Oil Conservation Division 

Environmental Bureau

Brine Well Collapse Evaluation Report 

June 18, 2009 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 1 

EXECUTIVE SUMMARY 

In 2008, New Mexico experienced two sudden and catastrophic brine well cavern collapses 

within a four-month period that led to the formation of massive sinkholes. The first, at Jim’s 

Water Service, occurred on July 16, 2008. The second, at Loco Hills Water Disposal Company, 

occurred on November 3, 2008. 

On November 14, 2008, Secretary Joanna Prukop of the Energy, Minerals and Natural Resources 

Department (EMNRD) ordered the Oil Conservation Division (OCD) to examine the causes of 

the brine well collapses and to provide a report with recommendations for a safe path forward 

(See Appendix 1 - November 14, 2008 Press Release). Secretary Prukop directed OCD to work 

with the Environmental Protection Agency, other states, technical experts, and oil and gas 

industry representatives. 

OCD formed an Underground Injection Control (UIC) Class III Brine Well Evaluation Work 

Group (Work Group). The Work Group included OCD staff, representatives from the Bureau of 

Land Management, the State Land Office, the New Mexico Bureau of Geology and Mineral 

Resources, the Environmental Protection Agency, the Sandia National Laboratory, the National 

Cave and Karst Research Institute, the Solution Mining Research Institute, and industry 

representatives. OCD staff met with the Work Group in Santa Fe for a two-day session March 

26-27, 2009. Other experts who could not attend the meeting submitted comments via email, 

including participants from Texas, Louisiana, New York, and Kansas (see Appendix 2). The 

Work Group examined the available data on the two collapses and examined data on other brine 

wells in New Mexico to evaluate their collapse potential. During the course of its review OCD 

and the Work Group identified an existing brine well located within the city limits of Carlsbad 

that shares features with the two wells that collapsed and that is itself in serious danger of 

collapse. OCD hired RESPEC, Inc., a company with expertise in brine wells, to provide 

technical assistance in evaluating the status of the Carlsbad brine well and to propose mitigation 

strategies. 

OCD is continuing to review the two collapses that occurred last year and to evaluate existing 

brine wells for subsidence and collapse potential. OCD sent out a Brine Well Information 

Request form to all brine well operators on August 1, 2008, that required operators to provide 

OCD with general information, siting information, well construction information, operations 

history, monitoring information, an estimate of the total volume of brine produced, and the 

volume of the cavern. 

A brine well will collapse when the cavern created by the brine production becomes too large to 

support the roof. In 2008, a study on subsidence, sinkholes, and craters above salt caverns 

quantified this concept, concluding that a salt cavern generally will not collapse if the ratio 

between the cavern diameter and the cavern depth (d/h) is significantly smaller than 2/3. 

Based on the information available at this time, OCD has concluded that the following factors 

may have contributed to the two collapses that occurred in 2008 by creating a brine well cavern 

that could not support its roof: 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 2 

Operation of brine wells in shallow salt zones; 

Placement of the casing shoe near the top of the salt zone; 

Use of the “reverse” circulation configuration; and, 

Overproduction of brine, creating a large cavern. 

OCD recommends taking the following actions: 

OCD should complete its review of all existing brine wells, including plugged and 

abandoned wells, shut-in wells, and operational wells, in light of the 2/3 ratio and 

prioritize the wells in terms of collapse potential. 

Based on its findings, OCD may require appropriate corrective actions. This may 

include changes in operation requirements, closure of active wells, monitoring of 

sites, and/or site remediation measures. 

OCD should re-evaluate existing permit terms, including: use of “reverse” 

circulation; use of a diesel oil blanket or pad to prevent dissolution from occurring 

at the top of the brine well cavern; plug and abandonment requirements; and 

financial assurance requirements. 

OCD should evaluate siting, drilling, construction, operation, monitoring, and 

closure requirements for new brine wells. 

1 INTRODUCTION 

1.1 Geology 

Much of southeast New Mexico is underlain by bedded salt. The principal salt-bearing 

formation is the Salado Formation, which is part of the late Permian Ochoan Series 

(approximately 251 - 260 million years ago). Other formations, including the Rustler and the 

Castile Formations, also contain bedded salt, but the Salado Formation is the thickest and most 

widespread of the salt-bearing formations. The Salado Formation is the geologic formation into 

which nuclear waste is disposed at the Waste Isolation Pilot Project (WIPP). The Salado 

Formation ranges in thickness from zero feet at the western edge of the Delaware Basin to 

approximately 2,400 feet in thickness in the central part of the basin. The Salado Formation is 

laterally continuous throughout much of southeast New Mexico and operators must drill through 

it to reach oil and gas producing zones. Drilling through the Salado Formation using a fresh 

water mud system is problematic because the fresh water mud will dissolve the salt zone and 

cause the operator to lose circulation. Operators drill through the Salado and other salt bearing 

formations using a saturated brine mud that will not dissolve the salt. 

1.2 Brine Well Operations in New Mexico 

A UIC Class III injection well (brine well) is a solution mining operation in which fresh water is 

injected into the salt zone, dissolving the salt, thus creating highly saturated brine. The brine is 

produced from the brine well and sold for use in oil and gas drilling operations. Over time, the 

salt zone dissolves, resulting in an underground cavern. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 3 

New Mexico has permitted 43 brine wells at 32 brine well facilities. Ten brine wells are 

presently active; four were never installed; one was completed but never operated; 26 are 

presently plugged, and two have collapsed. All are located in Eddy and Lea Counties (see Figure 

3). 

Brine well operators employ solution mining techniques to generate the saturated brine that it 

sells to the oil and gas operators. Either a new well is drilled for brine operations, or an old oil 

and gas well which has been abandoned and which the operator deems to be salvageable for 

brine well operations is reentered. Casing is most often set near the top of the salt, usually the 

Salado Formation, the drill hole is advanced to near the bottom of the salt, and tubing is set near 

the bottom of the hole. Several wellbore configurations have been utilized, including: single 

well, single tubing; single well, dual tubing; dual well; and, cased-hole, single tubing systems 

(see Figure 4). In a single well system using either a single tubing or dual tubing configuration, 

fresh water is pumped into the well bore and brine is extracted. In a dual well system, fresh 

water is injected down the tubing in one well and brine is extracted from the tubing in a second 

well. 

