Arkansas Oil and Gas Commission

Lawrence Bengal, Director

Shale Play Water Management Congress 2014

Southern States

Texas, Louisiana, Oklahoma & Arkansas

November 19 - 20 Dallas, Texas

New Water Storage And Pipeline Infrastructure Requirements

To Assess Opportunities For Less Costly Containment
Maintain Storage Integrity – repair 

leaks effectively....... “Plug-O-Matic”
4400+ wells (since 2005)

Fayetteville Shale Production Area

500 new wells completed annually
Arkansas Agencies

Regulating Water Sources, Storage and 

Disposal

 ANRC: Arkansas Natural Resources Commission

 AOGC: Arkansas Oil and Gas Commission

 ADEQ: Arkansas Department of Environmental Quality

 USACE: US Army Corps of Engineers

4
Water Definitions Used for Regulatory 

Purposes with respect to Storage

Encountered Water (EW)

Water encountered during oil or gas drilling operations, 

which is of sufficient quantity to require removal, and 

which is not Produced Water.

Frac Flow-Back Fluid (FFBF)

Fluids that consist of fresh water and solids such as sand or 

other proppant and additives that flow from a well 

following hydraulic fracturing operations.

Produced Water (PW)

Water produced from any productive or potentially 

productive oil or gas producing interval in the well, which is 

not Frac Flow-Back Fluid or Encountered Water.

5
Shale Water Storage Regulations based On 

Regulatory Definitions of Water Type

Encountered Water (EW)

May be temporarily stored in reserve pit, land application 

by permit, removed to SWD well, or transported to 

centralized recycle facility.

Frac Flow-Back Fluid (FFBF)

May only be stored in specialized (approved) reserve pit as 

part of recycle/reuse system, transported to centralized 

recycle facility, or removed to SDW well.

Produced Water (PW)

May not be stored in reserve pit. Must be stored in tanks, 

removed to SWD well, or transported to centralized recycle 

facility.

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Storage Regulatory Framework 

Produced Water Storage Options (if not removed for SWD 

well disposal):

Produced water storage at well-site authorized by AOGC Rule B26, in-ground tank storage prohibited.

Produced water may be transported to an offsite “temporary”

storage as part of an approved recycling/reuse facility authorized 

by Arkansas Dept of Environmental Quality (ADEQ)

Off-site Storage/Treatment Facilities

In-ground lined pit storage authorized

Permitted under NPDES or a State Authorized “No Discharge”

4 facilities currently permitted

Governed by ADEQ Regulation 6
Storage Regulatory Framework 

Frac Flow-Back Water Storage Options (if not removed 

for SWD well disposal):

Frac Flow-Back Water storage at well-site authorized for 

“temporary” storage only in portable frac tanks.

Frac Flow-Back Water may be transported offsite to an 

recycling/reuse facility authorized by Arkansas Dept of 

Environmental Quality (ADEQ) OR stored on-site in a reserve pit 

authorized for “temporary” storage as part of a recycling system.

On-site Storage/Re-use – Reserve Pit

Primary methodology currently used

Authorization by AOGC/ADEQ Joint Rule B-17

Pit construction standards by rule

Pipeline transfer system standards – BMP, welded no-joint poly

Spills/discharges reported to ADEQ
Well Site In-ground Water Storage Currently 

Utilized - Specialized Reserve Pit

Reserve Pit Storage 

AOGC/ADEQ Joint Rule B-17:

• Each pit authorized 

separately.

• two – 40 mil HDPE liners 

with leak detection.

• Water may be stored for 

90 days.

• Recycling plans must be 

filed with ADEQ prior to 

each use.

• Limited life – reviewed 

annually.

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On-site Frac Flow-Back Water storage utilizing specially 

constructed reserve pit, authorized by Rule B-17. Pipeline transfer 

systems authorized by Rule B-17.

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“Frac Road Tank Battery

Fresh Water Source (Company Owned Ponds) (Private Ponds and Lakes)

Fresh Water Source (Creek, River, Stream)

Off Site Reserve Pit: EW and FFBF Frac tank Frac tank

Frac Equipment Area

Reserve Pit EW

FFBF FW

Well

Frac tank Frac tank Frac tank Frac tank Frac tank Frac tank Frac tank Frac tank

Pit Turn Around For Vacuum Trucks to Haul in EW; FFBF

Off Site Tank Battery: Encountered Water

Location Clearing Limits

10" Aluminum Line 10" Aluminum Line

Frac Road Tank Battery for Hauling In EW and FFBF

4" Poly Pipe 4" Poly Pipe only

4" Poly Pipe 4" Poly Pipe

4" Poly Pipe 4" Poly Pipe

Location Lease Road

Fresh Water (FW) Encountered Water (EW) Frac Flow Back Fluid (FFBF) Transfer Pump Vacuum Truck (Fluid Hauling)

LEGEND

Tank
Multi Well Drill Pads Facilitates Reserve Pit Use For Re-use/Recycle System

FW
Multiple well pad showing reserve pit as component 

of the Rule B-17 authorized water storage, recycle 

and re-use system

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QUESTIONS ?