Buckeye Brine
Ohio EPA
Attention: Jess Stottsberry
I have included several reasons that the Buckeye Brine wells should not be allowed to go from class 2 to class 1:
I toured the Buckeye Brine facility on 6.5.2018 and was given a 90 minute tour by Monty Shell. I later got to meet David Durakovich. I was shown two pipes exiting the high pressure pumps and their secondary concrete containment and 10 feet later were encased in concrete. Unfortunately during that 10 feet, the pipe did not have secondary containment for a pipe carrying fracking waste water at greater than 1000 psi. After discussing this with both Monty and David, they promised me they would “look into it”. I was only there for 90 minutes yet the Buckeye Brine safety team, their design engineer, their supervisors, and even ODNR did not find this obvious flaw. That concerned me, so I examined their website, ODNR requirements, and submissions to the EPA for any additional problems.
ODNR deficiencies were easy to find. ODNR requires owners of oil and gas wells drilled between 2000 and 4000 feet to own a minimum of 20 acres and if greater than 4000 feet they need to own 40 acres. This means that landowners “own” the ground under which the well is located. Buckeye Brine is located on less than 18 acres and the wells are over 7000 feet deep and were allowed to drill very close to their property lines. How much of the already 10,000,000 barrels of wastewater is located just under Buckeye Brine property? Even section VI of Adams # 3 on page 1 states ”ODNR could not conclusively conclude which formation(s) are receiving the injectate or percent of total volume”. The wells were drilled with ODNR oversight, but deficiencies were allowed to exist. Attachment C page 15 Cementing Program of Adam #1 states: ”During the cementing of the long string casing, circulation was lost to the injection interval and returns were not observed at the surface”. Wells which are not built correctly, should immediately be corrected or plugged.
“No core samples or undisturbed formation water samples were collected during the drilling and completion of the well” page 30 #843505. Since we have no core samples then 3745-34-14 of the administrative code for a class 1 permit to drill application has NOT been satisfied.
Part F (2) (b) Laboratory testing results:
(i) Cores for permeability;
(ii) Cores for compatibility;
(iii) Cores for porosity;
(iv) Analysis of formation water; and
(v) Descriptive core analysis and sieve analysis
Part (C) Proposed formation testing program to obtain analysis of the chemical, physical and radiological characteristics of the receiving formation including, but not limited to:
(4) Physical and chemical characteristics of the injection matrix;
(5) Compatibility of the injected fluids with the formation fluids;
(6) Corrosiveness; and
(7) Other applicable information.
Baseline data now is skewed due to 10,000,000 barrels of fracking waste water has entered and diluted what was already there. If sulfides or heavy metal salts or other corrosive products were already present what is this going to do to steel pipe over a period of time? Will the pipe be eroded? We already know we have lost a distal portion of the pipe in one Adams well. Why?
For the EPA to accept ODNR oversight for a class 1 well is a major overstep. It would be like me building a structure with inadequate structural deficiencies and later calling in the state to approve it as structurally sound commercial building. They would not even consider it and neither should the EPA.
Physics show that fluids move from areas of high pressure to areas of low pressure. Old Faithful in Yellowstone National Park is an example. We also know that water always seeks the path of least resistance. On the ODNR website under Industrial-Waste Disposal Wells in Ohio under Geological Considerations in Class 1 Injection under Structural Setting it states:
“In the subsurface environment, the natural flow of fluids, in general, follows the most direct path from areas of higher pressures to areas of lower pressures. Because the amount of overlying rock is the primary pressure-loading factor, this concept translates into flow from deeper environments to shallower environments along the path of least resistance. … If the site is located at the top of an arch or anticlinal feature, lateral flow away from the injection site would be impeded by the natural flow (toward the injection well) of native formation fluids. This latter situation is undesirable because the injectate will then be inclined to migrate vertically should vertical routes exist.”
There are 27 oil and gas wells within the Area of Review. Document #843505 table V.C. lists wells > 5200 feet. The 5200 feet is based on the analysis by the geologist representing Buckeye Brine that indicates that the shallowest top of a potential receiving zone for the Adams wells would be expected to be 5500 feet below ground level. Wells drilled to depths greater than 5200 feet would potentially place the bottom of their borehole within 300 feet of the injection interval. None of those oil or gas wells were drilled with class 1 safety measures. When oil and gas are removed, it lowers the pressure in the surrounding area and native water or possibly fracking waste water can take their place. This is not the only vertical transmission possibility.