Two circulation methods may be used in dual tubing configurations. In the “normal” circulation 

method, fresh water is injected down the tubing and brine is extracted through the annulus, or 

outer tubing. In the “reverse” circulation method, fresh water is injected down the annulus and 

the brine is extracted through the tubing. The reverse circulation method is more protective of 

any fresh water zones above the Salado Formation because in the event of a casing leak, fresh 

water would leak into the fresh water zone rather than brine. 

The configuration and circulation method used affect the shape of the cavern created by the brine 

well operation. A single well system will create a single cavern. A dual well system will 

generally create two, linked caverns. Generally, normal circulation leads to a cylindrical cavern, 

whereas reverse circulation leads to a cavern that is broad at the top and narrow at the bottom of 

the cavern: an inherently weaker structure (see Figure 4). 

1.3 Regulatory Overview 

Brine wells are classified as “Class III injection wells” by the federal Environmental Protection 

Agency (EPA), which has established minimum federal requirements for state and tribal 

underground injection control (UIC) programs under the Safe Drinking Water Act (see 42 U.S.C.

300f et seq.). States and tribes may apply to EPA for primacy to administer the UIC program. 

To obtain primacy, they must demonstrate that their regulations meet or exceed federal 

requirements (see 42 U.S.C. 300g-2). 

In 1983, EPA granted primacy over Class III brine wells in New Mexico (except for those on 

Indian land) to the Water Quality Control Commission (WQCC), the Environmental 

Improvement Division (now the New Mexico Environment Department), and OCD (see 40 CFR 

147.1601). In granting New Mexico primacy, EPA specifically referenced New Mexico’s Water 

Quality Act (Chapter 74, Article 6 NMSA 1978). EPA reviews New Mexico’s UIC programs 

annually. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 4 

New Mexico’s regulations addressing UIC Class III brine wells specified at 20.6.2.5000 et seq. 

NMAC, were promulgated pursuant to the Water Quality Act, which gives broad powers to the 

WQCC to adopt regulations to prevent or abate water pollution, specifically including 

regulations requiring persons to obtain permits for the discharge of any water contaminant. The 

WQCC has delegated regulatory authority over Class III brine wells to OCD. 

EPA’s primary concern under the Safe Drinking Water Act is the protection of underground 

sources of drinking water. The federal requirements for injection wells, including brine wells, 

focus on “pathways of contamination” - specifically, ways in which fluids can escape the well or 

injection horizon and enter underground sources of drinking water. EPA’s UIC program 

provides standards, technical assistance and grants to state governments to regulate injection 

wells in order to prevent them from contaminating drinking water resources. In general, EPA 

requires the operators of Class III wells, including brine wells, to: 

Site the well in a location that is free of faults and other geological hazards; 

Drill to a depth that allows the injection into formations that do not contain water 

that can potentially be used as a source of drinking water and that are isolated 

from any formation that may contain water that may potentially be used as a 

source of drinking water; 

Case and cement brine wells to prevent the migration of fluids into an 

underground drinking water source; 

Never inject fluid between the outer-most casing and the well bore; and 

Test the well casing for integrity at the time of completion and every five years 

thereafter; and, 

Monitor to assure the integrity of the well. 

2 BRINE WELL COLLAPSES 

2.1 Jim’s Water Services (BW-005) 

The Jim’s Water Services brine well (BW-005) collapsed on July 16, 2008 (See Figure 4). An 

employee driving to the well to perform a site check observed a dust cloud in the area of the 

well. When he got out of his truck he noticed a surface crack open and progress toward him. He 

immediately left the site as the cavern began collapsing. The initial sinkhole was approximately 

40 feet wide. By that afternoon, the surface collapse was approximately 180 feet in diameter. 

As of April 2009, the sinkhole was approximately 400 feet across and 120 feet deep. The 

sinkhole continues to grow. 

BW-005 is located on state trust land approximately 17.3 miles southeast of Artesia in Eddy 

County. It is sited about 400 feet north of Hagerman Road (CR 217) and 2.4 miles southwest of 

State Highway 360. BW-005 was originally drilled as an oil and gas exploration and production 

well in 1955 with cable tools to a total depth of 3909 feet. The well was plugged and abandoned 

in 1955. The well was reentered and recompleted as a brine well in 1978. 

The Salado Formation was encountered at approximately 397 feet below ground surface (BGS). 

BW-005 was operated as a single well system with a single tubing configuration using normal 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 5 

circulation until 1986, when it was switched to reverse circulation. No sonar surveys were ever 

run to map the cavern. Based on incomplete production data, OCD estimates that the total brine 

production at BW-005 was approximately 8 million barrels and that the cavern volume was 

approximately 1.3 million barrels. 

BW-005 had passed an EPA 5-Year Mechanical Integrity Test (MIT) of the casing in 2007 and 

had passed an annual formation MIT of the cavern in 2008. The operator had not noticed any 

surficial cracks or fractures before the collapse. The well was active at the time of the collapse. 

After the collapse, OCD contacted New Mexico Tech to determine if their seismic array had 

picked up signs of the collapse. A seismograph (TA126), located approximately 8 miles 

southeast of BW-005, recorded seismic activity approximately six hours before the surface 

collapse occurred. The seismic signals are believed to be associated with subsurface spalling and 

upward stoping of the brine well cavern roof. 

2.2 Loco Hills Water Disposal Service (BW-021) 

The Loco Hills Water Disposal Service (BW-021) brine well collapsed on November 3, 2008 

(see Figure 5). Workers noticed surficial cracking or fracturing near the well at about 11:30 AM 

and immediately prevented access to the area. The collapse occurred at approximately 1:30 PM. 

The operator reported that the initial sinkhole was approximately 50 feet across and 

approximately 30 feet deep. As of May 2009, the sinkhole was approximately 291 feet across 

and as much as 200 feet deep.

