backOn December 31, 2011, an earthquake, measuring 4.0 on the Richter scale, shook Youngstown, Ohio. This tremor was relatively minorno one was injured, and Youngstown buildings did not suffer significant damage. Because Youngstown is near a permitted underground injection well used for disposing of wastewater from hydraulic fracturing operationsthe Northstar 1 wellcritics of shale gas development have cited the tremor as further support for their opposition to development of shale gas reserves.
Importantly, the Northstar well is not a production well, and no hydraulic fracturing activities took place there. At the request of the Ohio Department of Natural Resources (Ohio DNR), D&L Energy, the Northstar 1s operator, agreed to shut down the well due to prior tremors on December 30, 2011 until the cause of the earthquakes was determined.[1] The 4.0 magnitude quake struck one day after the voluntary shut down. The Northstar well is the only Class II well in Ohio to be shut down under suspicion that its activities may have induced seismic activity.
On March 9, 2012, Ohio DNR released its preliminary findings that strongly indicate the Northstar well induced the tremors.[2] Ohio DNRs findings were accompanied by a set of proposed state regulations to address concerns about induced seismicity from disposal wells. Although the potential for seismic events associated with certain oil and gas production activities is understood, investigation of the Northstar well may fuel demand for further regulation of not only disposal wells, but also shale gas operations.
Like shale gas operators nationwide, operators in the Marcellus Shale rely on Class II wells for wastewater disposal. Due to particular circumstances associated with one injection well, Ohio DNR announced new standards for locating disposal wells and monitoring seismic activity, which will increase the costs of operating these wells. The increased disposal costs will in turn impact expenses for the operators who depend on these wells. This is immediately concerning for operators in Ohio and Pennsylvania who send wastewater to Ohio's underground injection wells. However, Class II wells in other known faulted areas may encounter similar modifications and associated increases in costs.
Recent Seismic Activity Related to Oil and Gas Activities Opponents of hydraulic fracturing have blamed recent earthquakes in Arkansas, Colorado, and Oklahoma on hydraulic fracturing and underground injection of wastewater in disposal wells.[3] In investigating and addressing these seismic events, it will be important to distinguish between these potential causes. Activities related to oil and gas production may have had nothing to do with these earthquakes. For example, in November 2011, there was a 5.6 magnitude earthquake near Oklahoma City. Although some critics attributed the quake to hydraulic fracturing operations, it occurred along a previously active seismic fault. The United States and Oklahoma Geological Surveys concluded that it was doubtful that hydraulic fracturing caused the earthquake.[4] On the other hand, Cuadrilla Resources, a British gas developer, reported that it is highly probable that its hydraulic fracturing operations caused minor earthquakes in Lancashire, England.
Injection of water is just one of a host of human activities that can induce seismic activity. Other human activities that can induce seismic events include blasting, large-scale mining, and reservoir and dam construction.[5] In particular, the construction of large dams and reservoirs has frequently induced earthquakes with magnitudes above 5, significantly stronger than the Youngstown New Years Eve tremor.[6]
Preliminary Investigation of the Youngstown Earthquakes In addition to the New Years Eve earthquake, Youngstown experienced ten minor tremors between March and December 2011. Because earthquakes are rare in the Youngstown area, Ohio DNR brought in seismologist John Armbruster from Columbia Universitys Lamont-Doherty Earth Observatory to investigate the series of tremors.[7] The Northstar well was drilled to a depth of 9,184 feet (2,799 meters), 200 feet into the Precambrian basement rock layer.[8] Dr. Armbruster concluded that the earthquakes originated in the area of the Northstar well and were the result of slippage along a fault three kilometers below the surface, approximately the same depth as the wells injection site.[9] From this, Dr. Armbruster determined that the earthquakes were related to injections at the Northstar well, noting that all of the earthquakes occurred after D&L began operating the well, and Youngstown is not historically seismically active. However, Dr. Armbruster conceded that the other 177 Class II wells in Ohio have not experienced seismic events, and Youngstowns seismic activity has been a matter of luck.[10]
Ohio DNRs Conclusions and New Disposal Well Regulations
Ohio DNR released a preliminary report of its findings on March 9, 2012.[11] Based on [a] number of coincidental circumstances, Ohio DNR concluded that there is a compelling argument that the Northstar well induced the seismic activity near Youngstown.[12] These factors appear to be the ones that led Dr. Armbruster to determine that the Northstar 1 well was the probable cause of the earthquakesi.e., the proximity in time and location to the wells operations.[13] The report also found the Northstar well was not positioned properly due to Ohio DNRs inability to access adequate geological data.[14]
However, Ohio DNR emphasized that it is very difficult for all conditions to be met to induce seismic events. In fact all the evidence indicates that properly located Class II injection wells will not cause earthquakes.[15] To this end, Ohio DNR included a list of new standards for disposal wells in its preliminary report. These included:
A review of existing geologic data for known faulted areas within Ohio and a prohibition on locating new Class II wells in those areas;*Operators must submit comprehensive geological data, including gamma ray, compensated density-neutron, and resistivity logs, to Ohio DNR for newly drilled Class II wells;
*A prohibition on any new wells to be drilled into the Precambrian basement rock formation;
*The requirement, as part of an operators permit application, to submit any information available concerning the existence of geological faults within a specified distance of the proposed wells location, along with a plan for monitoring seismic activity;
*Operators must measure original down hole reservoir pressure before initial injection;
*Operators must conduct a step-rate injection test to establish formation parting pressure and injections rates;
*Operators must install state-of-the-art pressure and volume monitoring devices, including automatic shut-off switches and data recorders; and
*Transporters must install electronic transponders to ensure cradle to grave monitoring of wastewater shipments.[16] Ohio DNR will implement these regulations as conditions to new Class II well permits until the legislature codifies them or the agency includes them in an administrative rule.[17] To ensure thoroughness of the process, Ohio DNR plans to hire an outside expert to review the technical information regarding the Northstar well.[18] Additionally, Ohio DNR plans to purchase four portable seismometers to provide state geologists with more seismic data.[19]
Conclusions
Class II wells will likely continue as the preferred method for disposal of non-recyclable wastewater from hydraulic fracturing activities. Earthquakes such as those near Youngstown are rare,[20] and most induced seismic activity from deep well injection is imperceptible. In fact, Ohio DNRs report demonstrates the agencys firm belief that the risks of induced seismicity from deep injection wells can be mitigated by appropriate regulation.
