1

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) used for enhanced oil 

recovery. 

I have looked at the first source to confirm the accuracy 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 from table 5-44 and adding the “injection for disposal” and “offsite 

commercial disposal”. They are making a distinction between commercial and noncommercial disposals. Both types are 

saltwater disposal wells, the difference is described 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 extremely helpful. For background, I am an engineering contractor 

supporting EPA with an oil and gas rulemaking. Information about the rule can be found here 

https://www.epa.gov/eg/unconventional-extraction-oil-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 only data points 

for 2007 and 2012. Let me know if you have any thoughts. They are a bit different but generally on the same order of 

magnitude. I assume that the term “SWD” is equivalent to “Class III disposal” and does not include class II enhanced 

recovery injection, correct? 

http://www.gwpc.org/sites/default/files/Produced%20Water%20Report%202014-GWPC_0.pdf 

http://www.ipd.anl.gov/anlpubs/2009/07/64622.pdf 

Thank you, 

Brent Ruminski 
2

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 into SWD wells from 1995 to 2015. These numbers are pulled from 

the reports submitted by the operators of the SWD wells. I checked them with the production numbers for each year 

and they correspond as expected. Production being less than half of the injected volume of water before 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 of 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