The Coshocton Fault Zone, the Cambridge Arch, or the Coshocton Fracture Zone are documented but not well understood. If you believe the geologist paid by Buckeye Brine, it is not a normal fault, it is not a reverse fault, it is not a strike-slip fault. It is a growth fault like that found in the Gulf of Mexico Dome Province. A growth fault is a fault which initiates and evolves at the margins of continental plates. We have now injected 10,000,000 barrels of flowback water coming from shale gas wells which is loaded with high concentrations of slickwater chemicals. These chemicals that lubricate and reduce the viscosity of the water so it will not generate friction are being injected into a growth fault. We better hope it is NOT a growth fault.
A compression fracture is more plausible. A compression fracture occurs when one side is forced against another side and compression with micro fissures occur. This would explain the 112 foot discrepancy between the two wells which are only 921 feet apart. This would explain not only the widening of the layers but also the Airport Dome. Compression fractures do not produce a large fault but do produce micro fissures. The wire logs demonstrated micro fissures but no large cracks. It also showed the anomaly with folding and flexures present. In section II Adams # 3 page 81 it states:
“The most notable feature is on the west end of the line where there appears a down-to-the-west flexure …. Cannot be determined if the fabric is due to the structure (folding and / or faulting) … ”. As was stated above, water can go vertical if it encounters a structure blocking the flow of water.
Shale gas wells are cleaned with acids. The fracking water also has proprietary ingredients which they are not required to disclose. Unfortunately acids and CO2 products are problems which have not been adequately explored. Have you ever taken vinegar (acetic acid) and baking soda (NaHCO3) and mixed them together? The baking soda disappears in dramatic fashion. Concrete is made of cement which is limestone (CaCO3), clay, and aggregate. The dolomite cap is composed of CaMgCO3. If an acid is allowed to enter the reservoir it could cause erosion to the concrete around the steel pipe or to the cap rock. Solution caves are caves from limestone erosion with slowly moving water. What if that water is entering at > 1000 psi? It would be like taking salt water and a pressure washer to a concrete driveway 24 hours a day and possibly 365 days a year. The EPA website states that sequestering should last 10,000 years.
The Ohio EPA has a fact sheet on Requirements for Class 1 Injection Wells and Class 1 Hazardous Waste Wells. It states that “the injection zone must have no economic value.” Section VII Adams #3 page 15 states that there “was a gas show from the Rose Run.” On page 16, “Gas shows were more or less sustained for the next 250 feet.” If the injection wells are allowed to remain then no one will be able to access this important resource. The liability to drill in this area would be too great.
In the administrative Code for a Class 1 Permit Application 3745-34-13 (D) area of Review (3) (f) Springs, they responded with the answer “None identified within the AOR”. He must live in flat country and not in hill country. Of course we have springs within the AOR, we live in hill country. Did he not examine the area? If he lied on this part of his answer, are his other answers suspect?
Under #843505 on page 13, they stated “Buckeye Brine, as a legal entity, currently has not ever owned or operated any Class 1 wells.” This is technically correct but on page 15 they were to list all class 1 injection wells that the owner or operator has operated and is operating. They responded “N/A”. The owner of Buckeye Brine has and does operate class 1 wells. This is a blatant lie. This is a major transgression and should be dealt with a “Denied”.
Since the EPA is responsible for the safety of our drinking water, since the above examples demonstrate the lack of continuity from ODNR to EPA jurisdiction, since the city of Coshocton has their aquifer within one mile of the wells, since vertical penetration of the area of review with 26 gas and oil wells is already present, since it is located over a known anomaly, since the wells are not presently in compliance even with ODNR and should have been plugged, this permit should be denied.
The Coshocton Board of Health opposes Buckeye Brine converting two of the existing class 2 injection wells to class 1 injection waste wells. The board voted unanimously to oppose this. As the Coshocton County Board of Health, we are required to act in the best interests of Coshocton County residents. I am only one member of this board. I have included our letter.
The best place for a class 1 well is far away from a municipal water source, no current wells close to the class 1 injection well, not located near a ground fault or anomaly, and residents who understand the risk associated with concentrating a large number of trucks transporting this waste.
Thank you for your consideration.
Jeff A. Poland
Coshocton County Board of Health