Class 1 Conversion FAQ's


Background

Buckeye Brine established an operation in Coshocton County in 2012 to receive and dispose of oil and gas wastewaters via injection in a Class II injection well. These wastewaters are generated throughout the life of an oil or gas well: drilling, completion, and production. They include wash waters from drilling rigs, flowback from fracking operations, and saltwater from production. Today, Buckeye Brine’s facility houses three Class II wells—the Adams #1, #2, and #3—all three of which can only be used for fluids from the oil and gas industry.

Buckeye Brine needs to diversify its business base, and is now seeking Class I permits from Ohio EPA on two of our wells. These new permits will allow us to manage non-hazardous industrial wastewaters as well as the oil and gas wastes we’ve been handling. Ohio EPA will seek public input on the two permits—likely in early summer 2018.

Some basic information about the project follows.

1. How is this different from what’s already going on?
Currently, we inject only non-hazardous brine and other waste fluid originating in the oil and gas drilling industry. We do this under a Class II permit issued by the Ohio Department of Natural Resources’ Division of Oil and Gas. A Class II permit only allows for the injection of oil and gas wastewaters.

The Class I permit will allow us to take non-hazardous wastewaters from other industries. The fundamental principles of how Class I and Class II wells are permitted, constructed, and operated are very similar. However the permitting, development, and operating requirements for Class I wells are much more stringent.

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2. If Class I wells have higher standards, how can a Class II well be converted?
Buckeye Brine’s goal from the outset has been to provide the oil and gas industry with the safest, most secure disposal possible. Our management team has extensive background and expertise in industrial waste injection wells and we believe that salt-laden oilfield wastewaters deserve the same level of care as other industrial wastewaters. Accordingly, our aim from the outset was to build all of our wells to the same rigorous standards required for Class I wells.

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3. What kind of wastes will this permit allow the facility to receive?
Our facility will still only accept non-hazardous wastes. Many of these wastes are currently being disposed of at wastewater treatment plants that are ill-equipped to handle them, resulting in discharge to streams and other surface waters. With a Class I permit, our facility will give Ohio businesses a better, safer way to dispose of those wastewaters.

Examples of industrial waste that may be accepted under a Class I permit include water with trace oils, which can upset a wastewater treatment plant’s operations; and water with a high nutrients content, which can create algae blooms if discharged into surface waters. Other examples include:

• Landfill leachate
• Soap streams
• Metalworking fluids
• Glycols
• Water from oily waste streams
• Ammonia-laden wastewater
• Pipeline test waters
• Gas compressor wastes
• Food wastewaters

It’s important to note that our facility will NOT be permitted to receive hazardous waste. That means we can’t and won’t accept wastes that are ignitable, reactive, corrosive, or toxic according to EPA definitions, nor can we accept “Listed Wastes,” which are wastes EPA defines as hazardous, whether or not they exhibit a hazardous characteristic. Permission to inject hazardous waste requires an additional permit from U.S. EPA. Buckeye Brine doesn’t have any interest in obtaining such a permit or being in that business.

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4. What happens to these waste waters now?
The typical disposal of virtually all non-hazardous wastewaters are directed to:

• POTW’s – Publicly Owned Treatment Works – local municipal sewer systems, for treatment and dilution prior to being discharged into surface waters
• CWT’s – Centralized Wastewater Treatment facilities, similar to POTW’s, but are private companies accepting typically only commercial/industrial waste waters, treating and discharging into POTW’s or surface waters
• Direct dischargers – With an NPDES (National Pollutant Discharge Elimination System), discharge directly into surface waters, with or without prior treatment
• Sanitary Landfills - Liquids are ‘solidified’ utilizing specific solidification materials, but most often other waste streams (garbage), and placed in a landfill cell. Free waters that develop in the cell (leachate) are collected and transported to POTW’s, CWT’s, or directly discharged into surface waters

The water (and any untreated contaminants) from these operations remain in the ecosystem and are discharged back to surface waters. These practices are contributors to the algal blooms that occur in the lakes and rivers of Ohio.

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5. How will the operation differ from current operations?
There will be no noticeable change to our daily operations, and we won’t be receiving any more trucks than we do today. Inside the plant, though, the Class I protocols require more analysis of incoming waste streams, more monitoring of injection parameters, and more recordkeeping than Class II permits. However, because of our commitment to safety and quality control, our existing practices are very similar to what the new permits will require.

