Ohio’s Waste Not, Want Not!

By Ted Auch, PhD – Ohio Program Coordinator, FracTracker Alliance

The Akron Beacon Journal’s Bob Downing has just published an investigative report looking at the recent advisory put forth by the Ohio Environmental Protection Agency’s (OEPA) Division of Materials and Waste Management – along with the Ohio Department of Natural Resources (ODNR) Division of Oil and Gas Resources Management and the Ohio Department of Health (OHD) [1] Bureau of Radiation Protection – to all of Ohio’s municipal solid waste landfills. The advisory suggests that the landfills statewide – including 17 industrial residual waste, 40 municipal solid waste, 36 orphaned landfill facilities along with 64 transfer stations – should prepare to start receiving solid Utica and Marcellus shale drilling waste, “including drill cuttings, drilling muds, and frac sands,” (especially since Pennsylvania seems to be cracking down on some of its traditional drilling waste disposal practices). This new waste stream is in addition to the millions of barrels of potentially radioactive liquid waste already being trucked in from PA and WV [2] for deep well injection – and potentially shipped into Washington County, OH along the Ohio River [3]. This advisory is concerning because the same regulatory bodies have been conveying to other media outlets (e.g. The Columbus Dispatch) that such activities are strictly prohibited and that injection of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) is “almost the perfect solution” compared to to landfill disposal.

If the advisory is correct, however, there are complications associated with using this disposal method relative to the waste’s viscosity, elevated levels of Total Dissolved Solids (TDSs), and/or concentrations of TENORM. Materials deemed suitable for municipal landfills must not exceed five picocuries per gram radium above background levels; however, early returns speak to the potential for shale wastewater to be:

… 3,609 times more radioactive than a federal safety limit for drinking water…[or] 300 times higher than a Nuclear Regulatory commission limit for industrial discharges to water. Learn more

Additionally, Marcellus brine may have salinity and radium levels three times that of traditional sandstone/limestone oil and gas wells of the Cambrian-Mississippian age. To put this Marcellus data in perspective, the range was 0-18 picocuries per gram with a median value of 2.46 picocuries per gram. Issues associated with brine disposal, however, are not new here in Ohio where researchers like The Ohio State University’s Wayne Pettyjohn reported excessive levels of freshwater chloride (35-320,000 mg/l) pollution in Morrow, Delaware, and Medina counties. These results prompted Pettyjohn to write “ground-water resources may be seriously and perhaps irreparably contaminated long before landowners are even aware that a problem exists” (Pettyjohn, 1971).

The solution proposed by the authors of this advisory is to use the US EPA’s “paint-filter test” bringing materials into compliance with Code of Federal Regulation (CFR) 264.313 and 265.313, which basically ended the practice of disposing of “liquid waste or waste containing free liquids” in 1985. The EPA’s Paint Filter Liquids Test (Method 9095B) is summarized as follows:

Material is placed in a paint filter [Mesh number 60 +/- 5% (fine meshed size)] [4]. If any portion of the material passes through and drops from the filter … the material is deemed to contain free liquids.

Figure 1. Ohio’s Registered Non-Hazardous & Hazardous Waste Landfills

Figure 1. Ohio’s Registered Non-Hazardous & Hazardous Waste Landfills

This advisory is likely due to the backlash associated with injection well incidents, including the Youngstown earthquakes attributed by some scientists to the lubrication effect that injected materials have on geologic faults. Additionally, rural communities – and researchers – in Ohio’s Utica Shale basin are beginning to raise questions around the practice of spreading shale gas brine on roads as a substitute for salt in the winter and approved disposal method during the summer. Concerns revolve around elevated levels of chlorides in excess of 2-5 times EPA public drinking-water standards (Bair and Digel, 1990). Unfortunately, the OEPA advisory is ambiguous about post-disposal monitoring, suggesting only that:

… the landfill may need to perform monitoring of landfill systems, such as those related to leachate collection, to determine potential impacts to human health or the environment associated with these [TENORM] waste streams.

