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Historically, in the Marcellus Basin, produced fluids were taken to water treatment plants for disposal. This is not a condoned activity today because the high level of salts in these produced fluids can destroy bacteria that clean waste streams before discharge to surface waters.


You’re kind of left with subsurface Class IID wells, which have been working well for over 40 years. But with so few wells in Pennsylvania, Marcellus operators typically are trucking their produced fluids to Youngstown and other regions in Ohio. I personally don’t consider that a great option. Truck traffic is one of the most dis- liked components of gas develop- ment in Pennsylvania.


Anytime


you have a solution that requires a barge, a railcar or a truck, you in- troduce opportunities for accidents, and you involve additional regulato- ry agencies. The closer to home you can get rid of your produced fluids, the better it is for the industry and the public.


MQ: When companies need UIC wells, do they drill those wells themselves, or do they outsource all or parts of the process?


Rodiek: Operators usually choose one of three options. They can iden- tify a brand new well and go through a “greenfield” process to get it per- mitted. They can select an existing well and convert it to a disposal well using the same permitting process. Or they can engage third parties that operate disposal wells as a business.


Using a well they already have usually is their first choice. The casing already has been set and they know what injec- tion zones already were passed through, what injection rates are proper, whether the porosity and permeability of the receiv- ing formations are appropriate for acceptance of the fluid and what needs to be done to protect aquifers. Most Marcellus op- erators have very well qualified hydrogeologists and reservoir engineers. If they follow industry standards, you won’t see communication of the injected fluid anywhere outside the injection zone.


MQ: In Ohio, a deep injection well has been linked to seis- mic activity. What’s your reaction to that?


Rodiek: It is not surprising to folks associated with geology because the mechanism of seismicity is the lubrication of a fault or faults. In the case of the Youngstown events, some injection well operators explored Precambrian rock formations to increase injectivity rates. These deeper (greater than 8,000


feet below surface) formations did accept more fluid than shal- lower (about 5,000 feet below surface) sandstones formations, but it appears the reason for this increased injectivity was the presence of a fault or faults which, when lubricated, apparently caused small rock movements that resulted in seismic energy being felt at the surface. The Ohio Department of Natural Re- sources solved that problem by requiring drillers to cement up- hole 300 feet from Precambrian rock before settling on an in- jection zone. It’s good regulatory policy. It establishes that you won’t inject into a known faulted zone.


Ohio also requires that if you have a well within three miles of a known fault or a measured seismic event, you must install geophones to measure any imminent seismic activity. Par- sons Brinckerhoff uses an alternative to geophones called digital acousti- cal sensing (DAS) to monitor seismic events before they occur. A fiber optic cable installed in the well allows the measurement of sound within inches of the source. If you do it right, you can listen for any seismic activity before it can be felt at the surface and adjust in- jection volumes and pressures so you don’t have a seismic event. Step-rate tests will determine at what point the rock would fracture. Generally, state regulations require keeping injection pressure below 75 percent of known fracture pressure.


MQ: You mention Ohio’s regulatory agency, but isn’t the EPA involved in regulation as well?


Rodiek: States can have primacy over the regulatory process or, as in Penn- sylvania, they can allow it to be man-


aged by the EPA. Where states have primacy, they sometimes have developed more stringent sets of regulations than the EPA. For example, Ohio requires unannounced inspections every 11-12 weeks; the EPA requires one inspection per year. Generally speaking, state agencies and regional EPA offices are equally competent; they do a lot of communicating and co- operating.


MQ: Are there insurance policies available to help protect the owners/operators of deep injection wells?


Rodiek: Liability management is a big issue for anybody who drills a well. The operator of a well will be held to the highest standard. But even if you outsource the design, drilling and operation of a well, you can’t stop people from claiming you are absolutely responsible for it. Anybody who drills a well has some type of insurance, which comes in the forms of liability insurance, extra expense insurance and environmental site liability insurance.


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Marcellus Quarterly 2014


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