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### Brent Ruminski

From: Day, Ashleigh M. <amday@nd.gov> Sent: Thursday, March 17, 2016 11:06 AM To: Brent Ruminski Subject: RE: SWD inj volumes

Yes the information in spreadsheet I sent you is ok for publication. SWD is a class II saltwater disposal well and does not include class II water injection wells (WI) use d for enhanced oil

recovery.

I have looked at the first source to confirm the ac curacy of the numbers. The number I pulled for 2012 is 240,114,452 and the number that they have for produced water disposed of in a salt water disposal well is 238,663,131. This is taken f rom table 5-44 and adding the “injection for dispos al” and “offsite commercial disposal”. They are making a distinction between commercial and noncommercial disposals. Bo th types are saltwater disposal wells, the difference is describ ed in the paragraph above the table. Again I think this is true for the second source. I pulled 94,545,760 and the total they got is 70,118 ,391.

Ashleigh Day UIC Supervisor North Dakota Industrial Commission Dept of Mineral Resources Oil and Gas Division Phone: (701) 328-8020 amday@nd.gov

From: Brent Ruminski [mailto:Brent.Ruminski@erg.com] Sent: Thursday, March 17, 2016 9:21 AM
To: Day, Ashleigh M. Subject: RE: SWD inj volumes

Hi Ashleigh,

Thank you for quick response on this. This is extre mely helpful. For background, I am an engineering c ontractor supporting EPA with an oil and gas rulemaking. Info rmation about the rule can be found here https://www.epa.gov/eg/unconventional-extraction-oi l-and-gas-industry . Can you confirm that we are able to publish this data into the public record for our rulemaking ?

Attached is the spreadsheet with the numbers I was pulling from the following two reports. There are o nly data points for 2007 and 2012. Let me know if you have any thou ghts. They are a bit different but generally on the same order of magnitude. I assume that the term “SWD” is equivale nt to “Class III disposal” and does not include cla ss II enhanced recovery injection, correct?

http://www.gwpc.org/sites/default/files/Produced%20 Water%20Report%202014-GWPC_0.pdf http://www.ipd.anl.gov/anlpubs/2009/07/64622.pdf

Thank you,

Brent Ruminski2 Eastern Research Group, Inc. (ERG) 14555 Avion Parkway Suite 200 Chantilly, VA 20151 703-633-1701 (office)

From: Day, Ashleigh M. [ mailto:amday@nd.gov ]

Sent: Thursday, March 17, 2016 9:50 AM

To: Brent Ruminski < Brent.Ruminski@erg.com > Subject: SWD inj volumes

Here are the numbers for annual injection volumes i nto SWD wells from 1995 to 2015. These numbers are pulled from the reports submitted by the operators of the SWD w ells. I checked them with the production numbers fo r each year and they correspond as expected. Production being l ess than half of the injected volume of water befor e the Bakken and gradually the volumes of oil and injected produced water start to become closer up to present where it is approaching a
1:1 ratio. I also discussed the numbers with some o f the senior staff here and they agreed that it was correct and trends as expected. I am not sure where the source of your reference points got their information.

Thanks Ashleigh Day UIC Supervisor North Dakota Industrial Commission Dept of Mineral Resources Oil and Gas Division Phone: (701) 328-8020 amday@nd.gov