We will still have a Class II permit on the Adams #2 well, which requires that the oil and gas wastewaters we receive for injection stay separated from the industrial wastewaters we would receive under the Class I permit. This will require some modifications to our plumbing and tankage system. The other mechanical change will be a more stringent annular pressure monitoring method.

Our waste acceptance plan and receiving procedures are already modeled after industry best practices for commercial industrial waste operations and these procedures, described in our Class I permit application, don’t differ significantly from what we’re already doing.

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6. Will the facility receive water from out of state?
In 2017, less than 3% of our total receipts originated out of state. Although the Class I permit may increase that percentage somewhat, we don’t expect it to become a big part of our receipts. Situated as we are in the interior of the state, we think transportation costs will render us relatively uncompetitive for wastewaters in other states. To be sure, total receipts at our facility from all areas won’t increase.

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7. How is underground injection regulated?
The U.S. EPA regulates injection wells under the Safe Drinking Water Act through its Underground Injection Control program. In Ohio, U.S. EPA has delegated its authority to the state. The Ohio Division of Natural Resources’ Division of Oil and Gas regulates Class II wells for the oil and gas industry, and the Ohio EPA regulates Class I industrial wells. State rules must, at a minimum, contain all federal requirements, and Ohio’s Class I rules have significant additional requirements.

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8. What about earthquakes?
Nationwide, there are 180,000 Class II injection wells and 800 Class I wells. Earthquakes induced by these wells are extremely rare, and when detected, they are well publicized. Earthquakes as low as 3.0 on the Richter scale might be felt, although it takes a much stronger quake to create property damage. The few seismic events that are large enough to be felt occur when injected fluid encounters an unknown fault—most likely in areas with heavy faulting.

To be certain, seismicity is an important consideration when scouting appropriate locations for an injection well. We chose Coshocton County in part because it isn’t considered prone to earthquakes. The map below shows the historical record of earthquakes recorded in Ohio.

Regardless of an area’s risk level, ODNR has a relatively new policy affecting the newer permits statewide. Our Class II permit for the Adams #3 required that we monitor the seismic activity 60 days before and 180 days after operations began. The pre-operational monitoring established baseline conditions to compare with conditions observed once we started operating the well. To collect the data, we installed an array of seismic monitors in three directions within about a mile of the site. The data was transmitted directly via cellular network to third-party monitoring service and then to staff seismologist at ODNR for oversight. No activity of concern was observed. Again, because of our commitment to safety and quality control, we continue to gather this data even though we’re not required to.

Our Class I application requires even more study. We shot about 2.5 miles of seismic in each of four directions from the site. The resulting seismic mapping in our Class I permit application revealed no faulting that might induce a tremor.

Buckeye Brine has been subject to the demanding, but different, seismic requirements of both ODNR and Ohio EPA. We’ve also taken a close look at the geological formations immediately surrounding our wells –a process called downhole logging–that helps round out the picture. Our site’s seismic situation has been more rigorously studied than almost any other injection facility in the nation.

Finally, there’s our site’s history. Usually if a well induces a tremor, it will do it soon after operations begin or not at all. After over five years of operation, our site has not experienced any incidents of induced seismic activity.

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9. What about radioactivity?
New streams of wastewaters allowed under our Class I permits will not have elevated levels of naturally-occurring radiation. The wastewater we currently manage from oil and gas operations contains naturally-occurring radiation levels well below all regulatory requirements for management at our facility, and the U.S. EPA considers injection to be a very appropriate option for managing it. Prior to injection, solids that we accumulate have a higher level of radioactivity and are hauled offsite for disposal at an approved landfill. Our employees don't get exposed to to a dose higher than the naturally occurring levels measured on and around our property. Manmade nuclear waste has never been allowed at our facility and never will be.