BW-021 is located on state trust land 150 feet east of County Road 217 near Loco Hills, 

approximately 25 miles east of Artesia in Eddy County. BW-021was originally drilled as an oil 

and gas exploration and production well and was converted into a brine production well 

approximately 25 years ago. It was operated as a single well system with a single tubing 

configuration using reverse circulation. The casing shoe was set at 415 feet BGS above the salt 

which occurs at 470 feet BGS. (It is not clear whether the salt was part of the Rustler or Salado 

Formation, or both). The production tubing was set at 900 feet BGS. The last sonar log of the 

well was completed on February 7, 2001. Based on incomplete production information, OCD 

estimates that the total brine production at BW-021 was approximately 8 million barrels and that 

the cavern volume was approximately 750,000 barrels. 

BW-021 was plugged and abandoned at the time of the collapse and was being visually 

monitored for subsidence. The well had failed an annual formation MIT on June 18, 2008 and 

OCD had ordered the operator to plug and abandon the well. The well had previously passed a 

5-year MIT of the casing in 2006. 

After the collapse of BW-021, OCD again contacted New Mexico Tech to determine if their 

seismic array had picked up signs of the collapse. The same seismograph (TA126), located 

approximately 14 miles south-southwest of BW-021, did not detect any seismic activity before 

the well collapsed. 
Brine Well Collapse Evaluation Report June 18, 2009 

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3 FACTORS CONTRIBUTING TO COLLAPSE 

3.1 General 

A brine well cavern will collapse when the cavern becomes too large to support the roof. This 

can be expressed in terms of a ratio between the cavern diameter and the thickness of the 

overburden or roof. Cratering does not occur when the relation between cavern diameter and the 

thickness of the roof is significantly smaller than 2/3 (See Karimi-Jafari, M., P. Berest, and B. 

Brouard, 2008, “Subsidence, Sinkholes and Craters above Salt Caverns,” Solution Mining 

Institute (SMRI) Spring 2008 Technical Conference, Porto, Portugal). 

3.2 Cavern Size 

Sonar should be used to map the actual cavern size and location. Where sonar mapping is 

unavailable, or impractical, approximate cavern size may be calculated by determining how 

much of the salt zone had to be dissolved to create the brine produced by the well. A well with a 

long productive life is more likely to have a large cavern than a well with a short productive life. 

3.3 Weak Overburden 

Shallow salt zone: The salt bearing formations in the Delaware Basin of southeastern New 

Mexico occur at very shallow depths (less than 250 feet BGS) at the western edge of the basin 

and dip toward the east in the central part of the basin where the salt occurs at depths of more 

2000 feet BGS. Brine production techniques that dissolve the upper portion of the salt zone, 

such as “reverse” circulation, result in a thinner, weaker overburden. 

Placement of the casing shoe: In the two brine wells that collapsed, the casing shoe was set near 

the top of the salt zone, rather than being advanced into the salt by a certain amount, such as 100 

feet into the salt. 

“Reverse” circulation: The two brine wells that collapsed employed “reverse” circulation using 

a single tubing configuration. Injection of fresh water down the annulus generally creates a 

cavern that is broad on top and narrow at the bottom, an inherently weak configuration. Injection 

of the fresh water into the upper part of the cavern, rather than near the bottom of the cavern, will 

laterally dissolve the salt, aggressively increasing the size of the roof of the brine well cavern. 

Using “reverse” circulation in a well where the casing shoe is placed near the top of the salt 

zone, especially where the salt zone is shallow, tends to create a broad, thin, weak overburden. 

3.4 Additional Concerns 

Lack of Warning: The two cavern collapses in 2008 occurred with little or no advance warning. 

Well Siting: The two cavern collapses were located in remote areas. No injuries or loss of life 

occurred in the collapses. If a well is located in a populated or developed area, a collapse will 

have greater potential for injury, loss of life, and property damage. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 7 

Remediation: OCD is continuing to work with its consultant on what can be done to prevent 

collapses from occurring in wells that are at risk for collapse and what corrective measures will 

be required from operators. 

4. RECOMMENDATIONS 

OCD recommends the following actions, based on its evaluation of brine well operations in New 

Mexico, the two brine well collapses in 2008 and the information gained during the Brine Well 

Work Group sessions. 

4.1 OCD should complete its review of all existing brine wells, including plugged and 

abandoned wells, shut-in wells, and operational wells, in light of the 2/3 ratio and prioritize the 

wells in terms of collapse potential. 

4.2 OCD should evaluate existing information on all brine wells in order to determine cavern 

size, shape, and depth, and then prioritize the wells in terms of collapse potential. OCD should 

require additional information from operators to complete this study, either through existing 

permit terms or by modifying permits to add the following requirements: 

Operators should conduct sonar testing through the full extent of the cavity from 

top to bottom within six months of permit modification to document the size and 

configuration of the cavern. 

Operators should submit comprehensive historical injection and production 

reports with monthly and annual production totals and estimate the volume of the 

cavern within six months of permit modification to compare with the sonar 

surveys. 

Operators should propose criteria that will enable them to determine the 

“Maturity” of their brine operations to determine when they must stop production 

and either modify or terminate their permit. 

Operators should precisely monitor the actual injection volume of fresh water 

versus brine produced on a daily basis and notify OCD if the differential exceeds 

an amount to be determined to complement the annual MITs and to help identify a 

potential leak in the system. 

4.3 Require Corrective Actions on Wells 

OCD will examine each brine well on a case-by-case basis to determine if corrective action is 

required. Corrective action may include changes in operation, closure of active wells, 

monitoring of sites, and/or site remediation measures. 

OCD should require operators to cease operations if they cannot demonstrate that the brine well 

has a certain width to overburden thickness ratio; for example, less than or equal to 0.50 at any 

time during the operation of the well. For example, the cavern associated with a well with its 

casing shoe set at 1000 feet BGS, shall not exceed a diameter of 500 feet. In addition, OCD 

should not allow the maximum cavern roof diameter to exceed 200 feet. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 8 

OCD has already taken action on one brine well, which it determined posed the greatest risk of 

collapse, located within the city limits of Carlsbad. After the first collapse, OCD convinced the 

operator to cease it brine well operations on July 22, 2008. On April 22, 2009, the Carlsbad 

operator ceased its trucking operations at the site after discussions with OCD. OCD and its 

contractor are in the process of installing a subsidence monitoring system and early warning 

system and are investigating methods for mapping the cavern and possible remediation. 