This inclusion of the word may rather than must further alienates communities already skeptical about the ability or will of ODNR – and now OEPA and ODH – to regulate and/or ensure adequate monitoring of unconventional natural gas drilling activities. If this advisory is any indication related activities will be spreading beyond the Utica Basin to the state’s 21 hazardous and 121 non-hazardous waste facilities (Figure 1), with specific focus on the 57 industrial residual and municipal solid waste facilities throughout the state (Figure 2 below). Such a regulatory development has serious ramifications for PA’s 40+ municipal waste landfills, 5 construction/demolition waste landfills, 3 residual waste landfills, and 6 resource recover/waste to energy facilities (see full PA stats) and the nation’s 1,908 Municipal Solid Waste (MSW) landfills as reported in BioCycle (2010).

As drilling intensifies in the Utica Shale, nearby states may be further burdened by the mounting waste stream. Communities once thought to be disconnected from hydraulic fracturing will be forced to debate the merits of allowing such waste in their communities, similar to the situation facing non-Utica Shale cities in Ohio. Such a discussion will be unavoidable given that 84% of the state’s waste treatment facilities are located outside what could liberally be referred to as the Ohio Shale play (Figure 2 Inset).

Figure 2. Ohio’s Registered Non-Hazardous Waste Facilities by Type (% of the state’s 121 facilities)

Figure 2. Ohio’s Registered Non-Hazardous Waste Facilities by Type (% of the state’s 121 facilities)

[1] The ODH co-signed the OEPA advisory even though its own radiation-protection chief Michael Snee told The Columbus Dispatch that “wastes trucked to landfills pose a bigger threat to groundwater” relative to injection wells only days prior to the OEPA advisories release last September.
[2] 53% of the 12.2 million barrels of brine injected into Ohio’s 160 injection wells came from these neighboring states (PA and WV).
[3] The company proposing the Washington County landfill in New Matamoras is confident that the shipping of shale gas drilling waste is safe because “barges ship hydrochloric acid,” as their VP of Appalachian business development told The Columbus Dispatch.
[4] Mesh number 60 is in the lower third of the US Sieve size distribution with an opening of 0.250 mm or 0.0098 in, with the smallest sieve size being No. 400 at 0.037 mm. or 0.0015 in. Learn more>

Lakes in Appalachian Ohio’s Utica Play: A Snapshot

By Ted Auch, PhD – Ohio Program Coordinator, FracTracker Alliance

Ohio’s southwest Appalachian counties – namely Carroll, Harrison, Guernsey, and Noble Counties – are home to two significant resources:

  1. the state’s Utica Shale Triple Play – defined as the extraction of “natural gas and natural gas liquids…from the Marcellus Shale…Upper Devonian Shale…and the Utica Shale about 1,000 to 2,000 feet below the Marcellus” (Range Resources CEO, John Pinkerton); and
  2. many of the state’s premier lakes, including Atwood in Carroll and Tuscarawas and Senacaville in Noble and Guernsey counties (Figure 1).

Senacaville and Atwood Lakes provide countless ecological and economic benefits (a.k.a., Ecosystem Services) at a regional, state, and local level contributing substantially to the state’s $3.6 billion wildlife tourism economy – a number that is increasing by 2% per year according to the US Fish & Wildlife Service’s Wildlife & Sport Fish Restoration Program (WSFR). Needless to say, the unconventional natural gas industry, which uses approximately 5 million gallons of fresh water per drilled well, relies heavily on Ohio’s lakes, wetlands, and to a lesser degree vernal pools – all of which are concentrated in the Utica Shale sweet spot counties on the Pennsylvania and West Virginia borders. These same counties are home to nearly all the state’s 440+ Utica Wells and more than half its 160+ injection wells (used for waste fluid disposal) (Figure 2).

Recently – for these and other environmental reasons – many in the area have grown concerned that Appalachian Ohio’s entire lake network is at risk due to current and proposed hydraulic fracturing and injection wells. In an attempt to assess these risks, we analyzed the proximity of current Utica drilled wells and Class II/III [1] wells to these two lakes specifically and to the state’s inland perennial water bodies. Atwood Lake is the lake with the most wells – either injection or fracturing – within a five-mile radius with 19 total (Figures 3 and 4). Meanwhile, M.J. Kirwan Reservoir, Guilford, and Senacaville Lakes each have 12 wells within a five-mile radius. The Cuyahoga River, Lake Mohawk, Tappan Lake, and Berlin Lake are the remaining water bodies currently within five miles of 10 or more wells. Four of these 19 wells are within two miles of Atwood and Guilford Lake’s shores. In the case of Tappan and Berlin Lakes, 3 wells sit within two miles (Figure 4). Interestingly Tappan Lake’s integrity from a water quality perspective has come under pressure thanks to the Chesapeake Energy Dodson well according to Charles Fisher, administrator of the Harrison County Health Department and organic farmer John M. Luber as “a stream…that empties into Tappan Lake becomes discolored during periods of rainfall or melting snow…the pollution did not happen until drilling operations began.”

