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570979013 Cost of Compliance
Proposed Underground Injection Control Program
Oil and Gas Wells
Prepared for
Office of Drinking Water/U.S. Environmental Protection Agency
June 1979
Arthur D Little ln<
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EPA-570/9-79-013
I DRAFT
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| COST OF COMPLIANCE
PROPOSED UNDERGROUND INJECTION CONTROL PROGRAM
OIL AND GAS WELLS
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" PREPARED BY
" ARTHUR D, LITTLE, INC,
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FOR
f OFFICE OF DRINKING WATER/
U,S, ENVIRONMENTAL PROTECTION AGENCY
EPA CONTRACT No, 68-01-4698 (TASK 6)
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*
JUNE 1979
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Arthur!) Little Inc
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A Note on this Draft Report
This report is being made available in draft form for review
at EPA's regional offices. The final printed report is in
preparation and will be available by approximately June 20,
1979. Some editorial revisions will be made in the published
version of the report, but no substantive revisions are anti-
cipated.
Arthur D Little Ii
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THIiJ Sl-iti: f TO L'E UouD FOR SCAI^vti', COPY 0\'LY
TYC'EV-RITER SEITI'.'G
PARAGRAPH
10 P,TCM
173 o": rcX'r-
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g THIS SHctl IU be VSi^D hUH b^AKNLh COPY ONLY
TYPc'iVRITER SETTING ICP'.TCM Cni'-.'GES Wri'TE OUT
IELE'.'E'-T 175 Gr~. CC'-'^'E" "iZ t.'"-'Di;: .ED LC'.C C' S"L? U:T T HYF.-
SPACING: DOUfLE Bt'LLCTS USE A RED
MARGINS. 1V.- INCHES (BORDERS INDICATED) ADt S? ELL OUT
PARAGRAPH ENDING L'Sฃ - 1 i 1 (NOT ^^^^) E^:TI\C USE RED FE
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G. Thermal-Based Tertiary Recovery
Activity
H. Produced Water Disposal Activity
1. Historical Perspective
2. Salt Water Disposal Well Population
IV. DESIGN AND CONSTRUCTION OF INJECTION
PROJECTS
1
Vi
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^V
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A. Introduction
B. Existing State Regulatory Requirements
1 . Background
2 . Permitting
3. Requirements for Injection Well
Operating Permits
4. Summary
C. State Profile of Injection Operations
1 . Protection of Fresh Water
2. Construction Requirements
D. Current Industry Practices
1. Injection Well Construction
Classification
2 . Summary
V. INJECTION WELL OPERATING DATA
A. Overview
B. Monitoring Practices
1. Performance of Monitoring
Operations
2. Types of Monitoring
C. Collection and Reporting
1. Collection of Monitoring Data
2. Reporting of Monitoring Data
D. Surveillance by State Agencies
E. Conclusions
1
(PAGE
ADL-171.279MW
OR USE CORRECT;', C T^.r
PENCIL DOT t
COW ANY NAVE
SCiL
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PAG!
III-
17
111-18
III-j18
111-20
IV- 1
IV-3
IV- 3
IV-5
IV-8
IV- 1,8
IV- 19
IV- 19
IV-2',3
IV-24
IV-2'6
IV-30
V- 1
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V-9
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THIS S^EET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETTIN3
Ei-EVE'.T.
SPACING:
MARGINS
PARAGRAPH ENDING
1C =!TCH
DOUBLE
I'/; INCHES (ET'^DE17.C INDICATED!
USE .'-lil { N'T f. "i /. 1 )
CHANGES-
LCN; DA'-'ES
BULLETS-
ADL.
EDITING
WHITE OUT OR U?E CO^Rt C"!
t:-E 2 HNFKEN3
USE A RED PENCIL DOT ซ
SCELL OUT CC'/^ANY NAVE
USE RED PENCIL
VI. PROPOSED UNDERGROUND INJECTION CONTROL
PROGRAM
A. Overview
B. Statutory Framework
1. The Safe Drinking Water Act
2. Controlling Underground Injection
3. Applicability to the Oil and Gas
Industry
C. Interpretation of the UIC Regulations
1 . Introduction
2. Subpart A--General Provisions
3. Subpart C Criteria and Standards
Applicable to Class II Wells
VII. APPROACH TO COST ANALYSIS
A. Introduction
B. Overview of Costing Methodology
C. General Approach
1. Profile of Current Practices
2. Identification and Cataloging
of UIC Program Requirements
3. Determination of Incremental
Requirements
4. Development of Unit Cost Estimates
5. Well Population Projections Were
Developed
6. Computation of Incremental Costs
for Each Regulatory Component
7. Summation of Cost Elements
D. Estimates and Assumptions
E. Extent and Limitation of Analysis
PAGE
VI-1
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VI-2
VI-4
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17
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PAGE NUMBER
iii
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iTYPE'.VR.'TEP; SETTING
E L6' V" ' ปT
SฐACIWG-
PARAGRAPH ENDING
1C P:TTM
173 O-. CO-'r.lEr 12 !/. j^! = iฃD
DO UP LE
1\ INCHES (BORDERS INDICATED)
USE A 1 A 1 ( NOT ^ 1 A 1 )
CHANGES. VvH:Tฃ OUT OF. USE C"J~,~
BULLETS USE A RED PENC'L DOT <
AD- S-ELLO'JT CO'." ANY I,A'.
EDITING USE RED PENCIL
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PAGE
VIII. AREA OF REVIEW
A.
B.
C.
D.
Introduction VIII--
!