4.4 Re-evaluate Existing Permit Terms 

OCD may consider modifying existing permits. Possible modifications include: 

Requiring “normal” circulation. OCD has already contacted operators using 

“reverse” circulation and requested that they switch to “normal” circulation. 

Specifying technical standards to prevent dissolution from occurring at the top of 

the brine well cavern, such as cavern configuration, casing, tubing, and requiring 

a diesel oil blanket or pad. 

At time of closure, OCD may require operator to keep the cavern full of brine 

fluid and to monitor the pressure head for anomalous pressure changes. OCD 

may require operators to implement a post-closure subsidence monitoring 

program. OCD will examine its previous plugging and abandonment 

requirements in light of the research conducted by the Solution Mining Research 

Institute. 

Increase financial assurance requirements to better address monitoring and 

remediation issues. 

4.5 Consider Siting, Drilling, Construction, Operation, Monitoring and Closure 

 Requirements for New Brine Wells. 

Operational issues that would impact new brine wells include: 

Siting and setbacks; 

Area of review to assess the potential for “thief” zones and the potential for 

accidental de-watering; 

Establishing minimum depth to top of salt; 

Establish minimum depth for setting the casing shoe; 

Specify maximum brine production volume and life-of-well limits; and,

Establish minimum distance between brine well caverns.

5.0 CONCLUSIONS 

The UIC program which regulates brine wells is designed to protect underground sources of 

drinking water. The issue of subsidence and/or collapse of a brine well cavern has not been 

recognized by OCD or EPA as a major problem. Therefore, OCD must change its focus and 

address issues for which it does not yet have answers. For example, with the situation that exists 

in Carlsbad, OCD finds itself confronted with a major challenge that the UIC program does not 

address. First, and most importantly, OCD must attempt to mitigate any catastrophic collapse at 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 9 

the Carlsbad brine well facility to protect human life and property. OCD should also identify 

other brine well facilities that pose a risk for catastrophic subsidence or collapse and address 

these sites individually. 

In the future, OCD must evaluate the dual issues presented by permitting brine wells so as to 

protect ground water quality as required by the UIC program while preventing brine well 

subsidence and/or collapse. To move forward, OCD must strike an appropriate balance between 

protecting water quality and ensuring that brine well operations do not pose a risk to human life 

and property. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 10

APPENDIX 1 

PRESS RELEASES 
Bill Richardson chardson 

Governor Governor 

Joanna Prukop 

Cabinet Secretary 

Reese Fullerton 

Deputy Cabinet Secretary 

Mark Fesmire

Division Director 

Oil Conservation Division

November 14, 2008 NEWS RELEASE

Contact: Jodi McGinnis Porter, 

 Public Information Officer 505.476.3226 

Energy, Minerals and Natural Resources Cabinet Secretary Prukop Orders a Six 

Month Moratorium on New Brine Wells 

Oil Conservation Division to Investigate Brine Well Collapses and Provide Recommendations

SANTA FE, NM – Secretary Joanna Prukop today ordered the Oil Conservation Division to place a six 

month moratorium on any new brine well applications located in geologically sensitive areas. 

Secretary Prukop’s action comes following the second brine well collapse in less than four months in 

southeastern New Mexico. The Secretary has also directed the Oil Conservation Division to work with 

the Environmental Protection Agency, other states, technical experts and oil and gas industry 

representatives to examine the causes of recent collapses, and provide a report with 

recommendations to the Oil Conservation Commission for a safe path forward. The report should be 

completed by May 1, 2009. 

“I am deeply concerned by these two serious incidents and we are taking action to ensure the safety 

of our citizens and to protect the environment,” stated Secretary Prukop. 

Brine wells are an essential part of the oil and gas drilling industry, particularly in the southeastern part 

of the state. Oil and gas operators use brine water in the drilling process. Brine is saturated salt water 

which can be more salty than sea water. Brine is created by injecting fresh water into salt formations, 

allowing the water to absorb the salt and then pumping it out of the well. This method creates an 

underground cavity. 

“The moratorium will provide time to properly evaluate the causes of the recent collapses and to 

discuss the development of new rules or guidelines to ensure the safety and stability of brine well 

systems,” added Secretary Prukop. 

The moratorium will only affect new wells and will not impact existing wells and facilities. 

Below are photographs of the two recent collapses: 
November 14, 2008 

Page 2

Loco Hills brine well collapse, morning, November 7, 2008, sinkhole with fresh water pond in foreground. 

Photo courtesy of Oil Conservation Division 

Loco Hills brine well collapse, morning, November 7, 2008 sinkhole. 

Photo courtesy of Oil Conservation Division 
November 14, 2008 

Page 3

Loco Hills brine well collapse, morning, November 7, 2008 status of fresh water pond. 

Photo courtesy of Oil Conservation Division 

Artesia brine well collapse, morning, July 20, 2008 at 10:44 am. 

Photo courtesy of National Cave and Karst Research Institute 
November 14, 2008 

Page 4

Artesia brine well collapse morning, July 22, 2008 

Photo courtesy of National Cave and Karst Research Institute 

#30# 

The Energy, Minerals and Natural Resources Department provides resource protection 

 and renewable energy resource development services to the public and other state agencies. 

Oil Conservation Division 

1220 South St. Francis Drive ▪ Santa Fe, New Mexico 87505 

Phone (505) 476-3440 ▪ Fax (505) 476-3462 ▪ www.emnrd.state.nm.us/OCD
Brine Well Collapse Evaluation Report June 18, 2009 

Page 11

APPENDIX 2 

OCD MEETING AGENDA 

AND WORK GROUP MEMBERS
(Updated: 3/31/2009)

New Mexico Oil Conservation Division 

UIC Class III Brine Well Evaluation Work Group

Porter Hall (Wendell Chino Bldg.)

1220 South St. Francis Drive, Santa Fe, NM 87505

March 26-27, 2009 

(8:00 a.m. – 5:00 p.m.)

