tracts in ArcMAP 10.2, along with all census tracts that touch the actual census tract where the refineries are located, and calling that collection the oil refinery’s sphere of influence, for lack of a better term. We then assigned Mean Income in the Past 12 Months (In 2014 Inflation-Adjusted Dollars) values for each census tract to the aforementioned refinery tracts – as well as surrounding regional, city, and state tracts – to allow for a comparison of income disparities. We chose to analyze mean income instead of other variables such as educational attainment, unemployment, or poverty percentages because it largely encapsulates these economic indicators.

As the authors of the UN’s International Forum of Social Development paper Social Justice in an Open World wrote:

In today’s world, the enormous gap in the distribution of wealth, income and public benefits is growing ever wider, reflecting a general trend that is morally unfair, politically unwise and economically unsound… excessive income inequality restricts social mobility and leads to social segmentation and eventually social breakdown…In the modern context, those concerned with social justice see the general  increase  in  income  inequality  as  unjust,  deplorable  and  alarming.  It is argued that poverty reduction and overall improvements in the standard of living are attainable goals that would bring the world closer to social justice.

Environmental regulatory agencies like to separate air pollution sources into point and non-point sources. Point sources are “single, identifiable” sources, whereas non-point are more ‘diffuse’ resulting in impacts spread out over a larger geographical area. We would equate oil refineries to point sources of socioeconomic and/or environmental injustice. The non-point analysis would be far more difficult to model given the difficulties associated with converting perceived quality of life disturbance(s) associated with infrastructure like compressor stations from the anecdotal to the empirical.

Results

Primarily, residents living in the shadow of 80% of our refineries earn nearly $16,000 less than those in the surrounding region – or, in the case of urban refineries, the surrounding Metropolitan Statistical Areas (MSAs). Only residents living in census tracts within the shadow of 25 of our 126 oil refineries earn around $10,000 more annually than those in the region.

On average, residents of census tracts that contain oil refineries earn 13-16% less than those in the greater region and/or MSAs (Figure 2). Similarly, in comparing oil refinery census tract incomes to state averages we see a slightly larger 17-21% disparity (Figure 3).

Digging Deeper

United States Oil Refinery Income Disparities (Note: Larger points indicate oil refinery census tracts that earn less than the surrounding region or city)

Figure 4. United States Oil Refinery Income Disparities (Note: Larger points indicate oil refinery census tracts that earn less than the surrounding region or city.)

Oil refinery income disparities seem to occur not just in one region, but across the U.S. (Figure 4).

The biggest regional/MSA disparities occur in northeastern Denver neighborhoods around the Suncor Refinery complex (103,000 BPD), where the refinery’s census tracts earn roughly $42,000 less than Greater Denver residents1. California, too, has some issues near its Los Angeles’ Valero and Tesoro Refineries and Chevron’s Bay Area Refinery, with a combined daily capacity of nearly 600 BPD. There, two California census associations in the shadow of those refineries earn roughly $38,000 less than Contra Costa and Los Angeles Counties, respectively. In the Lone Star state Marathon’s Texas City, Galveston County refinery resides among census tracts where annual incomes nearly $33,000 less than the Galveston-Houston metroplex. Linden, NJ and St. Paul, MN, residents near Conoco Phillips and Flint Hills Resources refineries aren’t fairing much better, with annual incomes that are roughly $35,000 and nearly $33,000 less than the surrounding regions, respectively.

Click on the images below to explore each of the top disparate areas near oil refineries in the U.S. in more detail. Lighter shades indicate census tracks with a lower mean annual income ($).

Conclusion

Clearly, certain communities throughout the United States have been essentially sacrificed in the name of Energy Independence and overly-course measures of economic productivity such as Gross Domestic Product (GDP). The presence and/or construction of mid- and downstream oil and gas infrastructure appears to accelerate an already insidious positive feedback loop in low-income neighborhoods throughout the United States. Only a few places like Southeast Chicago and Detroit, however, have even begun to discuss where these disadvantaged communities should live, let alone how to remediate the environmental costs.