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10. What about risks to groundwater?
Cases of groundwater contamination associated with injection facilities are usually the results of surface spills due to poor housekeeping and tank maintenance, not with the injection well itself. In our case, we exceed the most stringent standards for liquid waste storage and handling. Our concrete secondary containment system is designed to hold the contents of the maximum possible spill, plus a 25-year rainfall event. In addition, our entire facility is underlain with a 60-mil HDPE plastic liner and a sand layer between it and the concrete with a French drain system. In the extremely unlikely event that our concrete containment system developed a leak that we couldn’t see, this liner system would allow us to detect such a leak and pump the contaminated water from the contained sand layer. With respect to groundwater contamination from a Class I non-hazardous injection well itself, it’s extremely rare, and almost unheard of since the advent of federal regulation in the 1980s. Even before modern-day regulations, groundwater contamination from injection wells was rare, and the practice goes back to at least the 1930s.

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11. Why is this good for the Coshocton Community?
Buckeye Brine has added about 30 jobs since 2012 just from our payroll, and we’d like to add some more. This permit change won’t add a barrel to our current receipts—it’s about diversifying our company’s customer base, not increasing the volumes our facility is receiving. Still, it will add jobs. We’ll need more drivers, for example, because we’ll haul more of our inbound waste.

We believe Buckeye Brine and the Coshocton community are good business partners. We’ve had a positive impact on the life of our community and we’ve been warmly received. It’s a mutually beneficial relationship that can only get better as Buckeye Brine gets stronger.

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12. How are Class I wells regulated once they’re in operation?
Every year, we’ll be required to conduct several tests on each well:

• An annulus pressure test is a demonstration that our leak monitoring system is working properly. We monitor annular pressure in real-time and the well is equipped with an automatic shutoff if we detect an unusual change in pressure. The yearly annulus pressure test is conducted at higher pressures than our daily/real-time pressure testing and is used to assure that all components are operating well within a prudent margin of safety.

• A RAT test shows the geologic formation where the fluids are being injected and that the fluids aren’t migrating up the wellbore. The test requires the injection of extremely small quantities of regulated radioactive materials with an extremely short half-life. Management of the sources are subject to strict regulation by Ohio EPA, much like radioactive sources in medical settings.

• The bottom-hole pressure test shows the extent to which the pressure rises in the geologic formation, which gives an early indication as to whether the reservoir is approaching the limit on its capacity to receive fluids in the future. A gradual rise in bottom-hole pressure over the years is expected, but a sharp, sudden rise would serve as an early indicator to regulators that they might want to consider a change to permitted injection pressures.

Every other year, the two Class I wells must have a pressure falloff test, which gives Ohio EPA information about reservoir conditions to confirm the bottom-hole pressure test.

Every five years, we must conduct a differential temperature survey. This test enables a comparison of the temperatures of different strata present from the top to the bottom of the well, and assures that no fluid is somehow migrating to a higher formation. Any injected fluid that migrates out of the injection zone is unacceptable, even if it presents no threat to drinking water aquifers. Buckeye Brine, without being required to, already conducts a differential temperature survey every year and plans to continue to do so.

Ohio EPA inspectors must approve the date for any testing so can be present to witness the tests, and may otherwise visit for an unannounced inspections at anytime.

We’ll also be required to send to Ohio EPA monthly injection reports and quarterly instrument calibration reports.

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13. Does the public have a voice in the permitting process?
Ohio EPA has been reviewing our applications since last summer. We anticipate that by early summer 2018, Ohio EPA will likely complete draft permits and post notice of a public hearing and a 45-day comment period in the Coshocton Tribune. Anyone can file written comments with Ohio EPA during the comment period, or make comments in person at the public hearing. The comment period lasts 45 days.

Once a draft permit is issued, but before Ohio EPA’s public hearing, Buckeye Brine will invite local citizens to an information session to allow for questions and discussion with our management team about our operations and the draft permit. We’ll announce further details when Ohio EPA sets the timeline for the public input process.

Once the comment period concludes, the agency will publish responses to the comments received and consider whether they warrant changing permit terms. After that process, if the agency concludes the application meets the requirements of the rules, the agency will issue a final permit and publish it in Ohio EPA’s Weekly Review. The permit would become effective upon issuance or a stated effective date, and we would plan to start Class I operations within two to three months of receiving the final permit.

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14. Where can I get more information?
Here are some links to several government and research organizations with information about underground injection:

We plan to host a limited number of tours of our plant for interested citizens between now and the date of the permit hearing.

If you’re interested, or if you have other questions, please contact:

Buckeyebrine@gmail.com