Background of Area of Review Requirement VIIIJ-4
Analytical Approach and Limitations
of the Analysis
1. Number of Wells to be Reviewed
2. Percent of Reviewed Wells that
Required Remedial Work
3, Unit Costs
Estimated Number of Wells in Area
of Review
1. General Assumptions for
Methodology
2. Number of Producing Wells in
Existing ER Projects
3. Number of Producing Wells in
Existing SWD Projects
4. Summary of Producing Wells in
the Area of Review of New ER
Injection Wells and New SWD Wells
5. Number of Abandoned Wells in the
Area of Review
6. Number of Wells in Area of Review
in First Five Years
E. Remedial Action to Nearby Wells
1. Completion and Plugging Practices
2. Abandoned Wells in the U.S.
3. Producing and Abandoned Wells
Requiring Remedial Action
4. Percent of Wells Requiring Action
for Cost Analysis
F. Unit Costs
1. Costs to Review Well Records
2. Costs to Recement and Test
Producing Wells
3. Costs to Reabandon Plugged Wells
G. Compliance Costs
VI II- 7
VIII-7
VIII-7
VIII-9
VIII
-9
VIIL-13
VIII-17
VIII
-20
V111- 2 1
VIII-22
VIIl'-23
VIII-23
VIIl'-27
VIII-28
VIII.-31
VIII-33
VIir-33
VI Hi-34
VIIl!-35
VIII
-36
PAGE NUMBER
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.TYPEWRITER SETTING
SPACING-
MARGINS
PARAGRAPH ENDING
1C
DO UP IE
V. lf^Cl-lC !E ORDERS !'>DICATED)
USE .11 ^1 ( K3T i 1z. 1 )
CHANGES WHITE OUT OR USE CORRECT)'
LOI.C- OA?HES USE 2 H'rr-'E\1S
BULLETS USE A RED PENCIL DOT
ADL: SpELL OUT COMPANY NAt/i
EDITING USE RED PENCIL
IX. EXISTING INJECTION WELLS TESTING AND
REMEDIAL ACTION
A. Introduction
B. Analytical Approach
C. Data
1 . Well Population Data
2. Unit Cost Data
D. Analysis
1. Salt Water Disposal Wells
2. Enhanced Recovery Injection Wells
X. NEW INJECTION WELLS- - INCREMENTAL COSTS
A. Introduction
B. Analytical Approach
C. Data
1. Well Population Data
2. Unit Cost Data
D. Analysis
1 . Salt Water Disposal Wells
2. Enhanced Recovery Injection Wells
XI. PERMITTING
A. Introduction
B. Preparation of the Permit Application
1. Existing Salt Water Disposal Wells
2. New Salt Water Disposal Wells
C. Testing the Injection Fluid
D. Preparation of Contingency Plan
E. Financial Responsibility
F. Public Hearings
G. Cost Summary
PAGE
IX- 1
IX- 3
IX-3
IX-3
IX-6
IX-1
IX- 1
IX-2
X-1
X-4
X-6
X-6
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X-9
X-9
X-20
XI-1
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XI-4
XI-5
XI-6
XI-7
XI-8
XI-9
PAGE NUMBER
ADL 1T1 279501.'.
(in red)
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TYPEV.RITER SETTING 10 PITC1^ CHA'.'C-ES V.-TTEO'JT
IELEYE',7 'iT 0~ Cc-:: :~ U- I.',1OIF| = D LC">C D-' -ET L.TT T u'vr'
SPACING' DOUBLE 5JLLETS U:E A RED
MARGINS V/: INCHES (BORDERS INDICATED) ADt- SPELL OUT
PARAGRAPH E\DING USE L 1 L 1 (NOT ฃ. 1 ฃ 1 } EDITING USE RED PE
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XII. MONITORING AND REPORTING COSTS
A. Introduction
B. Monitoring Costs Associated With
Salt Water Disposal Wells
1 . Determination of the Number of
Wells Requiring Additional
Monitoring
2. Development of a Unit Cost
3. Calculation of Incremental
Monitoring Costs
C. Monitoring Costs Associated with
Enhanced Recovery Injection Wells
1. Determination of the Number of
Wells Requiring Additional
Monitoring
2. Development of a Unit Cost
3. Calculation of Incremental
Monitoring Costs
D. Monitoring Cost Summary
E. Reporting
1 . Reporting Requirements
2. Analysis of Reporting Tasks
3. Reporting Practices
4. Development of a "Unit Cost"
5. Reporting Cost Calculations
XIII. COST TO STATE AGENCIES
A. Introduction
B. Functions to be Performed in a UIC
Program
1. Permitting of Existing Wells
2. Permitting of New Wells
3. On-Site Inspection
4. Enforcement
5. Complaints
6. Report Review and Data Processing
1. Overhead
1
IPAGE
*DL-17V27950K'
CR USE CO'-" ~ ECT!\; "^ -
; \ฃ
FE!,CILDOT fc
COMPANY r.AVE
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XII-
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TYPEWRITER SETTING 1C F 1C" CHANGES VV~::TE C'-." O- USE CO- r E~.-
c, r> - -r - ~- - - r T~ ,._,_ LON^ D~?';S? ijcr ;> UN r~-f,;:
E -...'.' . . ^ - ^ _x..^. - --
S-AC'Nj DC-JELE &Ji_LE'i L iE f- '*- il< > i , _. ^ DC", t
MARGINS. V: INCHES (BORDERS, INDICATED! ADL &f tl-L 0>JT COV- ANY I,~-','E
PARAGRAPH ENfiNG U3E^1^1 (N~T ^1^1) EDITING USE RED PENCIL
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PAGE
C. Determination of Resource Requirements XII3
-8
D. Estimated Cost of State UIC Programs XIII-10
E. Start-Up Costs XIII-18
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F. Summary XIII-22
XIV. SUMMARY OF COSTS TO OIL AND GAS PRODUCERS
APPENDIX A: Arthur D. Little, Inc . /Inter state Oil Comp
Commission Survey of State Agencies
APPENDIX B: EPA Regional Office Survey Injection Well
Population
APPENDIX C: Field Interview Guide
APPENDIX D: Relationship of Hazardous Waste Regulation
to Underground Injection Control Program
APPENDIX E: Production Well Coverage
Model
APPENDIX F: Estimated Cost of Fully Describing and
Designating the Underground Sources of
Drinking Water
APPENDIX G: Arthur D. Little Project Team
act
s
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1 PAGE NUMBER V11
ADL-U1-27950M (in red
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ซ i iuJ 1. !:. Li IO L't: Uii.i; H. , c J.:ซur .'.\'r;i 1 <_\ ,-'Y C. JL Y
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-. ..,-, .,
LIST OF TABLES
t
1-1 Summary of Total Costs to Oil and Gas Producers -
Five Years
1-2 Summary of Total Cost to State Agencies - Five
Years
t
1-3 Injection Well Population Projections
II- 1 Oil Production and Well Population, 1972-1977
II-2 U.S. Oil Production by State, 1975
II-3 Crude Oil and Natural Gas Production' in the
United States, 1976
II-4 Gross U.S. Gas production
II-5 Producing and Abandoned Wells by State,
December 1976
II-6 Major/Independent Share of Exploratory and
Development Wells Drilled, 1971-1977
1
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PAHAGF A-K cr.'L;i
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, '. V ' ' : ' ฃ"' '''- "' ' " ' "' '" '"' ~~.
,-r- . -. *- - -. i r> " - - t -> '-N i . - r- 1 i * ' ^*t r~* ' (. , J ~- " ' > " ^ ! ; ' '' U ' ' '"
T^ . ,ri(-,ii''i i _ ซ _j t ^ / i_i' >,' f. > '. i '
^ i i ( .""}." /''! " i\ Eiu'Tl\Cj U ^ : t -, L i ^ f ' c * \ . 1 1.
- - \j - - -- ^ ^ .c \ ' > j i , i . j i y *
i
III-1 Purposes and Processes of Hydrocarbon-Related i
Subsurface Injection Activity
[II-2 Number of Oil and Gas Related Injection Wells
by State as of December 31, 1976
i
!
