# Update on the Specifications of the Latest Water Disposal Regulations To Understand Steps to Take to Cost-Effectively Comply A Texas Prospective Michael Sims, P.E. Engineer, Technical Permitting O il & Gas Division, Railroad Commission of Texas

November 2014

# Topics to Be Covered • Disposal Options 

# • Injection/Disposal Wells • Surface Discharge • Recycling/Reuse

# Regulatory Background • There are over 392,000 oil and gas industry wells in Texas • The first injection well in Texas was permitted in 1936 

## • There are have been over 100,000 wells permitted for injection 

## • Over 52,000 have current permits, approximately 32,000 are active

# Statutory Authority

(Oil and Gas Division) • Chapter 27 of the Texas Water Code: • Well is in the public interest 

## • No harm to oil, gas, or other mineral formation • Both ground and surface water protected 

## • Financial responsibility • Various Chapters of the Natural Resources Code:

# Railroad Commission Rules –



# Permitting
• 16 TAC § 3.8 – Water Protection (pits, discharges, waste haulers) • 16 TAC § 3.9 – Oil and Gas Waste Disposal into Nonproductive Formations (Chapter 27 of the Water Code) • 16 TAC § 3.46 – Fluid Injection into Productive Formations (Natural Resources Code )

# Permitting Requirements



# Generalized • UIC Regulations of SDWA • Notice and Hearing Opportunity 

## • Area of Review • Surface Casing Requirements 

## • Base of UQGW vs USDW • Geologic Requirements • Production Casing cementing requirements • Tubing/Packer

# Notice and Hearing

• Surface owner notification • Adjacent landowners (Commercial Disposal ) • Operators within 1⁄2 mile • City clerk if within city limits • Published in newspaper • Protest – considered in public hearing

# Area of Review
• Applicant for a disposal well permit must provide the data of record for wells that penetrate the proposed injection zone within (at least) one quarter (1/4) mile – 

### expanded when appropriate . • Confirm wells have been plugged (or cased and 

### cemented) in a manner that will prevent the movement of fluids into strata other than the authorized injection or disposal zone. • Tabulated data keyed to a corresponding map.

# Geologic Requirements 1. Verify that the proposed injection zone is adequately isolated by relatively impermeable strata to confine injected fluids to the proposed injection interval. 2. Proposed injection interval must be isolated from overlying usable quality water by a sufficient thickness of relatively impermeable strata (accumulative total of at least 250 feet of clay or shale).

# Completion Requirements: Three “Degrees” of Separation Between Injection



## Stream and Groundwater • 1st Degree – Surface casing set through entire interval deemed to have useable quality groundwater and cemented to ground surface • 2 nd Degree – Long string casing with at least 400 – 600 feet of cement above injection interval • 3 rd Degree – Tubing set on a mechanical packer within 100 feet of the top of the injection interval

# 2014 Rule Amendments

• Amendments to Rule 9 (Disposal into Non - Productive Formations) and Rule 46 (Injection Into Productive Reservoir) Adopted on October 28, 2014 • Amendments Became Effective November 17, 2014 • Rule amendments address operation of disposal wells in areas of historical or future seismic activity • New Requirements Will Apply to Applications Received After Effective Date

# New Requirements

• As part of application, applicant must submit a map showing any historical seismic activity within a 100 square mile area of any new proposed disposal well • Equivalent of a 9 kilometer radius around the proposed well. • Historic seismic activity can be obtained from the USGS • Applicant may be required to submit pressure front calculations demonstrating the fluid will be confined to the proposed interval if conditions exist that pose an increased risk • Complex geology, proximity to basement rock to injection interval, transmissive faults, and historical seismic events are conditions that may warrant future study

# Other Changes
• Clarifies Commission staff’s ability to modify, suspend or terminate a disposal well permit if scientific data indicates the well is or is likely to contribute to seismic 

### activity • Possible modifications are reductions in volume and/or pressure or shutting in a well 

### • Clarifies staff may request more frequent reporting of 

### volumes or pressures if staff determines there is a need for this information

# Mechanical Integrity Testing

• Notify District Office in advance of conducting the MIT . • Apply external pressure on the sealed casing/tubing/packer annulus of 200 to 500 psi . • Record stabilized pressure for at least 30 minutes on pressure recording chart. • File results on Form H -5.24 Hour Security – Guard Shack Spill Containment Ring - Dike

Visual Alarm – Overfill Prevention Catch Basin – Load Line Commercial Disposal Facility – Safety Requirements

# Clarification on Domestic Sewage

• Domestic sewage generated at an oil and gas facility (drilling rig, commercial disposal well, etc.) is subject to RRC jurisdiction • Staff is beginning to add language to permits to clarify that any domestic sewage systems at these facilities must be designed, constructed, and maintained by a licensed professional and the resulting waste must be handled in accordance with all applicable local, county, and state regulations.

# Strategies for Obtaining UIC Permits

• Complete application - Carefully prepared and attentive to details • Study geology and engineering of area and design, respectively, to confirm the project is feasible • Strictly adhere to all rules affecting a complete application, administratively and technically

# Injection/Storage Rule



# Amendments

• SWR 13 amendments have been adopted and are effective January 1, 2014 (Well Casing) • Additional amendments to SWR 9 and 46 may begin sometime in 2015 • Informal draft and comment period in 2013 • Follow progress at this link: • http://www.rrc.state.tx.us/rules/proposed.php

# Discharges

• Several types of discharge permits are processed by Environmental Permits: • Permit to Discharge Hydrostatic Test Water • Permit to Discharge Produced Water to Inland Waters • Permit to Discharge Produced Water to the Gulf of Mexico • Permit to Discharge Gas Plant Effluent • All permits in which effluent will reach surface water require both a RRC permit and a permit from EPA. • Application fee to discharge to surface water is $750.

# Discharge to Inland Waters • Limited to produced water • Must comply with 

### Texas Surface Water Quality Standards • East of 98th 

### Meridianonly Carrizo Wilcox, 

### Bartosh, Reklaw formations • West of 98th 

### Meridian

### Must Be For Beneficial Reuse (Wildlife or Agriculture)

# Fluid Recycling

• On-lease recycling of fluid is authorized by rule (no permit needed) • Off-lease stand alone fluid recycling facility would require a permit under Chapter 4, Subchapter B • No additional authority needed if the recycled water is reused in downhole operations • No permit from RRC needed if water is reused in accordance with permit issued by another agency • Permit always needed to discharge to surface water

# Contact Information Michael Sims m ichael.sims@rrc.state.tx.us Environmental Permits Main Line 512.463.3840 Injection/Storage Permits Main Line

512.463.6792