Although operators will have to comply with Ohio DNRs new disposal regulations, we do not expect these standards significantly to affect access to well capacity for natural gas production in the Marcellus Shale. However, it is probable that increased disposal costs will attend the new oversight and regulation promulgated in response to these rare events. Further, induced earthquakes represent another environmental impact opponents of shale gas will likely cite in their efforts to halt production. It will be important to monitor how EPA, DOE, and other states react to Ohio DNRs new regulations and conclusions.
[1] Ohio DNR, Preliminary Report on the Northstar 1 Class II Injection Well and the Seismic Events in the Youngstown, Ohio, Area 13 (March 2012) [hereinafter Ohio DNR Preliminary Report], available at http://ohiodnr.com/downloads/northstar/UICreport.pdf; see also Press Release, Ohio Dept of Natural Resources (Jan. 3, 2012), available athttp://www.ohiodnr.com/home_page/NewsReleases/tabid/18276/EntryId/2644/State-Natural-Resources-Director-Reaches-Agreement-to-Halt-Operation-of-Youngstown-Area-Injection-Well.aspx. [2] Press Release, Ohio Dept of Natural Resources (Mar. 9, 2012), available athttp://www.ohiodnr.com/home_page/NewsReleases/tabid/18276/EntryId/2711/Ohios-New-Rules-for-Brine-Disposal-Among-Nations-Toughest.aspx. [3] See Mike Soraghan, Earthquakes erode support for drilling, but theyre nothing new, E&E Greenwire (Jan. 5, 2012), http://www.eenews.net/Greenwire/2012/01/05/1. [4] SeeSeth Borenstein & Jonathan Fahey, Oklahoma Earthquakes Stronger Than Fracking Tremors, Experts Say, The Huffington Post (Nov. 7, 2011), http://www.huffingtonpost.com/2011/11/07/oklahoma-earthquakes-not-manmade_n_1080749.html#; A.P., Ohio quakes could incite fracking policy shift, Tribune-Chronicle (Jan. 4, 2012), available at http://www.tribune-chronicle.com/page/content.detail/id/155236/Ohio-quakes-could-incite-fracking-policy-shift-.html?isap=1&nav=5031. [5] Michael L. McKinney, Robert M. Schoch, & Logan Yonavjak, Environmental Science: Systems and Solutions 136 (2007). [6] Id. (in at least six major dams around the world . . . the impounding of water in the dams reservoirs has apparently induced earthquakes of a magnitude greater than 5 on the Richter scale . . . . Over 1,000 earthquakes of various magnitudes have been felt since Hoover Dam was constructed in 1935 . . . .). [7] Mark Fischetti, Ohio Earthquake Likely Caused by Fracking Wastewater, Scientific American (Jan. 4, 2012), http://www.scientificamerican.com/article.cfm?id=ohio-earthquake-likely-caused-by-fracking. [8] Ohio DNR Preliminary Report at 3. [9] Id. [10] Interview of John Armbruster by Melissa Block, Fracking Byproducts May Be Linked To Ohio Quakes, National Public Radio, Jan. 3, 2012, available athttp://www.npr.org/2012/01/03/144633252/fracking-byproducts-may-be-linked-to-ohio-quakes [11] Press Release, Ohio Dept of Natural Resources (Mar. 9, 2012), available athttp://www.ohiodnr.com/home_page/NewsReleases/tabid/18276/EntryId/2711/Ohios-New-Rules-for-Brine-Disposal-Among-Nations-Toughest.aspx. [12] Ohio DNR Preliminary Report at 17. [13] See id. [14] See id.; Mike Soraghan, Wastewater injection well sparked earthquake -- Ohio officials, E&E Greenwire (Mar. 9, 2012), http://www.eenews.net/Greenwire/2012/03/09/1. [15] Id.at 4. [16] Id. at 18. [17] Press Release, Ohio Dept of Natural Resources (Mar. 9, 2012), available athttp://www.ohiodnr.com/home_page/NewsReleases/tabid/18276/EntryId/2711/Ohios-New-Rules-for-Brine-Disposal-Among-Nations-Toughest.aspx. [18] Ohio DNR Preliminary Report at 18. [19] Id. at 5. [20] Ohio quakes could incite fracking policy shift, supranote 4.