[11-3 Volume of Fluids Injected at Oil and Gas Relate^
i
j
Injection Wells !
i
EII-4 U.S. Injection Well Population and Injection j
i
Volumes as of December 31, 1976
IV- 1 Summary of Field Contacts j
IV-2 Expiration Periods for Injection Well Permits
IV-3 Plat Data Requirements
PAGE N I):.";
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'H i IS I':!!". :IT TO [;!: U^~:) f '-; CO/ "': T!: rr, iv n: u y
i
IV-4 Review Process for Permit Application
iIV-5 State Cementing and Casing Requirements
IV-6 State Definitions of Presh Water
IV-7 Mechanical Integrity Requirements for Permitting
IV-8 Cemented Surface Casing Through 3,000 and 10,000 TDS
IV-9 Cemented Surface Casing Through 3,000 and 10,000 TDS
i
!lV-10 Injection Well Completion Profile
IV-1 1 Injection Well Completion Profile
IV-12 Injection Well Completion Profile by Region j
i
Existing Salt Water Disposal Wells (December 31,' 1976)
j
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IV-13 Injection Well Completion Profile by Region j
!
Existing Enhanced Recovery Wells (December 31, 1979)
IV-14 Injection Well Completion Profile by Regions
New Salt Water Disposal Wells
PAGE NUMBER
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I IV-15 Injection Well Completion Profile by Regions
New Secondary Recovery Wells
IV-16 Converted and Newly Drilled Injection Wells by
Region
V-1 State Requirements for Collection and Reporting
of Monitoring Data
V-2 Salt Water Disposal Wells Current Monitoring
Practi c es
V-3 Enhanced Recovery Injection Wells Current Monitoring
Practices
V-4 Reporting Requirements Categorization Scheme
V-5 Categorization of Current State Reporting Re-
quirements Salt Water Disposal Wells
V-6 Categorization of Current State Reporting Require-
i
Ments Enhanced Recovery Wells
V-l Number of Complaints and Problems Related to
Pollution or Contamination or Ground Water
PAGE NUV.BtR
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V-8 Cost of Current State Efforts in Injection Control
i V-9 State Agencies Costs for Permitting and Surveillance
VI-1 Relationship of Cost Elements to Regulatory Elements
VII-1 Summary of Unit Costs
VII-2 Injection Vie 11 Population Projections
7II-3 Injection Well Population Projections by State
for Base Year December 31, 1979
VII-4 Injection Well Population Data by Geographic Region
VJEII-1 Classification of Oil Producing States by Percent
of 1975 Oil Production from Enhanced Recovery
VIII-2 Estimated 1C umber of Oil Producing Yfclls Potentially
in the Area of Review of New Enhanced Recovery }
i
Injection Wells
t
Estimated Number of Oil Producing Wells 'Dependent'
on Salt Water Disposal Wells
VIII-3
HACE Ku;": :-.^
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VIII-4 Estimated Nurr.ber of Producing Wells Potentially
i
in the Area of Review of New Salt Water Disposal
Wells
VIII-5
Producing Wells Potentially in the Area of Review
of New Enhanced Recovery Injection Wells and New
Salt Water Disposal Wells i
VIII-6 Abandoned Wells of Record Potentially in the Area
i
5
of Review of New Enhanced Recovery Injection Wells
and New Salt Water Disposal Wells
Percent of Wells Reviewed Given 5,000 New Injection
Wells Per Year
V,III-8 Producing Wells in the Area of Review
VpLII-9 Abandoned Wells in the Area of Review
VlII-10 Producing and Abandoned Wells to be Reviewed by!
the End of the Fifth Year
VJIII-11 Summary of U.S. Oil and Gas Producing Well Com-
pletion Profiles
PAGE Mu:.,;:Ln
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11:;> fiiii LI TO r'/. ur^L:
vtll-12 Oil and Gas Producing Well Completion Profiles
by State - 1976
V
LII-13 Abandoned Well Completion Profile by State - 1976
I
vjril-14 Summary of U.S. Well Completion Profiles for
Abandoned Wells of Record
VIII-15 Number of Abandoned Wells in the United States,
1859-1974
VIII-16 Producing and Abandoned Wells Near Injection Wells
VIII-17 Producing Wells in Area of Review of New SWD Wells
Requiring Testing or Recementing
VIII-18 Producing Wells in Area of Review of New ER Wells
Requiring Testing or Recementing
!
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V|EII-19 Procedure and Cost to Re-Enter Improperly Plugged
and Abandoned Well and Re-Abandon
V
111-20 Estimated Costs for Typical Well Re-Abandonment |
of Improperly Plugged Wells
PAGE NUMRL'n
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V11 i~- 2 T "CompTi
. ance
Costs ~fof" Ar'e~a of ReV'I'e'w
IX-1 Existing Salt Water Disposal Wells Without Cement
i
Between the Injection Zone and the Fresh V,7ater Zone
IIX-2 Existing Enhanced Recovery Injection Wells Without
Cement Between the Injection Zone and the Fresh ;
W a t e r Z o n e j
i
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IX-3 Surface Monitored Downhole Tests to Detect Casirig
Lea}; in Injection Wells
IX-4 Surface Monitored Dov.'nhole Tests to Detect Migration
i
i
of Fluids Along the Exterior of an Injection Well
IX-5 Cost of Squeeze Cementing Injection Well
i
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IX-6 Cost of Drilling New Injection Well - 2,000 Feet
j
IX-7 Cost of Drilling New Injection Well - 5,000 Feet
i
!IX-8 Industry Estimates for the Cost of Testing and ;
j
Remedial Action to Injection Wells as Reported '
t
to Arthur D. Little, Inc. in Field Interview:
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jIX-9 Cost of Remedial Action for Wells Failing Casing
Leak Test Existing Salt Water Disposal Wells
JIX-10 Summary: Cost of Fluid Migration Test and
Appropriate Remedial Action
IX-11 Cost of Remedial Action for Wells Failing Mechan
Integrity Test Existing Enhanced Recovery Injec
Wells
IX-12 Summary: Cost of Fluid Migration Test and Appropriate
R medial 7\ c t i o n
X-1 Injection Well Completion Profile by Regions
New Salt Water Disposal Wells
X-2 Injection Well Completion Profile by Regions i
New Secondary Recovery Wells
X-3 Summary of Unit Costs for New Injection Wells
X-4 Summary: Incremental Costs for Hew Salt V.'ater :
Disposal Wells
(in t
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' * " '-*."' *" . . i \ ' i .. u w t> ".', ' I - * % i - * f' '. \ . ; , ,. ' "f \ " ' ' /
XII- 1
X-5 Summary: Incremental Costs for New Enhanced
F. ccevery Wells
XI-1 Permitting Unit Cost Calculations
XI-2 Five Year Summary of Operator's Permitting Costs
Requirements for Additional llonitoring of Salt :
i
Water Disposal Wells
JII-2 Incremental Monitoring Projections for Salt Water
i
Disposal Wells I
i
klI-3 Calculation of National Average Hourly Wane '
!
