1. KCC Rules on Injection Wells
By Kate Catlin
Published in Harper County Herald, Vol. 6, Issue 19, 03/23/2015
In an order issued last Thursday by the Kansas Corporation Commission (KCC), oil and gas drilling
operators must reduce the amount of water they inject into underground saltwater injection wells. According
to geologists around the county, this is a practice that may be causing earthquakes in areas that have
experienced sudden increased earthquake activity in recent years, especially in Harper and Sumner counties.
In the order, the commission stated that, “The Commission finds damage may result if immediate action is
not taken.”
The order limits injection into the Arbuckle geologic formation in all of Harper and Sumner counties to
25,000 barrels of waste water per day. In five areas of greater concern, stemming from Kansas Geological
Survey data, more drastic measures were ordered. Producers will have to scale back waste injection gradually
over the next 100 days. Within 10 days of the order on Thursday, injection in the five areas must immediately
reduce injection to 16,000 barrels of saltwater per day. Within 55 days, they must drop to 12,000 barrels per
day, then to 8,000 barrels per day within 100 days, for a total reduction of up to 60 percent on certain
injection wells over this timeframe.
The commission also reported that it will no longer issue permits for new large-volume injections wells
within a quarter-mile of another large-volume well within the boundaries of the two counties. These large-
volume wells are typically permitted for more than 5,000 barrels a day. In 2013, there were 44 wells of this
type permitted by the KCC. Most of those were permitted for between 30,000 and 60,000 barrels per day.
The order limits daily injection pressures in the wells in the five high-risk areas to 250 pounds, but
pressure-spikes due to short-term errors resulting in a pressure of up to 500 pounds will be allowed.
Operators are ordered to regularly report data showing their compliance with the order, and all
operators of large-volume wells inside the five seismic areas must report the “true vertical depth of each
well.” If a well has penetrated beyond the Arbuckle formation, it will have to be plugged.
The order specifically cites the correlation between the number of earthquakes in Harper and Sumner
Counties and the amount of saltwater injection in the area. “Because individual earthquakes cannot be linked
to individual injection wells, this Order reduces injection volumes in areas experiencing increased seismic
activity,” it reads.
In January, Rex Buchanan, the interim head of the Kansas Geological Survey, reported to lawmakers that
there is a “reasonable probability” that a relationship exists between the quakes and injection.
According to the Kansas Geological Survey, 34 earthquakes with a 2.5 or higher magnitude occurred in
Kansas between 1977 and 2012. Since 2013, the KGS reports that Kansas has had at least 115 quakes of that
size or higher. Between 1977 and 2012, Harper and Sumner counties experienced only two quakes greater
than 2.0 magnitude, but since 2013, the counties have had more than 130.
In Harper County, the number of injection wells increased from 41 wells in 2010 to 71wells in 2012.
Eighteen new permits were given by the KCC in 2014. The amount of waste injected into Harper County wells
went from 9.67 million barrels in 2010 to over 51.82 million barrels in 2013. Generally, producers report
injection amounts once a year, in March, for the previous year. The KCC has not yet released data from 2014.
Frank Smith, a Bluff City resident, went before the KCC to protest applications for new saltwater
injection wells in Harper County. The hearing resulted in the new order. Smith has been an active campaigner

2. for more regulation of the oil industry in Harper County, and has communicated with the Harper County
Commissioners several times about the earthquakes, many of which have epicenters near his home.
Joe Spease, Chairman of the Fracking Committee for Kansas Sierra Club said, “This is a step in the right
direction, but it remains to be seen if reducing the amount of fluids disposed into the injection wells will
reduce the number of quakes. In a report recently distributed by the USGS, some scientists believe that once
the seismic activity has been started it will not stop as long as any fluid is disposed into the wells.”
According to a study by Healy, Rubey, Griggs and Raleigh which was published in the journal SCIENCE in
1968, there was a lag between heavy injection and earthquake activity, which would account for earthquake
activity to continue for months or even years after slowing down or stopping injection altogether. The group
studied in-depth seismic records and injection well reports by produced induced in Colorado after large
saltwater injection wells in the Denver area was found to have caused earthquake swarms, which extensively
damaged property in the area.
Spease continued, saying, “Since the protection of Kansans and their property in south central Kansas
should be the main concern of our government it would be best to see if there is any reduction in quakes as a
result of the KCC order. If no significant reduction is measured in three months it will be best to completely
cease the use of injection wells in Harper and Sumner counties.”