In researching previous natural resource activities in the Utica Shale Basin, we found that in addition to the many shale and injection wells in the vicinity of these lakes, most are surrounded or sit atop abandoned, underground coal mines (AUCM). One example is Senacaville Lake, where Seneca Coal’s Klondyke, Rigby, and Walholding AUCMs are within feet of the lake’s western shore. In addition, Akron Coal, James W. Ellsworth, and Cambridge Collieries’ AUCMs just to the west of Senecaville Lake lie directly beneath two Utica and two Class III wells, bringing into question the reported discrete nature of these types of extraction procedures with respect to their proximity to primary freshwater sources. The same is true for Atwood Lake, with six AUCMs less than a mile of its eastern extent – previously owned by the Ohio Central Mining Co., Burns Coal Co., White Barr Coal Co., Marshall Harvey, etc. (Figure 5).

The possibility for the disruption of regular inputs/outputs of these lakes’ hydrological cycles – specifically from a water quality or quantity perspective – is growing. This is the case because the interconnectivity (Setbacks Press Release V 3) between Utica and injection wells is increasing and due to the fact that many AUCM exist in the very areas where hydraulic fracturing is currently being conducted or has been proposed. As a result, many community organizations and non-profit environmental groups are looking to construct and implement a comprehensive water monitoring protocol in Ohio’s Utica Basin. However, given funding limitations and the lack of data being made available from Ohio’s Department of Natural Resource (ODNR) and Ohio Environmental Protection Agency (OEPA), these groups are being forced to prioritize water bodies of concern. Our research suggests that some of the state’s largest and most economically beneficial lakes – namely Senacaville, Atwood, Guilford, Tappan, and Berlin – are at the top of the list of stressed and/or potentially susceptible inland waters.

Figure 1. Eastern Ohio Utica Shale Basin - Click to enlarge

Figure 1. Eastern Ohio Utica Shale Basin

Figure 2. Ohio’s lakes, wetlands, and vernal pools relative to its Utica Shale and Class II/III injection wells - Click to enlarge

Figure 2. Ohio lakes, wetlands, & vernal pools relative to Utica Shale & Class II/III injection wells

Figure 3. The distribution of Ohio’s Utica Shale and Class II/III Injection wells with respect the region’s primary perennial water bodies at 1, 3, and 5 mile intervals

Figure 3. The distribution of Ohio’s Utica Shale and Class II/III Injection wells with respect the region’s primary perennial water bodies at 1, 3, and 5 mile intervals


Figure 4. Senecaville & Atwood Lake Region of Ohio’s shale geology, state parks, Utica Shale and Class II/III wells (Note: Pink & Green Circles represent 1 mile radius around Utica Shale and Class III Wells). - Click to enlarge

Figure 4. Senecaville & Atwood Lake Region of Ohio’s shale geology, state parks, Utica Shale & Class II/III wells

Figure 5. Senecaville & Atwood Lake Region of Ohio’s shale geology, state parks, Utica Shale and Class II/III wells, and Abandoned Underground Coal Mines (AUCMs) - Click to enlarge

Figure 5. Senecaville & Atwood Lake Region of Ohio’s shale geology, state parks, Utica Shale & Class II/III wells, plus Abandoned Underground Coal Mines

Note: Pink & Green Circles in Figures 4 and 5 represent a 1 mile radius around Utica Shale & Class III Wells.


1. From the ODNR: “Class II disposal wells include conventional brine injection wells, annular disposal wells, and enhanced oil recovery injection wells. Enhanced recovery injection wells are used to increase production of hydrocarbons from nearby producing wells… Additionally, DMRM also regulates Class III salt-solution mining wells, which are used to produce saturated brine from the salt deposits that occur from 2000 to 3500 feet below Ohio’s ground surface. The saturated brine is then used to make table salt, water softener salt, and salt blocks. All types of injection wells are designed to ensure safe injection into permitted formations.”