Collection of Monitoring Data
*II-4 Unit Cost Calculation Detail for Salt Water
Disposal Well Monitoring
JII-5 Five-Year Costs Salt Water Disposal Well Monitoring
(II-6 Requirements for Additional Monitoring of Enhanced
Recovery Injection Wells
PAGE uuv.Br.n
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CC- S' C:.'LY
PARAGRAPH
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JCII-7 Incremental Monitoring Projections Enhanced
Recovery Injection Wells
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CII-8 Five-Year Costs Enhanced Recovery Injection Well'
Monitoring
CII-9 Five-Year Cost Summary Collection of Monitoring ',
Data
CII-10 Characteristics of Reporting Tasks
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TYFd.'.-'Tr i *-_.---.,
ipp;;:
ป.
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V,i:? bSLlr.T 10 I,- UoLU Ft.);-; .-'^. !-,-..;;: f.'.V -. ...\'LY
;: ;;,;::::, .mrP.1?v^,r,:i Lc^c';;..';:.: i^1,;:;1,:
,0 ^'-L ,!.! ( :. -T i^l) tO.T,. , L,, r . U f .......
CII-3 Summary of Total Costs to State Agencies
JIV-1 Cost to Oil and Gas Producers
F-1 Estimated Efforts Required to Perform Tasks for
Massachusetts (5=22)
F-2 Cost Estimates for Designating and Describing ;
the Underground Sources of Drinking Water in
the United States
F-3 Numerical Inforuation for the States
I
F-4 Estimated Subtask Indices (in Team-Months) and
Total Index (Team- Years) for the States
V
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CHAPTER I - EXECUTIVE SUMMARY
A,
In August 1976, the Environmental Protection Agency proposed the Un-
derground Injection Control (UIC) regulations (41 FR 36730) intended
to protect drinking water sources from potential contamination by un-
derground injection wells. These regulations implement portions of
the Safe Drinking Water Act (SVDA) of 1974. After receiving extensive
comment, EPA revised the regulations and reproposed them on April 20,
1979 (44 FR 23738). The reproposed regulations differ considerably
from the earlier version, both in organization and content, allowing
considerably more latitude on the part of state agencies for administering
the UIC program. Of particular note is the consolidation of the per-
mitting and other administrative procedures for the UIC regulations
with the hazardous waste (RCRA) regxilations nnd the water effluent
(NPDES) regulations, proposed for codification in 40 CFR 122, 123, and
124.
This report is an assessment of the. incremental costs of compliance
fl for Class II wells under the UIC program as it has been reproposed.
_. Class II wells are defined as those injection wells used for enhanced
oil recovery, hydrocarbon storage and disposal of oil field production
brines. The reproposed UIC program outlines the minimum acceptable
technical criteria for a Federally approved state UIC program reulating
Class II wells. The costs of compliance estimated in this report are
the direct incremental costs to oil and gas producers and state regula-
ArlhurDI.ittlcIr,
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tory agencies of implementing the proposed UIC program. The economic
impact of the proposed regulations in terms of closed wells or fore-
gone production has not been estirated. The reduced costs of compliance
resulting from wells which would be shut in rather than brought into
compliance also have not been estimated.
The cost estimates in this report cover enhanced recovery (ER) injection
wells and salt water disposal (SWD) wells. Also included in Class II
2
wells are a significant population of hydrocarbon storage wells. Esti-
mating the costs of compliance for these wells was not within the scope
of this analysis. The term enhanced recovery injection well, as used
in this report, includes pressure maintenance, secondary recover}', and
thermal based tertiary recovery injection wells.
M Oil field operations on the north slope of Alaska and those offshore
fhave not been considered in this report. Very little 'production fluid
is injected offshore and the number of injection wells on the north
tf slope is small relative to the national total. Production and injec-
tion well population estimates may include these areas, but the unit
cost estimates have specifically excluded consideration ol these two
very high cost producing areas.
The UIC regulations require that records of all existing SWD wells be
reviewed and/or the wells tested for both casing leaks and fluid migration
out of the injection zone. These data would be examined by state program
EPA has prepared such an estimate. See AA FR. 23758.
2
EPA has estimated the population of hydrocarbon storage wells to be about
15,000. See AA FR. 237A5.
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directors and remedial action, if warranted, prescribed before an opera-
tor would be issued a permit. Existing ER injection wells will also
be tested or reviewed, however, not permitted. In addition to conducting
mechanical integrity tests, operators of new injection wells will be
required to review producing, abandoned and other wells near the injec-
tion well for channels allowing fluid migration between the injection
zone and fresh water zones. Also included in the regulations are re-
strictions on operating practices and requirements for monitoring in-
jection well operations and reporting the monitoring data to the state
director.
Estimating the costs of compliance with the proposed UIC regulations
required the development and use of a six step methodology. First,
the number of injection, producing, and abandoned wells covered by
the UIC regulation was estimated. Second, the current condition of
^
these wells was profiled according to the casing and cementing pro-
grams used. Third, the current industry operating practices were
surveyed; and then the unit costs of bringing individual wells into
compliance were estimated. Next, the regulations were interpreted
as to the likely level of state enfcrce/icnt and finally, these indi-
vidual components were used to make a national cost of compliance
estimate. Wherever possible, regional differences in oil field pro-
duction and injection practices have been considered in the preparation
of this national estimate. Sufficient data on current practices has
not been available from each producing state to make reliable state
and regional cost impact estimates.
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_ The preparation of this report required extensive data base generation.
~ The principal data sources used in this analysis include the following:
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A joint survey by Arthur D. Little, Inc. and the In-
^ terstate Oil Compact Commission (IOCC) of the 31 oil
"* and gas producing states of current state agency re-
quirements and practices. (July 1977)
V An Arthur D. Little, Inc. survey of oil and gas pro-
_ ducing state agencies of the current population of
^ injection wells and their condition. (June 1977)
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Personal interviews with 70 oil and gas producers,
Q) oil field service companies, and state agency staff
^ in all major producing areas to profile current
operating practices. (Fall 1978)
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a Published statistical data on oil and gas production,
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a Unit cost estimates prepared by Subsurface, Inc.,
Houston, Texas, a subcontractor to Arthur D. Little,
Inc.
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j| The physical condition of the more than two million injection, pro-
ducing, and abandoned wells currently in existence reflect the history
V of evolving production technology and gradual recognition by operators
and state agencies of the potential for groundwater contamination.
9 There is little direct information available on. the physical condition
of these wells and their potential for contaminating groundwater re-
sources. A set of assumptions have been developed for determining the
I percentage of wells which state agencies will decide must undergo testing
or remedial repair. These assumptions are listed in the body of the
W report. They are based on inferences from historical data, judgments
fl| of operators and state agencies' staffs and interpretations of likely
state enforcement of the regulations.