FINAL AGENDA

Thursday, March 26, 2009

8:00 - 8:10 a.m. Welcoming remarks: OCD Director Mark Fesmire or EMNRD 

Secretary Joanna Prukop. 

8:10 - 8:15 a.m. NMOCD introduction: OCD Environmental Bureau Jim Griswold 

states purpose and goal of the work group.

8:15 - 8:30 a.m. Work group members introduction: Members briefly state 

interest in serving on the work group; and what he/she hopes to 

bring to the table. 

8:30 - 8:50 a.m. Shallow geology & hydrology of the Delaware/Permian Basin 

in SE NM (Glenn von Gonten- OCD/ Richard Beauheim- SNL) 

8:50 - 9:05 a.m. A history of brine well operation & regulation in NM (Jim 

Griswold- OCD)

9:05 - 10:00 a.m. Recent brine well collapses in NM & case studies (Jim 

Griswold- OCD) Jims Water Service SE of Artesia on 7/16/2008 & 

Loco Hills Disposal E of Artesia on 11/3/2008

10:00 – 10:15 a.m. Break

10:15 – 10:35 a.m. Federal discussion (Ray Leissner- EPA) 

10:35– 11:15 a.m. Potential impacts to the WIPP Site? (Chuck Byrum- EPA & 

Russ Patterson- DOE) Slide show of subsurface facilities relative 
to the oil field activities in the region; associated regulatory 

requirements; and any other relevant issues.

11:15 – 11:45 a.m. Sonar Testing in Bedded Salt (Jason McCartney- SOCON 

Sonar Well Services, Inc.) 

11:45 - Noon Developing a research plan to evaluate existing brine wells & 

to assess potential risk of collapse (George Veni (NCKRI)

Noon – 1:00 p.m. Lunch (on your own)

1:00 – 1:30 p.m. Potash Well Siting, Construction & Operation (Richard MillerIntrepid Potash)

1:30 – 2:00 p.m. Class II Hydrocarbon Storage Wells- Western Refining L.P. 

Siting, construction & operation. Should these types of wells be 

considered similar to Class III brine wells for potential collapse?

2:00 – 3:00 p.m. Current OCD discharge permit requirements for Class II HC 

Storage & Class III Brine Wells (Carl Chavez- OCD) 

Display of OCD discharge permits and current requirements

3:00 – 3:15 a.m. Break

3:15 – 4:00 p.m. Brine well strategy/talking points (Carl Chavez- OCD)

 Brainstorming

4:00 – 4:30 p.m. Miscellaneous (Work Group)

4:30 – 5:00 p.m. Work Group Summary
Friday, March 27, 2009

8:00 – 9:00 a.m. Siting Criteria (Work Group)

 Proximity of populated development

Proximity of public roadways

Proximity of utilities including water supply wells

Oil & gas production

Potash mining (Hugh Harvey)

Other brine wells/caverns

Easements

WIPP (Chuck Byrum)

Other infrastructure

Disposition of protectable ground water

Thickness of salt ore layer

Interbedding

9:00 – 9:30 a.m. Construction Characteristics (Loren Molleur) 

Re-entry of former oil and gas wells

Thickness and lithology of overburden

Borehole geophysical logging

Well Materials

Casing penetration into salt

Cementation of casing

Multi-well operation

9:30 – 10:00 a.m. Operations (Mark Cartwright) 

Tubing placement

On-site pumping of fresh water

Modes of fresh water injection/brine extraction

Production pressures and rates

Operational lifetime

Closure including possible backfilling of cavern with solid materials

10:00 – 10:15 a.m. Break

10:15 – 10:45 a.m. Monitoring (Work Group)

Subsidence monitoring

Mechanical integrity testing of casing and cavern (Wayne Price)

Surface assessment

Geophysical methods for determination of cavern size and geometry (Andreas 

Reitze)

Groundwater quality monitoring

10:45 – 11:15 a.m. Plug & Abandonment (Work Group)

Fill brine cavern w/ brine water & cement casing to surface
11:15 – Noon Collapse Response (James Rutley- BLM)

Pre-positioning of emergency materials

Immediate public safety

Longer term restriction of access

Property damage (Thaddeus Kostrubala)

Groundwater contamination (Lewis Land)

Backfilling

Noon – 1:00 p.m. Lunch (on your own)

1:00 – 1:30 p.m. NM Class III Brine Well Regulations (Carl Chavez- OCD)

 WQCC 20.6.2 NMAC

1:30 – 2:00 p.m. TX Class III Brine Well Regulations (Jim Griswold- OCD)

 Chapter 3: Oil and Gas Division, Rule 3.81

2:30 – 3:00 p.m. KS Class III Brine Well Draft Regulations (Jim Griswold- OCD)

 Article 46 - Underground Injection Control Regulations

3:00 – 3:15 p.m. Break

3:15 – 3:45 p.m. Suggestions for NM Regulations or Guidelines based on 

WQCC 20.6.2 NMAC (Work Group) 

3:45 – 4:00 p.m. Work Group Members from Industry w/ Work Group

4:00 – 4:15 p.m. Work Group Members from the Federal Government w/ Work 

Group

4:15 – 4:30 p.m. Work Group Members from the State of NM w/ Work Group

4:30 – 5:00 p.m. Work Group Summary & Thank you

(Work Group members who provided e-mail addresses will be 

included on any draft electronic draft documents, regulations, 

report, etc. that may follow from our meeting.
Work Group Biographies

Richard Beauheim (WIPP): Richard Beauheim is a Distinguished Member of Technical 

Staff at Sandia National Laboratories, and is currently Lead Hydrologist for the Waste 

Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico. From 1984 to 1996, he was the 

Principal Investigator for the hydrogeological characterization of the WIPP site. He is 

now coordinating and directing hydrogeologic field studies and hydrology-related 

performance assessment activities related to the recertification of WIPP. He is an 

expert on the geology and hydrology of the Delaware Basin, and has several decades’ 

experience with drilling and testing of wells in that area.