Internally Displaced People

There exists a robust history of journalists and academics focusing on Internally Displaced People (IDP) throughout war-torn regions of Africa, the Middle East, and Southeast Asia – to name a few – and most of these 38 million people have “become displaced within their own country as a result of violence.” However, there is a growing body of literature and media coverage associated with current and potential IDP resulting from rising sea levels, drought, chronic wildfire, etc.

The issues associated with oil and gas infrastructure expansion and IDPs are only going to grow in the coming years as the Shale Revolution results in a greater need for pipelines, compressor stations, cracker facilities, etc. We would propose there is the potential for IDP resulting from the rapid, ubiquitous, and intense expansion of the Hydrocarbon Industrial Complex here in the United States.

N. American Hydrocarbon Industrial Complex Map

View map fullscreenHow FracTracker maps work | Download map data

Footnotes and Additional Reading

  1. The Suncor refinery was implicated in a significant leak of tar sands crude associated benzene into the South Platte River as recently as 2013. According to Suncor’s website this refinery “supplies about 35% of Colorado’s gasoline and diesel fuel demand and is a major supplier of jet fuel to the Denver International Airport. The refinery is also the largest supplier of paving-grade asphalt in Colorado.”
  2. New York Times story on the growing footprint of BP’s Whiting Refinery: Surrounded by Industry, a Historic Community Fights for Its Future

By Ted Auch, PhD – Great Lakes Program Coordinator, FracTracker Alliance

Drilling Bella Romero: Children at Risk in Greeley, Colorado

By
Kirk Jalbert, Manager of Community Based Research & Engagement
Kyle Ferrar, Western Program Coordinator

Weld County, Colorado, is one of the top producing shale oil and gas regions in the United States, boasting more than 12,000 active horizontal or directional wells, which account for 50% of all horizontal or directional wells in the state. To put this into perspective, the entire state of Pennsylvania has ten times the land area with “only” 9,663 horizontal or directional wells. At the center of Weld County is the city of Greeley, population 92,889. Greeley has experienced dramatic changes in the past decade as extraction companies compete to acquire oil and gas mineral rights. Extensive housing developments on the outskirts of the city are being built to accommodate future well pads on neighboring lots. Meanwhile, a number of massive well pads are proposed within or on the border of city limits.

FracTracker visited Colorado back in November 2015 and met with regional advocacy organizations including Coloradans Against Fracking, Protect our Loveland, Weld Air and Water, and Our Longmont to determine how we could assist with data analysis, mapping, and digital storytelling. FracTracker returned in June 2016 to explore conditions unique to Weld County’s oil and gas fields. During our visit we interviewed residents of Greeley and found that one of their greatest concerns was the dangers of siting oil and gas wells near schools. While there is much more we will be publishing in coming weeks about our visit, this article focuses on one troubling project that would bring gas drilling to within 1,300ft of a public school. The proposal goes before the Weld County Commissioners on Wednesday, June 29th for final approval. As such, we will be brief in pointing out what is at stake in siting industrial oil and gas facilities near schools in Colorado and why residents of Greeley have cause for concern.

Drilling Bella Romero

On June 7th, the Weld County Planning Commission unanimously approved a proposal from Denver-based Extraction Oil & Gas to develop “Vetting 15H”—a 24-head directional well pad in close proximity to Bella Romero Academy, a middle school just outside Greeley city limits. In addition to the 24-head well pad would be a battery of wastewater tanks, separators, and vapor recovery units on an adjacent lot. The permit submitted to the Colorado Oil & Gas Conservation Commission (COGCC) also states that six more wells may be drilled on the site in the future.

As was detailed in a recent FracTracker article, Colorado regulations require a minimum setback distance of 500ft from buildings and an additional 350ft from outdoor recreational areas. In more populated areas, or where a well pad would be within 1,000ft of high occupancy buildings, schools, and hospitals, drilling companies must apply for special variances to minimize community impacts. Setbacks are measured from the well head to the nearest wall of the building. For well pads with multiple heads, each well must comply with the respective setback requirements.

bella_romero_playground

Bella Romero’s playground with Vetting 15H’s proposed site just beyond the fence.