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A strict interpretation both of the 10,000 ppm TDS drinking water definition
w and of the construction and abandonment requirements in the regulations
ffc would imply compliance costs far greater than those estimated. The
cost analysis was based on state enforcement of the Federal criteria.
M It has been assumed that the state agencies responsible for implementing
these criteria will utilize the flexibility provided in the regulations.
This means that the current state definitions for groundwater to be
ft protected will be continued and that construction and abandonment
practices in existing injection fields must only comply with state
regulations in effect at the time the UIC program is promulgated, except
when a potential contamination problem has been identified. However,
' . each individual state will prepare its own set of regulations reflecting
ft the state's specific needs and the actual costs of compliance, on a per
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__ well basis, experienced by oil and gas producers within each state is
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likely to vary accordingly.
The costs of compliance with the proposed hazardous waste regulations
resulting from the Resource Conservation and Recovery Act of 1976 have
^ not been included in this report. These regulations apply to surface
* facilities associated with oil and gas production. Any costs of com-
flf pliance with RCRA, or any other Federally mandated program, would be
in addition to the costs estimated in this report.
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B. MAJOR FINDINGS
The total incremental cost of compliance with the UIC program to opera-
tors of oil and gas related dnjectAcr: veils during the first five years
of the program is estimated to be approximately $650 million. At about
$130 million per year, these costs of -compliance are estimated to be
between 3 and 5% of total capital investment for the on shore oil and
gas producing industry. The total cost to state regulatory agencies
for implementing a Federally approved UIC program in the 22 designated
states is estimated to be about $18 million. Figure 1-1 shows the re-
lationship between these two cost components.
Approximately $410 million, or 63% of the total expenditures by oil and
gas producers will be related to producing and abandoned wells located
near new injection wells. (Figure 1-2.) Because of high cost estimate
V for this element of the regulations, EPA has provided for a re-exardrmticn
of the area of review requirement at the end of the first year following
promulgation. Should EPA make a decision to discontinue this require-
I merit, actual costs of compliance will be significantly lower than the
estimates provided in this report. Two hundred and ten million dollars.
w or 32% of the total cost, will be expended on existing injection wells.
f The remaining 5%, or $31 million, is divided among the permitting pro-
gram, $20 million, the collection and reporting of monitoring data, $4
million, and new injection wells, $7 million.
New information received too late to be included in the formal analysis
suggest that the incremental cost to industry for the permitting pro-
cess might be as high as $40 million. This data concerns a require-
ment for operators to conduct a water quality analysis prior to being
issued a permit.
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97cf OF EACH COMPLIANCE DOLLAR IS
INCURRED BY OIL AND GAS PRODUCERS
State Costs
Total Incremental Program Costs $605 Million
Source: Arthur D. Little, Inc.
FIGURE (-1 COMPLIANCE COSTS RELATIVE TO TOTAL PROGRAM COSTS
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OIL AND GAS PRODUCERS WILL SPEND GSc'OF EACH UiC COMPLIANCE DOLLAR
TO TEST AND TAKE REMEDIAL ACTION ON PRODUCING AND
ABANDONED WELLS IN THE AREA OF REVIEW
Permitting
oC
Monitoring
1d
New Injection Weils
.'.'.-'.-.' . Producing and ':.:
ป'V: Abandoned Wells '.;
in the Area of Review
Existing Injection
Wells
Total Industry Costs $050 Million
Source: Arthur D. Little, Inc.
FIGURE 1-2 COMPLIANCE COSTS CATEGORIZED BY PROGRAM ELEMENTS
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The distribution of incremental costs to oil and gas producers by type
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of activity is shown in Figure 1-3. Fully 75%, or $480 million, is
estimated to be spent on remedial action to injection, producing, and
abandoned wells, which pose an actual or potential threat to underground
sources of drinking water. Twenty-one percent, or $140 million, will
be spent for testing and reviewing well records. The remaining 4%, or
$30 million, will be distributed among the administrative activities,
such as permitting, monitoring, and reporting.
A third distribution of industry costs by type of well is detailed in
Figure 1-4. Approximately 37%, or $240 million, will be expended di-
M rectly on injection wells; the remaining 63% will go to producing and
^ abandoned wells (as also shown in Figure 1-2). About $320 million, or
49%, has been estimated as the cost for reabandoning previously abandoned
wells in an area of review near injection wells. Making this estimate
required development of assumptions from scarce data resulting in a
| high potential for variance in the actual costs from those estimated.
Focusing regulation on new wells is consistent with the generally pre-
vailing environment protection philosophy of concentration on new
facilities. A distribution of the total incremental compliance costs
for new and existing injection wells is displayed in Figure 1-5. Sixty-
six percent, or $430 million, is applicable to new injection wells.
If this amount were allocated equally to all new injection wells, the
average incremental cost for each new injection well would be about
$17,000, and for each existing injection well it would be about $1,600.
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01 LAND GAS PRODUCERS WILL SPEND 75dOF EACH UIC COMPLIANCE DOLLAR
FOP REMEDIAL ACTION
(petmining, monitoring, &iepomng)
Total Industry Costs S650 Million
Source: Arthur D. Little, Inc.
FIGURE 1-3 COMPLIANCE COSTS CATEGORIZED BY TYPE OF ACTIVITY
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OIL AND GAS PRODUCERS VYI LL SPEND 3/cOF EACH U!C COMPLIANCE DOLLAR
DIRECTLY ON INJECTION WELLS
Total InriLiUy Costs ฃ:.50 Million
Source: Arthur D. Little, Inc.
FIGURE 1-4 COMPLIANCE COSTS CATEGORIZED BY TYPE OF WELL
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OIL AND GAS PRODUCERS WILL SPEND 66d OF EACH UIC COMPLIANCE DOLLAR
FOR PERMITTING NEW INJECTION WELLS
y^^\ y- :^' .\U^\
/'' ''' ''' ''- ' ' '-' '' :'': ' ^\
/.'''':'''.'::' '' -::-.;:;.-.- : '''::'':. '' :' ': \
f . .' ..'.-.' ... - - .-/ ' . . \
ฃ . - . .--.'' .-. '. \
/-.' '- -.''- ; '; ,y ;," .- . .- -. \
imM^^-w -^:&m
V-:-:-:-:-:-:-:-:-: '.^ *'-.; -. : : ,
\ Existing Inicction Wells /
\. 34tf /
Total Industiy Costs S650 Million
ource: Arthur D. Little, Inc.
FIGURE 1-5 COMPLIANCE COSTS FOR NEW AND EXISTING INJECTION WELLS
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These averages are misleading, however, because remedial action only
applies to a small percentage of veils. Most new wells will experience
costs lover than f]7,000 but a 5-vail miir.bcr of veils will face costs
much greater than $17,000. Even with the inherent limitation of using
averages, one sees that the average incremental cost to an operator of
a new injection well is more than ten times greater than for an existing
injection well. Because of this cost differential, largely driven by
, the area of review requirement, there may be some disincentive for the
development and construction, or conversion, of new injection wells.