Chuck Byrum (EPA): is an environmental scientist with the EPA Office of Radiation 

and Indoor Air in Washington, DC. He has been involved with WIPP performance 

assessment in multiple capacities, including waste characterization and WIPP technical 

lead as well as conducting other general technical reviews of WIPP and regulations 

development since 1993. Since the WIPP certification decision, he has been the 

Technical Lead working on WIPP performance assessment, WIPP site continued 

compliance of Subpart A, and monitoring programs and is leading the effort to prepare 

for the second re-certification in 2009. Before coming to EPA he worked for almost 

fifteen years in oil exploration, first will Shell Oil and finally with Meridian Oil. 

Carl Chavez (NMOCD): is an Environmental Engineer (August 2005 to present) with 

the Environmental Bureau, Oil Conservation Division, Energy, Mineral & Natural 

Resources Department in Santa Fe, New Mexico. He graduated from New Mexico State 

University with a bachelor’s degree in Geological Sciences and a minor in Economics in 

1986. He attended the California State Polytechnic University in Pomona, California, in 

the Mechanical Engineering-Petroleum Option Program. He has been the permit writer

and inspector for oil & gas refineries in New Mexico. He led the NMOCD’s primacy 

initiative for the NPDES and storm water program. He served as the NMOCD’s Quality 

Assurance/Quality Control Officer and as inspector for the NMOCD UIC Program in 

New Mexico. He has provided technical assistance and testified as an expert witness at 

NMOCD environmental regulatory hearings. 

He worked as an Environmental Scientist/Specialist (March 2004 to August 2005) for 

the New Mexico Environment Department, Hazardous Waste Bureau, Waste Isolation 

Pilot Plant (WIPP) Group in Santa Fe, New Mexico. He evaluated hydrogeologic and/or 

ground water detection monitoring reports from WIPP for compliance with the WIPP 

Permit; EPA ground water monitoring requirements; and RCRA hazardous waste 

regulations. He lead comprehensive groundwater monitoring evaluations of field 

environmental sampling procedures and methods; five-year regulatory review of the 

WIPP Permit and ground water monitoring program; assessments, investigations and 

cleanup actions; evaluations of air ventilation monitoring reports, head space gas 
sampling of waste drums and other technical permit related projects. He participated in

RCRA waste characterization audits/inspections with the USEPA and Carlsbad 

Technical Assistance Group at hazardous waste generator facilities across the U.S. to 

confirm compliance with hazardous waste provisions of the WIPP Permit, i.e., Waste 

Analysis Plan, Waste Acceptance Criteria, etc. 

He spent from 1989 to 2004 working for the Michigan Department of Natural 

Resources-DNR (which later became the Department of Environmental Quality-DEQ) in 

Lansing, Michigan. 

Mike Cochran (Chief Geologist for Kansas Department of Health and 

Environment): has been instrumental and provided information regarding the state of 

Kansas' issues with sodium brine well failures and remediation efforts. 

Daniel Ferguson (DOE): Oversees the activities related to the hydrology program at 

the Waste Isolation Pilot Plant (WIPP) Site. Provides technical oversight of the 

hydrology program to ensure the integration and coordination of work activities of the 

management and operating contractor and Sandia National Laboratories.

Jim Griswold (NMOCD): 

David Herrell (BLM): I was born in Carlsbad, NM in 1955. Graduated from Carlsbad 

High School in 1973, and New Mexico State University, with a Bachelor of Geological 

Science, in 1980. Served in the United States Army and attended Officer's Candidate 

School where he received a commission as a 2nd Lieutenant. He served in various 

staff and command positions and retired as a Lieutenant Colonel after 26 years of 

service. After retirement from the military, he was employed by the State of New 

Mexico as a patrolman with the New Mexico State Police, where he served for 8 years. 

While in the New Mexico State Police, he served as an Emergency Response Officer 

(ERO) and handled numerous hazardous materials spills and other incidents. He is

now employed by the Bureau of Land Management as the Hazardous Materials 

Specialist and Safety Officer for the Carlsbad Field Office. I was involved in the Incident 

Command Center at both of the recent brine well collapses in southeast New Mexico. 

He has an understanding of the basic geology of the area and the processes 

associated with these collapses. 

Courtney Herrick (SNL): I am in the technical lead for the geotechnical / rock 

mechanics group down here at Sandia National Laboratories Carlsbad Field Office, 

4100 National Parks Highway, Carlsbad, NM. I have been working here at WIPP for 4 

years. We are presently poking around with some rock mechanics models.
Dave Hughes (Washington Regulatory and Environmental Science- WRES): has 

an extensive knowledge of the Delaware Basin of New Mexico and West Texas and 

maintains the Geographic Information System for the Department of Energy’s Waste 

Isolation Pilot Plant. Also attached is the background information for Mr. Russ Patterson 

with the DOE Carlsbad Field Office. 

Brad Jones: (NMOCD): is an environmental engineer with the Oil Conservation 

Division’s Environmental Bureau since July 2006. My primary duties include the review 

of permit applications, permit modifications, and closure plans under Part 17 (the pit 

rule) and Part 36 (the surface waste management rule); review of ground water and 

hydrostatic test discharge permit applications, modifications, and renewals under the Oil 

and Gas Act and Water Quality Control Commission regulations; and training and 

outreach on Part 17, Part 36 and discharge permits. Currently, my focus has been in 

the creation of rules and policies and training staff, operators, consultants, and the 

public of the implementation of new environmental rules. He holds a Bachelor of 

Science degree in Environmental Health Science from the University of Georgia. He 

has over 10 years of environmental regulatory experience, mainly as a regulator but 

also some in industry. 

Prior to joining the Oil Conservation Division (OCD) he worked as an Environmental 

Specialist in the Solid Waste Bureau – Permit Section of the New Mexico Environment 

Department for approximately four years. He was involved in the permitting of landfills, 

solid waste facilities. He oversaw ground water monitoring programs and investigations 

for those facilities. Prior to that he worked as an Environmental Specialist I in the 

Florida Department of Health, where he designed, permitted, inspected and approved 

on-site sewage systems. For a short period, He worked as an Environmental Scientist 

for Redemption Environmental, Inc., a small consulting firm in Tampa, Florida where he

performed site investigations, remediation programs, and cleanups of underground 

storage tank contamination sites. He worked as an Environmental Health Specialist II 

for the Island County Health Department in Coupeville, Washington, under a state 

granted funded position that involved overseeing solid waste programs, voluntary 

cleanup programs, investigations of contaminated sites, and the cleanup of meth lab 

sites. He worked as an Environmental Specialist I at the Florida Department of Health 

where I oversaw the implementation of several environmental programs.

