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 permit 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 until October 26, 2018.

Some basic information about the project follows.

1. How is this different from what’s already going on?
Currently, we hold Class II permits from 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 permits will allow us to take non-hazardous wastewaters from other industries. The fundamental principles of Class I and Class II are very similar. However, the permitting, development, and operating requirements for Class I wells are much more stringent.

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. To our knowledge, no Class II well has ever been developed this way.

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 industrial wastes are currently being disposed of at wastewater treatment plants that are ill-equipped to handle them, resulting in discharge of these pollutants to streams and other surface waters. With Class I permits, 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:

• Soap streams
• Metalworking fluids
• Glycols
• Water from oily waste streams
• Landfill leachate
• 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.

4. What happens to these waste waters now?
Disposal of virtually all non-hazardous wastewaters are directed to the following types of facilities:

• POTWs – Public Owned Treatment Works (POTWs) are municipal treatment plants that discharge into surface water. Many of them accept the types of wastewaters we’re interested in, although they weren’t designed with these kinds of wastes in mind. In many cases, these plants do is dilute the constituents to a level that should—but often don’t—meet the discharge standard of their permits.
• CWT’s – Centralized Wastewater Treatment (CWT) facilities are operated by private companies and typically only accept commercial and industrial wastewaters by truck, then treating and discharging them into POTWs or surface waters.
• Direct dischargers – With an NPDES (National Pollutant Discharge Elimination System) permit, wastewaters may be discharged directly into surface waters after any treatment that may be necessary.
• Sanitary Landfills - Liquids are ‘solidified,’ sometimes with a bulking agent such as sawdust and sometime with other waste streams, for disposal in a landfill. Free waters that develop in the bottom of the landfill cell (leachate) are eventually collected and—once again—transported to POTW’s or CWT’s for discharge into surface waters.

However they’re rearranged, the contaminants from these operations remain in the biosphere and are discharged back to surface waters. These practices contribute to the algae blooms that occur in the lakes and rivers of Ohio as well as many other problems with water quality.

5. How will the operation differ from current operations?
From the road, there won’t be any 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 longstanding commitment to superior 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 stay separated from the industrial wastewaters that we’ll receive under the Class I permit. Keeping the two types of waste separated 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. These procedures, described in our Class I permit application, don’t differ significantly from what we’re already doing.

6. Will the facility receive water from out of state?
In 2017, less than 3% of our total receipts from the energy industry originated out of state. Although receipt of the industrial wastewaters may increase that share somewhat, we don’t expect this new business to change that percentage very much. Situated as we are in the interior of the state, we think transportation costs will usually render us uncompetitive for wastewaters in other states. To be sure, total receipts at our facility from all areas won’t increase.

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. With the new permits, inspectors from both agencies will be visiting us—sometimes without notice. Neither agency has the authority to permit the injection of hazardous wastes, and we’re not interested in the federal permit required to do so.

8. What about earthquakes?
Nationwide, there are some 180,000 Class II injection wells and 800 Class I wells. Earthquakes induced by the very few of these wells are extremely rare, and when they’re felt by individuals in the area, they make the news. 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 rare 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 sure, 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 policy affecting the newer permits. 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 real-time via cellular network for oversight by staff seismologists at ODNR. No activity of concern was observed during the monitoring period. Again, as part of our commitment to the highest level of 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 of the seismic situation. We shot about 10 miles of seismic lines--2.5 miles 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. Through a research partnership with Battelle Memorial Institute, we’ve had the benefit of cutting-edge analytical techniques employed by world-class earth scientists. We believe 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 so soon after operations begin or not at all. After six years of operation, our vicinity hasn’t experienced any seismic activity of any kind.

9. What about radioactivity?
The wastewaters we currently manage from oil and gas operations contain naturally occurring radiation levels well below all regulatory requirements for management at our facility. However, U.S. EPA concerns itself with even very low levels, and considers injection to be a very appropriate option for managing these wastes. Prior to injection, solids that settle out of our oil and gas wastewaters have a higher level of radioactivity than the waters and are hauled offsite for disposal at an approved landfill. Our employees don't get exposed to a dose higher than the naturally occurring levels measured on and around our property. Regulators have never allowed manmade nuclear waste and never will. Unlike materials from the oil and gas industry, wastewaters allowed under our Class I permits will not have elevated levels of naturally-occurring radiation.

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 tank contents of the maximum possible spill, plus a 25-year rainfall event, even though these concrete containment structures should never come in contact with anything more than drips and rainwater. In addition, our entire operational area is underlain with a 60-mil plastic liner and a sand layer between it and the concrete to function like a French drain system. In the extremely unlikely event that our concrete containment system did developed a leak that we couldn’t see, this tertiary liner system would allow us to detect such a leak and pump the water from the contained sand layer. Groundwater contamination from a Class I injection well itself is almost unheard of since the advent of federal regulation in the 1980s. Even before modern-day regulations, groundwater contamination from injection wells was extremely rare, and the practice goes back to at least the 1930s.

11. Why is this good for the Coshocton Community?
Buckeye Brine has added about 35 jobs to the Coshocton County economy since 2012 just from our own 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 have been good for each other. 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.

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 annular pressure test is conducted at higher pressures than our daily, real-time pressure monitoring 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 assures that the fluids aren’t migrating up the wellbore. The test requires the injection of minute quantities of regulated radioactive material with an extremely short half-life. Much like radioactive sources in medical settings, managing these sources is subject to strict regulation by Ohio Department of Health.

• A 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 there’s no pathway to the drinking water aquifers thousands of feet uphole. Buckeye Brine, without being required to, already conducts a differential temperature survey every year.

Ohio EPA inspectors must approve the date for any testing so they can be present to witness the tests. They may otherwise enter the site for unannounced inspections at anytime. We’ll also be required to send to Ohio EPA monthly injection reports and quarterly instrument calibration reports.

13. Does the public have a voice in the permitting process?
Ohio EPA has been reviewing our applications since the summer of 2017 and has completed draft permits for public inspection. It has posted legal notice in the Coshocton Tribune of a public hearing on October 18 and a comment period that runs to October 26. Anyone can file written comments with Ohio EPA during the comment period, or make comments in person at the public hearing. Comments by members of the public, whether written or delivered at the hearing have the same effect: EPA staff will consider and respond to all of them after the comment period is closed.

Once the comment period closes, the agency has 30 days to publish responses to the comments received and consider whether they warrant changing permit terms. After considering all comments, if Ohio EPA still concludes that the application meets the requirements of the state’s rules, the agency will issue a final permit and publish it, along with responses to public comments, in Ohio EPA’s Weekly Review. The permit would typically become effective upon publication, and we would plan to start Class I operations within two to three months of receiving the final permit.

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

• US EPA: On safety of Class I wells
• Ohio EPA: Underground Injection Control (UIC) Program
• Groundwater Protection Council: Underground Injection Control
• Groundwater Protection Council: Injection Wells: An Introduction to Their Use, Operation & Regulation

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