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At year end 1976, there were an estimated 127,300 injection wells in
active use, including 90,500 enhanced recovery injection wells, 25,400
salt water disposal veils, and 11,400 producing wells vith annular in-
jection. At year end 1979, the base year for the analysis, there will
P be an estimated 140,000 injection veils of which 100,000 will be onhr.nred
recovery injection wells and 40,000 will be salt water disposal wells,
* including annular injection wells. The number of active injection veils
are projected to increase at a rate of 3.5% per year for enhanced re-
covery injection veils and 2.25" per year for salt vstrr disposal wells.
The number of new injection wells estimated to be permitted each year
totaled 5,000: 4,000 new enhanced recovery injection wells; and 1,000
new salt water disposal wells. To balance the projected growth rate
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with the number of new wells permitted each year, the projection allows
for a small number of injection wells to be retired from operation.
For purposes of this analysis, it has been assumed there are 505,000
active oil producing wells and 1.2 million abandoned wells recorded by
state agencies.
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There is oil and gas producing in 31 of the 50 states. However, the
industry is geographically concentrated. In 1976, Texas accounted for
40% of the total U.S. production and 32!' of the producing wells for an
average production rate of 20.2 barrels per well per day. The top five
states in 1976 (Texas plus Louisiana, California, Oklahoma, and Wyouing)
account for 81% of total production and 63% of the total number of pro-
ducing wells. The average production from wells in these states is 21.3
barrels per well per day. Production from wells in the remaining 26
states averages less than ten barrels per day. In 1976, stripper wells,
wells producing at a rate less than ten barrels per day, numbered 365,000,
or 73% of all oil producing wells. These wells accounted for 13% of
total U.S. production at an average rate of less than three barrels per
day. About 30% of these stripper wells are located in Appalachia and
the Illinois Basin, regions that combined account for less than 2% of
domestic oil production.
9 The domestic production of crude oil has declined steadily from 9.4 million
| barrels per day in 1972 to 7.8 million barrels per day in 1977. The ap-
plication of enhanced oil recovery practices utilizing injection wells
is increasing. In 1960, 27% of production was from enhanced recovery,
and by 1977, it rose to 53%.
State agencies estimate that over 11 billion barrels of fluid were in-
jected for enhanced oil recovery in 1976. This fluid injection was
conducted through about 90,500 wells at a rate of just over 330 barrels
per day. An additional 8.4 billion barrels of fluid were injected for
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disposal purposes through about 25,400 injection wells &t an average
rate of 900 barrels per day. Texas accounted for 34% of enhanced re-
covery injection wells and 51ฐ' of cr.lt water disposal wells which re-
spectively injected 28% and 45% of the total volume of fluids. Together,
the top five oil producing states accounted for 62% of the enhanced re-
covery injection wells and 65% of the salt water disposal wells, and
respectively, 53% and 65% of the total volume of fluid injected.
Although drilling activity in the United States has declined steadily
following the Korean War, beginning in 1972, drilling has increased at
about 15% per year through 1977. Even more significant is the increased
* success ratio for new wells, which has increased from 17% in 1972 to
27% in 1977 for exploratory holes and from 10% to 17% for new field
wildcats.
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The increase in underground injection has been paralleled by increasing
* pressure to maintain and protect underground reserves of fresh water.
About 20% of all fresh water used in the United States comes from un-
derground aquifers; but the dependence on groundwater varies greatly
ฃ between regions. In Arizona, 62% of all water used comes from ground-
. water. Municipal wells supply 80% of the public water systems in the
country. These well supplied systems serve 30% of the nation's popula-
tion. In addition, almost all of the nation's rural population receives
water from wells; some ten million families are supplied by these in-
dividual wells.
Statistics from Groundwater - An Overview report by the Comptroller General;
June 21, 1977.
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Areas which show the greatest dependence on groundwater (for irrigation
and human consumption) often include important oil production centers.
The vitally important Ogallala Aquifer overlies oil production zones in
West Texas and New Mexico, Kansas, and Oklahoma. The aquifer sustains
a much higher level of agricultural and commercial activity than the
dry lands of the high plains could normally support. The Ogallala
Aquifer is being rapidly depleted, and the value placed upon this un-
contaminated water resource continues to grow. There is both a growing
dependence on enhanced recovery practices and a growing dependence on
underground sources of drinking water.
Most states have existing programs for the protection of groundvater
ซ and the regulation of underground injection. However, most of these
programs were designed not to correct past problems but to prevent new
ones. Existing injection wells were, in most cases, "grandfathered."
Existing programs in many states perform only administrative functions.
jj Enforcement systems, if they exist, are primarily responsive to com-
M plaints. Estimated expenditures for the regulation of underground
injection vary from a high of $1.8 million in Texas to a low of $1,500
in South Dakota, While some major oil producing states, such as lexas,
have a well developed base for the new UIC regulations, almost all states
jง will be required to upgrade current programs to meet minimum EPA stan-
m dards. This will require substantial additional expenditure in a state
like South Dakota just to achieve these minimum standards.
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The state agencies in 22 designated states will spend an estimated
$18 million for UIC programs above current expenditures over the next
five years, including enforcement activities. This figure averages
M*
out to $3.6 million per year higher than the 1976 state agency budgets,
an increase of about 85% over the 1976 level.
Arthur I) bah
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Recurring costs.
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. C. COSTS OF COMPLIANCE
Two principal categories of cost impact from five elements of the UIC
fl program have been analyzed. The tvo categories are:
Nonrecurring costs, and
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The five regulatory elements are:
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Area of review,
fl ฉ Testing and remedial action to existins injection veils,
ฃ e Testing and remedial action to new injection veils,
e Permitting, and
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e Collecting and reporting monitoring data.
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jm The individual cost estimates for the elements of this matrix are sum-
marized in Table 1-1. State agency costs have been estimated separately
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and are shown in Table 1-2.
Arthur I) Little in
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TABLE 1-2
SUMMARY OF TOTAL COST TO STATE AGENCIES -
FIVE YEARS
($ millions)
1. Operating Costs
- Permitting New Wells $ 5.0
Permitting Existing Weils 7.8
Enforcement 14.1
Report Processing 2.3
Overhead 5.6
2. Total Operating Costs $34.8
3. Start-up Costs 4.2
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" 4. Total Costs $39.0
fl| 5. Less Current Operating Budget1 20.7
6. Incremental Cost $18.3
1. Based on continued agency spending for five years at 1976 level.
Source: Arthur D. Little, Inc., estimates.
NOTE: Individual cost elements used in the preparation
of this table may vary by as much as +_ 50/i.