Vetting 15H would prove to be one of the larger well pads in the county. And while its well heads remain just beyond the 1,000ft setback requirement from Bella Romero buildings, a significant portion of the school’s ballfields are within 1,000ft of the proposed site. When setbacks for the well pad and the processing facility are taken together—something not explicitly demonstrated in the permit—almost the entirety of school grounds are within 1,000ft and the school itself lies only 1,300ft from the pad. The below figures show the images supplied by Extraction Oil & Gas in their permit as well as a more detailed graphic generated by FracTracker.

 

Youth: A High Risk Population

The difference between 1,000ft and 1,300ft may be negligible when considering the risks of locating industrial scale oil and gas facilities near populated areas. The COGCC has issued 1,262 regulatory violations to drilling companies since 2010 (Extraction Oil & Gas ranks 51st of 305 operators in the state for number of violations). Some of these violations are for minor infractions such as failing to file proper paperwork. Others are for major incidents; these issues most often occur during the construction phases of drilling, where a number have resulted in explosions and emergency evacuations. Toxic releases of air and water pollution are not uncommon at these sites. In fact, the permit shows drainage and potential spills from the site would flow directly towards Bella Romero school grounds as is shown in the figure below.

Vetting 15H post-development drainage map.

Vetting 15H post-development drainage map.

A host of recent research suggests that people in close proximity to oil and gas wells experience disproportionate health impacts. Emissions from diesel engine exhaust contribute to excessive levels of particular matter, and fumes from separators generate high levels of volatile organic compounds. These pollutants decrease lung capacity and increase the likelihood of asthma attacks, cardiovascular disease, and cancer (read more on that issue here). Exposure to oil and gas facilities is also linked to skin rashes and nose bleeds.

As we’ve mentioned in our analysis of oil and gas drilling near schools in California, children are more vulnerable to these pollutants. The same amount of contaminants entering a child’s body, as opposed to an adult body, can be far more toxic due to differences in body size and respiratory rates. A child’s developing endocrine system and neural pathways are also more susceptible to chemical interactions. These risks are increased by children’s lifestyles, as they tend to spend more hours playing outdoors than adults and, when at school, the rest of their day is spent at a central location.

At the June 7th public hearing Extraction Oil & Gas noted that they intend to use pipelines instead of trucks to transport water and gas to and from Vetting 15H to reduce possible exposures. But, as residents of Greeley noted of other projects where similar promises were made and later rescinded, this is dependent on additional approvals for pipelines. Extraction Oil & Gas also said they would use electric drilling techniques rather than diesel engines, but this would not eliminate the need for an estimated 22,000 trucking runs over 520 days of construction.

Below is a table from the Vetting 15H permit that shows daily anticipated truck traffic associated with each phase of drilling. The estimated duration and operational hours of each activity are based on only 12 wells since construction is planned in two phases of 12 wells at a time. These numbers do not account for the trucking of water for completions activities, however. The figures could be much higher if pipelines are not approved, as well as if long-term trucking activities needed to maintain the site are included in the estimates.

Vetting 15H daily vehicle estimates.

Vetting 15H daily vehicle estimates from permit

 

At the Top of the Most Vulnerable List

Bella Romero Academy has the unfortunate distinction of being one of the few schools in Colorado in close proximity to a horizontal or directional well amongst 1,750 public and 90 private schools in the state. Based on our analysis, there are six public schools within 1,000ft of a horizontal or directional well. At 2,500ft we found 39 public schools and five private schools. Bella Romero is presently at the top of the list of all schools when ranked by number of well heads located within a 1,000ft buffer. An 8-head well pad is only 800ft across the street from its front door. If the Vetting 15H 24-head well pad was to be constructed, Bella Romero would be far and above the most vulnerable school within 1,000ft of a well. It would also rank 3rd in the state for well heads located within 2,500ft of a school. The tables below summarize our findings of this proximity analysis.

