There are two kinds of wells used for fossil fuels: extraction wells to draw either petroleum or natural gas from geological formations, and injection wells to force liquids under high pressure deep down underground. Injection wells can be of three types. The first is to force saltwater mixed with CO2 into oil bearing shale to thin the oil so it will flow freely up an extraction well. The second is to force the saltwater that returns with oil to the surface back down into deep rock layers to dispose of it. And the third is to force fracking wastewater that returns with oil to the surface back down into deep rock layers to dispose of it.
Here are three concerns about injection wells associated with petroleum and gas drilling. The most common one is the high potential for triggering earthquakes in unstable geologic formations. The Kansas Geological Survey links earthquakes to wastewater disposal, and has increased restrictions as a result of the 2016 earthquakes in southern Kansas. A second concern is the potential for the deep-injected wastewater to migrate into freshwater aquifers. And the third concern is the potential for the brine wastewater to cause land subsidence and sink holes near the oil fields – Brine Disposal, Land Subsidence, Salt Dissolution: Oil and Gas Operations.
As far as we know, there is no fracking in Douglas County, all seemingly concentrated in the southern-most Kansas counties bordering Oklahoma. But there is petroleum in Douglas County in relatively small fields, and dozens, if not hundreds, of wells are scattered around the eastern part of the county. Most of these wells produce little, so operators are resorting to what is called “enhanced recovery” technology, or “tertiary recovery”. This amounts to applying pressure to the pockets of petroleum by injecting high pressure saltwater into the rock that dilutes the petroleum and forces it to the surface. A rash of these saltwater injection wells have come to the attention of the public recently, because operators must get permits from the Kansas Corporation Commission (KCC).
In mid-October 2017, a contractor named Midstates Energy Operators filed applications with the KCC for saltwater injection wells on two properties southeast of Lawrence. There had been earlier applications, and permits granted in the general vicinity, as well as dozens south and east of there near Baldwin City, but only a few people knew of them. The KCC permit process is very opaque for the public in many ways, one such being that a “public” notice for an application need be published for only one day, and appears in the classified ad supplement, not the main newspaper. It so happened that a Sierra Club member noticed the two recent applications, and alerted others.
The Midstates Energy Operators injection well applications are for two adjacent properties southeast of Lawrence and southwest of Eudora, three miles south of the K-10/Dg. Co. 1057 Rd. interchange.
- One is the Thrasher Lease on the Mr. Pat Thrasher property, N.E. of the intersection of Dg. Co. 1057 Rd. and 458 Rd. The permit application is to “amend the injection well permit #E-31,965, Thrasher #10, Thrasher I-5, on Sec. 25, Twp. 13S, R 20E, Douglas County, Kansas”. Protest letters must reference that exact description. The KCC has issued to this case a main reference Docket Number of 18-CONS-3195-CUIC, and it can be viewed at Thrasher Docket Details.
- The other is the Hadl Lease on the Mr. Vernon Hadl property, S.E. of the intersection of Dg. Co. 1057 Rd. and 458 Rd. The permit application is for “enhanced recovery of injection wells under permit #E-32,566, Hadl I-1 and Hadl I-2, on Sec. 36, Twp. 13S, R 20E, Douglas County, Kansas” Protest letters must reference that exact description. The KCC has issued to this case a main reference Docket Number of 18-CONS-3196-CUIC, and it can be viewed at Hadl Docket Details.
The public is encouraged to send protest letters (if so inclined) before the deadline of 27 November. The KCC ordered the applicant to republish the public notices with a correct protest window of 30 days. The technical deadline is Saturday, 25 November, but since the KCC is closed on weekends, the effective deadline is extended to Monday, 27 November. To be valid, protest letters must ARRIVE AT THE KCC OFFICES on or before the deadline (not the postmark date). The U.S. Postal Service won’t deliver on Thanksgiving, and the KCC will be closed from Thursday through Sunday. That means that letters must arrive at the KCC either by Wednesday, 22 November, or Monday, 27 November. Play it safe and aim for the 22nd.
However – there now is an electronic way to file a protest letter. No postage, no delay, no uncertainty, and it works any day, holiday or not, including Saturday 25 November. Go to the KCC website E-filing link at – https://puc.kcc.ks.gov/e-filing/e-express/, where you can upload a PDF version of your protest letter (not a Word.doc version). Reference each application with the Docket Number, and put the Docket Number in your letter also. To get site access, you first must create a user name and a password, just like you might for Craig’s List or your kid’s school grades. E-filing is faster, no envelopes and stamps, and you get a notification back that your letter was received.
If using the U.S. Postal Service (or other delivery services), mail it to: Kansas Corporation Commission, Attn: Rene Stucky, Conservation Division (Oil & Gas), 266 N. Main St. Ste. 220, Wichita, KS 67202-1513. It’s best to mail letters Certified/Return Receipt, to get proof that a letter was delivered.
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