Word bubble using news headlines from Jackson study release

Duke Study Prompts Confusing Headlines

If you are like me and start your morning work routine by scrolling through the daily Marcellus Shale news with a good cup of coffee, then you are probably just as confused as the rest of us about the recent Duke University study results regarding shale gas drilling. Just take a look at the list below and try to interpret strictly from the news headlines what it is Nathaniel Warner, Dr. Robert Jackson, and colleagues actually found:

  • New research shows no Marcellus Shale pollution (
  • Marcellus Shale Study Shows Fluids Likely Seeping Into Pennsylvania Drinking Water (Huffington Post)
  • Rising Shale Water Complicates Fracking Debate (NPR)
  • Marcellus Brine Migration Likely Natural, Not Man-Made (Oil and Gas Online)
  • Duke study finds possible pathways from Marcellus shale to drinking water … (Akron Beacon Journal)
  • Fracking Did Not Sully Aquifers, Limited Study Finds (New York Times -blog)
  • Water contamination from shale fracking may follow natural routes (
  • Duke study: Fluids likely seeping into PA’s drinking water from Marcellus Shale (News & Observer)
  • Findings are mixed in fracking-water study (Pittsburgh Post-Gazette)
  • New study: Fluids from Marcellus Shale likely seeping into PA drinking water (
  • New research shows no Marcellus Shale pollution (The Wall Street Journal)
  • Marcellus Brine Migration Likely Natural, Not Man-Made (Duke University)
Word bubble created using Tagxedo showing news headlines from Jackson study release

No wonder this entire issue is so contentious. Not only is the science still evolving, but then you have to waft through the countless takes on what the research means. Perhaps we should take a cue from our childhood years and get the story “straight from the horse’s mouth.” E.g. try reading the official results (PDF) published in the Proceedings of the National Academy of Sciences. Even the abstract below will tell you a lot more about the implications of the results than any truncated news headline could:

The debate surrounding the safety of shale gas development in the Appalachian Basin has generated increased awareness of drinking water quality in rural communities. Concerns include the potential for migration of stray gas, metal-rich formation brines, and hydraulic fracturing and/or flowback fluids to drinking water aquifers. A critical question common to these environmental risks is the hydraulic connectivity between the shale gas formations and the overlying shallow drinking water aquifers. We present geochemical evidence from northeastern Pennsylvania showing that pathways, unrelated to recent drilling activities, exist in some locations between deep underlying formations and shallow drinking water aquifers. Integration of chemical data (Br, Cl, Na, Ba, Sr, and Li) and isotopic ratios (87Sr∕86Sr, 2H∕H, 18O∕16O, and 228Ra∕226Ra) from this and previous studies in 426 shallow groundwater samples and 83 northern Appalachian brine samples suggest that mixing relationships between shallow ground water and a deep formation brine causes groundwater salinization in some locations. The strong geochemical fingerprint in the salinized (Cl > 20 mg∕L) groundwater sampled from the Alluvium, Catskill, and Lock Haven aquifers suggests possible migration of Marcellus brine through naturally occurring pathways. The occurrences of saline water do not correlate with the location of shale-gas wells and are consistent with reported data before rapid shale-gas development in the region; however, the presence of these fluids suggests conductive pathways and specific geostructural and/or hydrodynamic regimes in northeastern Pennsylvania that are at increased risk for contamination of shallow drinking water resources, particularly by fugitive gases, because of natural hydraulic connections to deeper formations.

In all fairness, this study is very technical, so writing a catching but accurate news headline is extremely difficult. It is important to keep in mind, however, that summaries written for the lay public will often contain a piece of the translator’s perspective – like snippets of foreign code embedded in the story.

By Samantha Malone, MPH, CPH – Communications Specialist, FracTracker; DrPH Student, University of Pittsburgh Graduate School of Public Health, Environmental and Occupational Health department

Updated Drilled Wells Data for PA

Three drilled wells datasets for Pennsylvania have been updated or created, including:

The last of the three datasets is the most unique, with data spatially joined to municipalities. The following two maps exhibit the Marcellus Shale related data that they contain:

Number of Marcellus Shale wells per PA municipalities as of December 16, 2011. Click the gray compass rose and double carat (^) to hide those menus. Then click the information tool (the blue “i”) then any map feature for more information.

Number of Marcellus Shale wells in PA municipalities per square mile, as of December 16, 2011. Area calculation performed in PA State Plane South.