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These point cost estimates are the direct incremental cost to oil and
gas producers for coreplying with the proposed UIC program during the
first five years folio*.'ing its pror.ulf.r.ti on. Tipper snd lever bounds
on the national cost estimates have not been specifically evaluated.
Several of the average unit costs could vary by as much as plus or
minus 50%. In addition, variations in the central assumptions of
regulatory interpretation and the current condition of existing wells
could alter some cost elements by a similar amount. However, these
variations are not likely to be consistently in the same direction.
Injection well population data have been broadly classified, first by
intended type of service, either enhanced recovery injection or salt
water disposal, and second, by service date, either new (commencing
injection following the promulgation of a state UIC program), or ex-
isting. For purposes of this analysis, the date for distinguishing
between new and existing injection wells was selected as December 31,
1979. Table 1-3 summarizes the injection well population estimates.
Several as si:-pt ions are central to the cost analysis. First, is the
estimate of $20,000 for reabandoning previously abandoned wells in
the area of review. Field data suggest that this average cost could
range from $10,000 to $40,000. The cost of reabandonment is 50% of
the total cost of compliance. Second, assumptions based on operator
judgment have been made as to the expected failure rate for wells con-
ducting a mechanical integrity or fluid migration test. The assumptions
are important to the total compliance cost estimate because of the
Arthur D I.it! !c
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large well population to which they apply. Third, fluid migration or
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mechanical integrity tests may be inconclusive indicators of potential
groundwater contamination. In the.r.e capos, the potential for state
required remedial action is hard to predict. Some operators may have
to take remedial action without conclusive evidence of potential con-
tamination.
Finally, the analysis assumes that enhanced recovery injection well
operators have a somewhat greater incentive to maintain their facilities
in good operating condition. This assumption implies that operators
would already be performing some remedial action in order to maintain
oil recovery operations at peak efficiency. While most oil and gas
operatois believe this assumption was probably correct, no field data
is available as a foundation for the assumption or the degree to which
compliance costs for enhanced recovery fields will be lower because of
more acceptable current practices. For this analysis; the failure rates
B apply to enhanced recovery injection well operations were reduced by 25%
from the percentages applied to salt water disposal operations. Because
of the larger population of enhanced recovery injection wells, this "25%
I factor" significantly reduces the total costs of compliance with the UIC
I
program.
These assumptions were developed using the best available data, how-
ever, the cost analysis is particularly sensitive to variations, either
positive or negative, from the estimates used. Should actual experience
ultimately establish failure rates that are different from those used
Arthur I") Little It
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in preparing this cost analysis, the compliance costs will al^ r>e
different.
Arthur D Little
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETTING: 10 PITCH
ELEMENT: 173 OR COURIER 12 MODIFIED
SPACING: DOUBLE
MARGINS: V/4 INCHES (BORDERS INDICATED)
PARAGRAPH ENDING: USEAlAl (NOT A 1 A 1 )
CHANGES: WHITE OUT OR USE CORRECTING TAPE
LONG DASHES: USE 2 HYPHENS
BULLETS: USE A RED PENCIL DOT *
AOL: SPELL OUT COMPANY NAME
EDITING. USE RED PENCIL
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CHAPTER II
PETROLEUM PRODUCTION IN THE UNITED STATES - A PROFILE
The petroleum industry operates today in an uncertain
international environment. Following three decades of
abundant supplies of crude oil and relative price sta-
bility, an increasing international demand and the for-
mation of the OPEC cartel have led to rapidly escalating
world prices over the last five years. While domestic
demand has continued to increase, supplies available to
U.S. markets have fluctuated widely in recent years as
a result of both economic and political factors. The
prospects for improvement of this situation are unknown),
and hence the long-term industry outlook remains in
question.
A. CRUDE OIL AND NATURAL GAS PRODUCTION IN THE
UNITED STATES
Domestic production of crude oil declined from 9.4
million barrels per day (MMBD) in 1972 to 7.8 MMBD in
1977, an annual decrease of 3.7%. This decline in pro-
duction is expected to continue over the long term;
PAGE NUMBER
; -ctt
(in red)
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETTING'
ELEMENT.
SPACING'
MARGINS.
PARAGRAPH ENDING.
10 PITCH
173 OR COURIER 12 MODIFIED
DOUBLE
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USE 11 A 1 ( NOT A 1 ^ 1 )
CHANGES: WHITE OUT OR USE CORRECTING TAP
LONG DASHES. USE 2 HYPHENS
SULLETS, USE A RED PENCIL DOT *
AOL. SPELL ObT COMPANY NAME
= D'7iNG USE RED PENCIL
however, the Bureau of Mines (BOM--now the Bureau of
Energy Data in the Department of Energy) forecasts a
slight increase over the short term to between 8.2 and
8.5 MMBD in 1980. Domestic production of natural gas
declined from 24.0 trillion cubic feet (TCF) in 1972
to 20.0 TCF in 1977, although production in 1977 was
up 2.6% from 1976 levels. The long-term forecast for
gas production is also at substantially reduced levels;
however, production over the short term (1980) is
expected to maintain or improve slightly over 1977
levels. Figure II-1 highlights these trends in domestic
joil and gas production and Figure II-2 outlines the
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'major oil producing fields in the continental United
States.
1. Oil Production j
JAt year-end 1977, there were about 508,500 oil producing
I |
wells. Stripper wells, wells producing less than 10
PAGE NUMBER
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
YPEVVRITEH SETTING
ELEMENT
SPACING:
MARGINS
PARAGRAPH ENDING.
10 ?!TCH
173 GR COURIER 12 MODIFIED
DOUBLE
1'/. INCHES tBORDERS INDICATED!
USE i 1 A I ( NOT A, 1 A 1 )
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BULLETS. USE A RED PENCIL DOT *
ADL. SPELL OUT COMPANY NA>V5
EDITING USE RED PENCIL
barrels per day (BPD), accounted for 72.5%, or 369,000
wells. Table II-1 summarizes well population data and
oil production from 1972 through 1977. While total
daily production averaged only 15.3 BPD, production
from non-stripper wells averaged 48.7 BPD, and from
stripper wells, 2.91 BPD. Table II-2 shows 1975 pro-
duction and well population figures by state with par-
ticular emphasis on the impact of stripper wells on
production, while Table II-3 shows 1976 production and
well population data by state for both crude oil and
natural gas.
Of particular interest in Table II-3 is that the top
five oil-producing states (Texas, Louisiana, California
Oklahoma, and Wyoming) account for 81% of total pro- j
i
duction and only 63% of total wells. Thus, the daily
I
production for the remaining states averages less than \
10 BPD, and stripper oil in these other states averages!
just over 1 BPD. It is clear, therefore, that operator^
outside the top five oil-producing states are less able!