Ross Kirkes (DOE): Mr. Kirkes provides environmental consulting services, primarily 

to DOE contractors and laboratories. He supports the development of compliance 

demonstrations and applications and he has provided significant input to the 

implementation of programs to ensure ongoing compliance with the provisions of 

environmental regulatory approvals. Mr. Kirkes has over 15 years negotiating 
compliance issues with various environmental regulatory agencies for the Waste 

Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico. Mr. Kirkes was instrumental in 

the development and production of the demonstration of compliance that led to the U.S. 

Environmental Protection Agency (EPA) certification of the WIPP. Mr. Kirkes combines 

his regulatory experience and knowledge of the regional petroleum industry to ensure 

that future human activities such as petroleum and potash exploitation are accurately 

represented in WIPP performance demonstrations and assessments.

Ray Leissner (EPA): Graduated from Sam Houston State University with a B. S. in Ag 

Business in 1976. Ray entered the field of underground injection control in 1984 

working for the Railroad Commission (RRC) of Texas in Austin while attending class at 

the University of Texas. Ray graduated with a B. S. degree in Petroleum Engineering 

from the University in 1986 and worked full time at the RRC until 1988 wherein he 

accepted a position with the Environmental Protection Agency, Region 6, Dallas.

Initially working in the Region's direct implementation UIC program for the Osage 

Mineral Reserve in Osage county Oklahoma, Ray is now senior program manager in 

the Region's State UIC oversight program. This position involves him with all of the 

state UIC programs in the Region and he directly oversees the RRC.

Lewis Land (NCKRI & New Mexico Tech.): Is a hydrologist with the New Mexico 

Bureau of Geology and Mineral Resources, and the National Cave and Karst Research 

Institute in Carlsbad, NM. He has an extensive background and publication record in 

sinkhole research. He recently completed a manuscript documenting geophysical 

records of the Loco Hills brine well collapse, which will be published later this spring in a 

conference proceedings volume of the Symposium on the Application of Geophysics to 

Engineering and Environmental Problems. He has been conducting aerial surveys of 

the two collapsed sinkholes and has accumulated a large number of photographs 

displaying their growth over the past few months.

Richard Miller (Intrepid Potash): Has worked for Intrepid Potash in Denver with Hugh 

Harvey since 2001. His duties include assisting Hugh with design, permitting, 

construction, and operation of 12 Class III injection wells in Moab that are used for 

injection/extraction of solution mining fluids. 

Loren R. Molleur (Key): Grew up in Tatum, New Mexico. Graduated from high school 

in 1966. Attended New Mexico Junior College in Hobbs, New Mexico in 1968-1969. 

Worked for Amoco Production Company from 1970-81. Started with Amoco in Artesia, 

New Mexico in 1970 working in the Empire Abo Gas Plant. Transferred to Hobbs, New 

Mexico in 1973 and worked for the production group until transferring to Andrews, 

Texas in 1976. While in Andrews, I worked with the production group as well as the 

drilling and work over group. I retired from Amoco in January of 1981 and went into the 

trucking business. Was co-owner of L & L Trucking Company from 1981 until it was sold 
in October of 1997 Work for Key Energy managing their trucking business in the 

Permian Basin and New Mexico for the past 7-8 years. 

Russ Patterson (DOE): Is the Compliance Certification Manager and works closely 

with the Environmental Protection Agency and is very knowledgeable about the geology 

of the Delaware Basin and also EPA’s Environmental Regulations.

Wayne Price (NMOCD): Is the Environmental Bureau Chief of the Oil Conservation 

Division, Energy, Minerals & Natural Resources Department in Santa Fe, New Mexico

(1993-present). He earned a Bachelor of Science Degree in Electrical Engineering from 

New Mexico State University in 1969. He worked in the NMOCD Hobbs District office 

as an environmental engineer, witnessing and evaluating mechanical integrity tests 

(MIT’s) for EPA Class II and III wells, maintained files for discharge permits, processed 

C-141 spill reports, and C-138 waste management approvals. He inspected NMOCDregulated facilities, collected soil and water samples, performed well logging, processed 

APDs, analyzed lab reports, reviewed and evaluated remediation plans, and provided 

training to industry on NMOCD rules, regulations and guidelines. As the Environmental 

Bureau Chief, he has managed bureau staff in their duties: oversight, inspection, and 

permitting of the state’s oil refineries, crude oil pump stations, EPA UIC Class I (oilfield 

exempt, non-exempt non-hazardous waste disposal well), II (hydrocarbon storage), III

(brine well), and V (geothermal well), gas plants, gas compressor stations, oilfield 

service companies, and the management of over 400 active remediation and abatement 

plans throughout the state. He has served as a technical expert witness concerning 

environmental and regulatory issues including evaluation and use of vadose zone and 

ground water modeling. He has served in the New Mexico Water Quality Control 

Commission that presides over the state’s water rules and regulations. 

He worked for Unichem International from 1983 to 1993 where he was manager of 

engineering and environmental projects for Unichem’s domestic operations. He

provided project oversight, maintained cost controls, prepared budgets and supervised 

technical employees for engineering and environmental operations throughout the 

continental United States. Projects included the design, construction, start-up of 

chemical plants, abatement of contaminated sites, and environmental permitting. He

implemented environmental best management practices and waste management 

policies for Unichem’s company-wide operations. He also created a permit tracking 

system for all ground water discharge, air quality, NPDES, storm water, SPCC, RCRA, 

and local permits. He also worked in the oil field as a roustabout and drilling rig 

roughneck during summers when he was not attending college. 

