--> Challenges Facing Class II Disposal Well Operations in the Appalachian Basin

2019 AAPG Eastern Section Meeting:
Energy from the Heartland

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Challenges Facing Class II Disposal Well Operations in the Appalachian Basin


With the continued development of the unconventional oil and natural gas resources from the Marcellus and Utica shales in the Appalachian Basin, the demand for Class II disposal of oilfield fluid wastes has seen a significant increase. Production of brine water from the Utica and Marcellus in Ohio and West Virginia in 2018 averaged 159,572 barrels of water per day. With a small number of Class II disposal wells in West Virginia and lack of primacy in Pennsylvania, only Ohio remains well situated to handle the increase in Class II saltwater disposal well activity in the Appalachian Basin area. Currently, there are 45 active Class II disposal wells in West Virginia, 15 permitted disposal wells in Pennsylvania, and 240 permitted and 219 active disposal wells in Ohio. In West Virginia, Class II disposal well permits are issued by WV DEP, are valid for five years, and then need to be renewed every five years after initial issuance of the permit. In Pennsylvania, since the state does not have primacy, Class II disposal wells require two permits, a UIC permit from U.S. EPA Region III and a well permit from PA DEP. In Ohio, which has had primacy of its Class II program since 1983, a permit to drill a new disposal well or a permit to convert a well to disposal is issued. Once the well has been drilled or converted, a second permit is issued for authorization to inject. After a well has been authorized to inject in Ohio, the permit remains valid for the life of the well. The challenges facing Class II disposal well applicants and operators in the Appalachian Basin can be overwhelming. These challenges include: Finding locations and properly siting disposal wells; conducting title searches and mineral rights issues; understanding the various regulatory challenges, dealing with areas of dense population; addressing public and local political activists opposed to injection well development; finding adequate geologic formations for high capacity disposal operations; developing proper well construction, cementing, and completion methodology; selecting the right option for surface facility development and pre-treatment programs; dealing with NORM/TENORM testing and solid waste disposal issues; and working with the regulatory agency on potential seismic monitoring and mitigation issues or requirements. Proper consideration of all of these challenges can lead to the successful permitting, drilling, construction, completion, and operation of a commercial Class II saltwater disposal facility in Appalachian Basin. This presentation will explore the challenges faced by a Class II disposal well applicant or operator and provide solutions to addressing the issues.