Meeting Summary

Topic: Conference Call with North Star Disposal, Inc Regarding Underground 

Injection Operations in Ohio

Meeting Date: 2 July 2012

Participants: Lisa Biddle, Erik Helm (EPA/EAD)

Betsy Bicknell, Meghan Camp, Brent Ruminski, Lori Weiss (ERG)

Bill Hays, Dave Jenkins, Terry Smerks (North Star)

On 2 July 2012, the U.S. Environmental Protection Agency (EPA) held a conference call 

with North Star Disposal, Inc. (North Star) to discuss their underground injection well operations 

near Youngstown, Ohio. Discussion topics included:

 Company Background;

 Underground Injection Industry Background;

 Well Development Process and Permitting; and

 Technical and Cost Information.

Attachment 1 lists the meeting participants.

Company Background

North Star is a drilling and operating company that owns seven underground injection

wells in eastern Ohio with approximately 50 employees. Currently, only two of these wells are in 

operation while the other five have been drilled and are awaiting permit approval to begin 

operation. North Star is permitted to inject any oil and gas wastewater for disposal but almost 

exclusively accepts Marcellus and Utica shale gas wastewater. 

Figure 1 shows the North Star underground injection wells and all Marcellus and Utica

shale gas wells located in Ohio, West Virginia, New York, and Pennsylvania using ArcGIS 

mapping and coordinates from DrillingInfo, Inc’s HPDI database and Pennsylvania Department 

of Environmental Protection’s (PA DEP) oil and gas database.

1

Figure 1 also shows a 90 mile 

radius around North Star and indicates the Pennsylvania Marcellus wells from which wastewater 

was hauled to North Star (yellow) according to PA DEP. Attachment 2 provides wastewater 

volumes by Pennsylvania Marcellus operators that hauled wastewater to North Star in 2011.

 

1 HPDI database last updated in December 2011. PA DEP database last updated January 2012.
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Sources: Generated using ArcGIS and coordiantes from HPDI and PA DEP’s oil and gas databases.

Figure 1. North Star Underground Injection Wells (green), Marcellus and Utica 

Shale Gas Wells (red), and Pennsylvania Marcellus Shale Gas Wells that Hauled

Wastewater to North Star in 2011 (yellow).

Injection Industry Background

Underground injection wells are classified into five classes. Class II injection wells inject 

fluid associated with oil and gas production. This includes brine disposal, hydrocarbon storage, 

and enhanced recovery. According to North Star, there are currently189 active underground 

injection wells in Ohio. According to the Ohio Department of Natural Resources (OH DNR), 98 

percent of oil and gas wastewater generated in Ohio is disposed of via class II injection wells.2

North Star commented that demand for underground injection has decreased in the past year due 

to low gas prices, which prompted shale gas operators to increase reuse of wastewater in 

hydraulic fracturing. North Star also noted that a few larger oil and gas operators operate their 

own class II underground injection wells.

 

2 Available online at: http://www.ohiodnr.com/mineral/injection/tabid/10374/Default.aspx
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Well Development Process and Permitting

The Ohio Department of Natural Resources (OH DNR) regulates class II underground 

injection wells in Ohio. North Star mentioned that a pending Senate Bill will bring new 

requirements to the underground injection well industry, but did not provide any details about the 

new requirements. North Star provided general information on the underground injection well 

development permitting process. According to North Star, the timeframe for obtaining a lease, 

drilling the well, and getting final permit approval to operate is approximately six to eight 

months. In general, the requirements to drill an underground injection well are similar to oil and 

gas extraction well requirements except that underground injection wells do not have spacing 

requirements like oil and gas wells. In general, the well development process includes the 

following steps.

1. Obtain a lease — When obtaining a lease, operators tend to look near interstate 

highways to accommodate trucking traffic to and from the injection well site.

2. Obtain a drilling permit — After the operator obtains a lease, OH DNR requires 

operators to obtain a drilling permit. North Star estimated it takes two to three weeks 

to obtain a permit.

3. Drill the well — North Star drills vertical wells with openhole completion for 

underground injection.

4. Conduct pressure testing — After the well is drilled, the operator must conduct 

pressure injection tests to determine the capacity of the well. 

5. Final OH DNR Approval — After the pressure test is complete, North Star submits 

the results to the OH DNR who studies the results to determine the final operating 

specifications that will go in the permit, including the maximum injection rate with

respect to the injection pressure.

Technical and Cost Information

North Star provided technical and cost information on underground injection. Table 1

provides a summary of cost information.

Wastewater Trucking and Storage 

North Star does not provide trucking for operators. Most operators hire a third party 

trucking company to transport the wastewater from the extraction well site to the underground 

injection well. Trucking companies charge SGE operators between $95 and $105 per hour. A 

typical truck is capable of hauling 130 barrels of fresh water and only 100 barrels of wastewater 

due to weight limitations. 
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Drilling

Underground injection operators can drill new wells or convert existing oil and gas 

extraction wells into underground injection wells. Operators may convert existing extraction 

wells to underground injection wells when they reach the end of their productive life or if the 

well did not produce economically after completion. According to OH DNR’s 2011 annual oil 

and gas summary, Ohio operators drilled seven new underground injection wells and converted 

twelve existing production wells into underground injection wells.3The approximate cost to 

convert an existing well is $300,000 to $400,000. To drill a new underground injection well costs 

$700,000 to $1,000,000 for shallow wells and up to $3,500,000 for deep wells.