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total.

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total

Colorado private schools within 2,500ft of a horizontal or directional well

Colorado private schools within 2,500ft of a horizontal or directional well

The following interactive map shows which schools in Colorado are within a range of 2,500ft from a directional and horizontal well. Additional buffer rings show 1,000ft and 500ft buffers for comparison. 1,000ft was selected as this is the minimum distance required by Colorado regulations from densely populated areas and schools without requiring special variances. Environmental advocacy groups are presently working to change this number to 2,500ft. The map is zoomed in to show the area around Bella Romero. Zoom out see additional schools and click on features to see more details. [NOTE: The Colorado school dataset lists Bella Romero Academy as an elementary/middle school. Bella Romero was recently split, with the elementary school moving a few blocks west.]

Map of schools and setbacks in Colorado

View map full screen | How FracTracker maps work

Environmental Injustice

Drilling near Bella Romero is also arguably an environmental justice issue, as its student population has some of the highest minority rates in the county and are amongst the poorest. According to coloradoschoolgrades.com, Bella Romero is 89% Hispanic or Latino and 3% African American whereas, according to the U.S. Census Bureau, Greeley as a whole is 59% White and 36% Hispanic or Latino. 92% of Bella Romero’s students are also from low income families. Furthermore, according to the EPA’s Environmental Justice Screening Tool, which is used by the agency to assess high risk populations and environments, the community surrounding Bella Romero is within the 90-95% percentile range nationally for linguistically isolated communities.

Many of Bella Romero's students come from low-income communities surrounding Greeley.

Many of Bella Romero’s students come from low-income communities surrounding Greeley.

 

Implications

These statistics are significant for a number of reasons. Firstly, oil and gas permitting in Colorado only requires operators to notify residents immediately surrounding proposed well pads. This rule does not include residents who may live further from the site but send their students to schools like Bella Romero. Parents who might comment on the project would need to hear about it from local papers or neighbors, but language barriers can prevent this from occurring. Another factor we witnessed in our June visit to Latino communities in Weld County is that many students have undocumented family members who are hesitant to speak out in public, leaving them with no voice to question risks to their children.

Residents of Greeley speak out at the June 7th Planning Commission meeting.

Residents of Greeley speak out at the June 7th Planning Commission meeting

Nevertheless, at the June 7th Planning Commission hearing, Weld County administrators insisted that their decisions would not take race and poverty into consideration, which is a blatant disregard for EPA guidelines in siting industrial development in poor minority communities. Weld County’s Planning Commission claimed that their ruling on the site would be the same regardless of the school’s demographics. By comparison, another proposed Extraction Oil & Gas site that would have brought a 22-head well pad to within 1,000ft of homes in a more well off part of town was denied on a 0-6 vote by the City of Greeley’s Planning Commission earlier this year after nearby residents voiced concerns about the potential impacts. Extraction Oil & Gas appealed the ruling and Greeley City Council passed the proposal in a 5-2 vote pending additional urban mitigation area permit approval. While the Greeley Planning Commission and the Weld County Planning Commission are distinct entities, the contrast of these two decisions should emphasize concerns about fair treatment.

Conclusion

There are very real health concerns associated with siting oil and gas wells near schools.  When evaluating this project, county administrators should assess not only the immediate impacts of constructing the well pad but also the long-term effects of allowing an industrial facility to operate so close to a sensitive youth population. There are obvious environmental justice issues at stake, as well. Public institutions have a responsibility to protect marginalized communities such as those who send their children to Bella Romero. Finally, approving the Vetting 15H project would place Bella Romero far at the top of the list for schools in Colorado within 1,000ft of oil and gas wells. School board administrators should be concerned about this activity, as it will undoubtedly put their students’ health and academic performance at risk. We hope that, when the County Commissions review the proposal, these concerns will be taken into account.