James Rutley (BLM): I was born in Detroit, Michigan in 1964. Graduated from Roswell 

Goddard High School in 1983 and New Mexico State University in 1989 with a Bachelor 
of Science in Geology. Worked two years in the Permian Basin as a mud logger before 

beginning a career in potash. After 15 years, resigned from Mosaic as a Surface 

Production General Foreman to pursue work at the BLM. Works as a BLM geologist in 

the Carlsbad Field Office and am responsible for performing potash mine inspections 

and sodium site inspections. Wrote mineral reports and permit APD's in the potash 

basin. After the first sink hole on Hagerman Cutoff, Dave Herrell and I began 

researching all federal sodium wells both abandoned and current- mapping their 

relationship to municipal and transportation systems. Identified several potential wells 

that could have catastrophic consequences because of their proximity to both systems. 

Dan Snow (Lotus L.L.C.): sdfc

George Veni (NCKRI): is the Executive Director of the National Cave and Karst Research 

Institute (NCKRI) and an internationally recognized hydrogeologist specializing in caves 

and karst terrains. He received his Master’s degree from Western Kentucky University in 

1985 and his Ph.D. from the Pennsylvania State University in 1994. Prior to NCKRI, he 

owned and served as principal investigator of George Veni and Associates for more than 

20 years. Much of his work has been in Texas, but he has also conducted extensive karst 

research throughout the United States and in several other countries. He has served as 

the Executive Secretary of the National Speleological Society’s Section of Cave Geology 

and Geography for 11 years and President of the Texas Speleological Survey for 13 

years, and has served as a member of the governing board of the International Union of 

Speleology since 2002 and as Chairman of the 15th International Congress of Speleology. 

He serves as a doctoral committee advisor for geological and biological dissertations at 

The University of Texas and teaches karst geoscience courses as an adjunct professor for 

Western Kentucky University. Three cave-dwelling species have been named in his honor. 

He has published and presented over 170 papers, including four books, on hydrogeology, 

biology, and environmental management in karst terrains. 

Glenn von Gonten (NMOCD): is a Senior Hydrologist with the Environmental Bureau, 

New Mexico Oil Conservation Division, Energy, Minerals and Natural Resources 

Department. He has a B.S. in Geology from Texas A&M University and a M.S. in 

Geology from the University of Texas at Arlington. He has more than 30 years of 

experience as a geologist and has worked as an environmental regulator responsible 

for the investigation and remediation of contamination sites for the past 14 years. His 

responsibilities with the NMOCD include: supervising, reviewing, and approving 

professional hydrogeologic investigative work plans and reports to determine actual or 

potential threats to ground water from the past, current or proposed activities of oil and 

gas industry; supervising, reviewing, and approving remediation and abatement plans 

and reports; and, performing professional hydrologic, geologic, and engineering work 

related to the NMOCD's environmental protection efforts under the Oil and Gas Act and 

NMOCD rules and regulations. 
From 1999 to 2005, he supervised staff in permitting and overseeing corrective action at 

RCRA regulated U.S. Department of Defense (DOD) installations and sites in the 

Hazardous Waste Bureau of the New Mexico Environment Department. From 1993 to 

1999, he issued RCRA permits with corrective action requirements in the Virginia 

Department of Environmental Quality. From 1977 to 1991, he worked in the oil and gas 

industry as a geologist. 

Veronica Waldram was raised in Carlsbad, NM. Earned a Bachelor of Science degree 

in Environmental Management from College of the Southwest (now named, University 

of the Southwest). Currently a Regulatory Compliance Specialist for Navarro Research 

and Engineering. Navarro is a technical assistance contractor to the Department of 

Energy, Carlsbad Field Office. Review the managing and operating contractor’s 

regulatory reports and documents for environmental compliance. Before Navarro, 

worked as a subcontractor to Los Alamos National Laboratory-Carlsbad Operations. 

Was a member of the Site Generator Interface Team that assisted the National TRU 

Program with their activities at 23 DOE facilities throughout the United States. We 

assisted in certifying the characterization, treatment, packaging and transportation 

programs of TRU waste destined for disposal at WIPP.

Gary Wallace (CRI- Hobbs, NM): sdsd
Work Group:

James_Rutley@blm.gov

byrum.charles@epa.gov

Leissner.Ray@epamail.epa.gov

hugh.harvey@intrepidpotash.com

lmolleur@keyenergy.com

gveni@nckri.org

brad.a.jones@state.nm.us

carlj.chavez@state.nm.us

Glenn.vonGonten@state.nm.us

jim.griswold@state.nm.us

tkostrubala@slo.state.nm.us

balch@prrc.nmt.edu

leo.vansambeek@respec.com

rlbeauh@sandia.gov

grkirke@sandia.gov

reitze@socon.com

mcartwright@unitedbrine.com

dave.hughes@wipp.ws

Allen.Hains@wnr.com

ken.parker@wnr.com

Ron.Weaver@wnr.com

Veronica.Waldram@wipp.ws

RichardM@intrepidpotash.com

cgherri@sandia.gov

dwsnow@lotusllc.com

lyn.sockwell@basicenergyservices.com

dwpowers@evaporites.com

daniel.sanchez@state.nm.us
Internet Work Group:

jhand@kdhe.state.ks.us

khoeffner@kdheks.gov

mcochran@kdheks.gov

jvoigt@solutionmining.org

douglas.johnson@rrc.state.tx.us

joeb@dnr.state.la.us

psbriggs@gw.dec.state.ny.us

david_herrell@blm.gov

lland@gis.nmt.edu

douglas.johnson@rrc.state.tx.us

gary.wallace@crihobbs.com

john.hall@state.nm.us

bill.olson@state.nm.us

kdavis@subsurfacegroup.com

Overbay.Michael@epamail.epa.gov

eric@lonquist.com
Brine Well Collapse Evaluation Report June 18, 2009 

Page 12

FIGURES 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 13

Figure 1: Jim’s Water Services brine well (BW-005) on August 26, 2008. 

Photo courtesy of the National Cave and Karst Research Institute. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 14

Figure 2: Loco Hill’s Water Disposal Company (BW-021) on November 18, 2008. 

Photo courtesy of the National Cave and Karst Research Institute. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 15

Figure 3: Brine Wells in New Mexico sorted by depth to top of salt and length of operations. 
Brine Well Collapse Evaluation Report June 18, 2009 

Page 16

Figure 4: Normal vs. Reverse Circulation.