Well Completion and Formation

North Star drills and completes their underground injection wells in the Rose Run and 

Clinton-Medina sandstone formations. In eastern Ohio, these formations have high porosity and 

permeability, which are good qualities for underground injection. North Star completes their 

wells in these formations using openhole completion techniques. This means there is no well

casing across the target formation interval. Figure 2 provides a diagram of an openhole 

completion.

Figure 2. Open Hole Completion

Injection rates

The injection rate (i.e., barrels per day) is inversely proportional to the injection pressure. 

The required injection pressure varies with the wastewater density, formation porosity, formation 

permeability, and the ultimate capacity of the formation. As these properties decrease, the 

pressure required for injecting wastewater increases and the injection rate decreases. North Star

estimated their two relatively shallow wells in operation are capable of injecting 500 to 600 

barrels per day on average. However, the deeper wells North Star drilled that are not yet in 

operation may be able to accept 2,000 to 4,000 barrels per day.

 

3 The total depth of all underground injection wells in 2011 was 60,699 feet or an average depth of 3,200 feet. 

Available online at: http://www.ohiodnr.com/portals/11/publications/pdf/oilgas11.pdf

Target 

formation

Casing
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Wastewater Quality Acceptance Criteria

North Star requires that all wastewater meets two quality acceptance criteria in order to 

accept a load. The wastewater must have a total suspended solids (TSS) concentration of less 

than one percent. This is because TSS clogs the formation and decreases porosity and 

permeability. North Star samples every incoming load for TSS using a test tube and flocculent

addition. The wastewater must have a density of 9.5 pounds per gallon or higher in order to be 

injected. This is because it requires less pressure to inject higher density brines. North Star does 

not restrict bacteria levels because the wastewater is not stored onsite for long periods of time.

Well Life

The typical lifespan for an underground injection well is approximately 30 years but is 

hard to predict and varies well to well. An operator can drill a new underground injection well 

directly next to an existing well that has reached the end of its life. However, it is likely that the 

formation in this location is saturated and unable to hold additional wastewater under normal 

operating pressures. 

Cost Summary

Table 1 provides a summary of costs provided by North Star and from OH DNR’s 

website. The cost for disposal varies with demand and wastewater density. Because less dense

wastewater requires higher injection pressures or blending, North Star may surcharge operators

for less dense wastewater.

Table 1. Summary of Costs Provided by North Star and from OH DNR

Cost Description Cost a Notes

Convert a producing well to an 

underground injection well

$300,000 - $400,000

Drill a new shallow 

underground injection well

$700,000 - $1,000,000 Shallow wells are approximately 

4,000 feet deep and can accept 500 

to 600 barrels per day.

Drill a new deep underground 

injection well

$3,500,000 Deep wells are approximately 

10,000 feet deep and can accept 

2,000 to 4,000 barrels per day.

OH DNR Costs In-state fee: $0.05 per barrel

Out-of-state fee of $0.20 per barrel

Permit application fee of $1,000

Costs under Senate Bill 165. 

b

Disposal Cost to SGE Well 

Operators

$4.00 per barrel Does not include trucking. Cost is 

subject to surcharge if wastewater 

has low density.

Trucking Cost to SGE Well 

Operators

$95 to $105 per hour 100 barrel capacity for dense 

wastewater and 130 barrel capacity 

for freshwater.

a—North Star and trucking costs are approximate and vary with demand and natural gas prices.

b—OH DNR costs reported online at: 

http://www.ohiodnr.com/mineral/injection/tabid/10374/Default.aspx
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Attachment 1

Table A-1. List of Meeting Participants

Name Affiliation Phone Email

Bill Hays North Star 330-623-0678 bhays@mohawkservices.us

Dave Jenkins North Star Not Provided Not Provided

Terry Smerks North Star Not Provided Not Provided

Lisa Biddle US EPA 202-566-0350 Biddle.Lisa@epamail.epa.gov

Erik Helm US EPA 202-566-1049 Helm.Erik@epa.gov

Betsy Bicknell ERG 703-633-1612 betsy.bicknell@erg.com

Meghan Camp ERG 703-633-1684 meghan.camp@erg.com

Brent Ruminski ERG 703-633-1701 brent.ruminski@erg.com
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Attachment 2

Table 2. North Star 2011 Pennsylvania Shale Gas 

Wastewater Volumes by Operator

Operator Volume (barrels) a

EOG Resources 182,287

REX Energy Operating Corporation 110,396

Pennsylvania Generation Company, LLC 66,798

EQT Production Company 41,216

Seneca Resources Corporation 17,957

Atlas Resources, LLC 9,416

Consol Gas Company 6,360

CNX Gas CO, LLC 6,176

Chevron Appalachia, LLC 4,962

Stone Energy Corporation 3,488

Snyder Bros, Inc 2,070

Vista Operating, Inc 515

Total 451,642

Daily Average 1,237

a—Report volume is for both of North Star’s wells.

Source: PA DEP’s Oil and Gas Reporting database.