Violations per Well by Operator, Part 2: Bad Actors

Recently, I conducted an analysis of the legacy of each Marcellus Shale operator’s violations over time, normalized by the number of wells each company has drilled, in a metric that I call Violations per Well, or VpW. While that analysis was cumulative, I’ve had FracTracker readers ask if the VpW from one year predicts the VpW for the following year, particularly among the bad actors. To help answer that question, I’ve taken the same raw data from the previous post, and recompiled it to help address that.

I’ve been looking at violations per well for some time, on the theory that it can be used to help score a company’s compliance history with regards to the Pennsylvania Department of Environmental Protection, which issues them. All of these wells and violations are Marcellus Shale specific, and come from sources posted on the DEP website.

For ease of use, I’ve color coded the results, with bright green being the best scores, and bright red being the worst. Companies without wells for a given year are indicated in pale blue. They may either indicate drilling operators that were inactive in a given year, or midstream companies that haven’t drilled any well. Here’s the color coded key:

And here are the results:

To look at the bad actors from 2010, I selected all of the entries that were colored burgundy or bright red for that year’s VpW score. How have they fared so far in 2011?

To be fair, I should point out that operators with very few wells can get obnoxious VpW scores in a hurry. On the other hand, there were 14 Marcellus Shale operators with at least one well drilled in 2010 that didn’t get any violations that year. Therefore, in this instance, I’ve included all operators with a VpW of 1.00 or greater, and will leave questions about sample size up to the reader.

Five of the operators with VpW scores of 1.00 or higher haven’t drilled any wells at all in 2011 so far. In fact, all of them had VpW scores of at least 2.50. There may be a variety of reason for their absence in 2011, but honestly, their lack of compliance isn’t missed.

Nine operators improved from 2010 to 2011, four of which improved all the way into green categories. This is the result that we want to see, where companies appear to be responsive to violations issued by the DEP. Notable among this group is Citrus Energy, which had a huge amount of violations compared to one drilled well in 2010, to a VpW score under 0.50 so far in 2011. Also, PA Gen Energy is an operator with a significant number of wells that went from a red to a green category, which is encouraging to see. Cabot, on the other hand, barely budged, and remains over 2.00 violations per well.

There are also three operators from 2010 with VpW scores of 1.00 or greater that actually got worse in 2011. And keep in mind, the data used includes almost two more months of drilled wells than violations, so inclusion in this group is especially dubious. They include Rice Drilling B, whose VpW more than duobled to 2.13; XTO, which went from awful to horrific since becoming a subsidiary of ExxonMobil; and Ultra Resources, whose performance has been nothing short of ghastly in 2011. Luckily, Ultra has been leaving the Keystone State alone since January–let’s hope it stays that way.

I maintain that since so many operators–big and small–are able to keep their violations to wells ratio at less than 1:2, all of the operators that operate in Pennsylvania’s Marcellus Shale should try to reach that standard.  Those that show a continued disregard for our laws protecting our environment should face stiff fines for their complacency, while those operators that average more than two violations per well drilled over a prolonged period of time need to be banned.

Violations per Well by Operator Over Time

The following chart contains all operators that have either drilled a Marcellus Shale well in Pennsylvania from March 6, 2006 to November 27, 2011, or have been issued a Marcellus Shale related violation by the Pennsylvania Department of Environmental Protection between January 1, 2008 and September 30, 2011. Results are cumulative, thereby reflecting each company’s legacy with the Marcellus Shale, rather than their performances for any given year. The Violations per Well (VpW) score has been color coded for easy reference, with the following scale:

Most companies that are issued violations are well operators, although there do seem to be some midstream companies on the violation list. This might account for some of the blue “No wells” below, but mostly they reflect operators that were not yet active. For example, Antero Resource’s first well was in 2010, so entries for 2008 and 2009 read as “No wells”.

Whenever we look at Marcellus operators over time, the changes in companies has to be dealt with in some way. In this case, I took a minimalist approach: while East Resources, Inc. and East Resources, Llc. were combined, I did not merge name changes that were more substantial than that. For example, even though CNX Gas and Consol Gas are both owned by Consol, I did not merge the two. Another example is St. Mary Land and Exploration changed its name to SM Energy, and those two entries were left unchanged. Because of all of the changes within the industry, I have included the most recent drill date, so that viewers can determine if the drillers are still active.