I
to bear any economic burden placed on them as the result
jof increased regulation.
i
PAGE NUMBER ~^~
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TABLE 11-1
OIL PRODUCTION AND WELL POPULATION, 1972-1977
1972 1973 1974 1975 1976 1977
Well Population
Total Oil Producing Wei Is 508,443 497,378 497,631 500,333 499,110 508,561
Number of Stripper Wells 359,471 355,229 366,095 367,872 365,733 368,930
Stripper Well % of Total 70.7 71.4 73.6 73.5 73.3 72.5
Oil Production
Total U.S. Production (MMbbls/yr) 3,307 3,213 3,065 2,927 2,995 2,874
Stripper Well Production (MMbbls/yr) 412 386 412 394 392 392
Stripper Wei I % of Total 12.5 12.0 13.4 13.5 13.1 13.6
Average Daily Stripper Well Production (bbls) 3.13 2.97 3.08 2.93 2.93 2.91
Source: "National Stripper Well Survey:" Interstate Oil Compact Commission and the National Stripper Well Association,
Bureau of Mines Information Circular 8734. "Energy Data Reports," Department of Energy. "Stripper Oil Well
Production," American Petroleum Institute Fact Sheet.
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Enhanced oil recovery practices, including both
secondary and tertiary recovery practices, now account
for over 50% of all domestic oil production. This per-
centage applies equally to stripper and non-stripper
oil production, and has increased in importance from
27% of production in 1960, to 47% in 1970, to an esti-
mated 53% in 1977. The Bureau of Mines estimates that
by 1980, over 60% of U.S. production will come from
enhanced recovery practices. (See Figure II-3.) Esti-
mates reported from individual states for 1976 show that
over 11 billion barrels of fluid were injected for en-
hanced oil recovery. This fluid injection was conducted
through about 90,000 wells at a daily injection rate of
just over 340 barrels. The top five oil-producing
states accounted for 53% of the fluid injected and 62%
of injection wells.
The major proportion of injection fluids is salt water
produced from lifting oil out of the ground. In older
wells, the ratio of salt water to oil can be as high as
99 to 1, while the average for the country as a whole
is about 7 to 1. Most of this produced salt water
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,must be re-injected either for enhanced recovery or disj-
! I
-posal. There are parts of the country where the for- ;
,mation fluid is of sufficient quality to warrant dis- j
.charge into surface streams. However, in other parts
Jof the country, additional injection fluid must be pur--
! i
jchased for re-injection because formation fluid produc-i
i i
jtion is insufficient to accomplish adequate enhanced !
recovery. Details on enhanced oil recovery and salt
water disposal practices can be found in Chapter III.
2. Natural Gas Production
Natural gas is produced either from gas reservoirs or in
.association with crude oil production. In 1976, about
137,600 non-associated gas-producing wells in the United
;States accounted for 82% of total natural gas production.
This percentage increased only slightly from 1972 to
!1976 as shown in Table II-4. However, average non-
'associated well production declined from 0.55 million
:cubic feet per day (MMCFD) in 1970 to 0.34 MMCFD in 1976.
Details on natural gas production are shown in Table II-3.
Although there are injection wells associated with gas
production and some gas wells are located in or around
-------
TABLE 11-4
GROSS U.S. GAS PRODUCTION
Nonassociated Associated Total
1972 79.3% 20.7% 100.0%
1973 80.5 19.5 100.0
1974 81.7 18.3 100.0
1975 82.4 17.6 100.0
1976 82.1 17.9 100.0
5-YearAv. 81.2 18.8 100.0
Source: American Gas Association data: Annual "Gas Facts," 1977.
-*l
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USc '_'>-'^ ; _
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oil fieldSj the percentage of total wells impacted by j
I
the proposed Underground Injection Control (UIC) pro- <
\
gram is small in comparison to oil-producing related j
wells. This analysis, therefore, focuses primarily on
oil production and the cost of compliance with the UIC
program.
3. Oil Producing Wells
a. Description of Wells
Crude oil and natural gas flow from underground reser- '
voirs to the surface through wells. As shown in
Figure II-4, wells are a series of pipes or casing joints
assembled together to form a continuous string from the;
producing zone(s) to the above ground well head. This
string is developed during the well-drilling operation.1
As the hole is deepened, additional sections of pipe
are added.
When the well is drilled to its final depth, tests of
the reservoir are conducted and a decision is made re- '<
igarding the well's completion. If tests indicate that
commercial quantities of oil or gas cannot be produced,
the well is designated a dry hole and is plugged and
^abandoned. If commercial production is possible, tne
-------
WELL HEAD
CONDUCTOR
SURFACE CASING
INTERMEDIATE
PRODUCTION CASING
CEMENT
CASING SHOE
LOOSE SURFACE SOIL
SHALE OR CLAY
GRAVEL BED
SHALE
FRESH WATER SAND
SHALE
LIMESTONE
SHALE
OIL SAND
SHALE
Source: Petroleum Extension Service University of Texas at Austin
FIGURE 11-4 CASING STRINGS AND PIPE USED IN AN OIL WELL
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[well is completed. This completion process involves -.
I ;
jthe running of a final string of small diameter pro- !
i ;
Jduction casing or tubing through which the oil or gas ;
i '
,'is produced.
I
Tubing packers are sometimes required to seal the space!
between the larger diameter casing and the smaller dia-
jmeter tubing. Sealing is typical in wells producing
i
!
jfrom high-pressure reservoirs. Packers prevent the
i
!
'casing from being exposed to high pressures and lessen
I
1
|the probability of casing failure.
i
j b. Drilling Activity
While drilling activity grew rapidly following World
IWar II (Figure II- 5) , the number of wells drilled
^following this boom declined at 5% per year beginning
.in 1956. More recently, the total number of wells
'drilled has increased at a rate even higher than that
of the early post war period. A current profile of pror-
ducing and abandoned wells by state is shown in Table II-5
of even greater significance than the increased drilling
activity is the increased success ratio for new wells
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03
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CM
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QC
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TABLE 11-5
PRODUCING AND ABANDONED WELLS BY STATE, DECEMBER 1976
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky2
Nebraska
Indiana
Pennsylvania
West Virginia2
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Totals
Drilled Wells
632,171
131,859
110,172
302,473
35,369
42,577
903
174,773
17,139
4,795
713
22,950
20,463
106,998
28,345
5,551
26,389
2,133
122,577
80,705
12,806
57,157
294,123
96,772
9,682
2,367
422
596
166
1,098
257
2,344,501
631,842
Abandoned Wells
Total Number of
Producing Wells
191,261
30,395
43,423
81,223
10,069
25,113
262
50,945
2,485
3,289
143
4,763
4,479
23,377
4,983
2,018
8,752
653
28,270
21,216
1,308
5,454
49,100
35,380
6,331
182
29
38
6
168
192
Recorded1
By State
350,000
119,297
47,000
290,000
18,000
16,088
456
103,600
20,500
N.R.
710
N.R.
N.R.
50,000
26,000
3,633
N.R.
1,475
84,000
10,000
16,000
25,000
14,300
10,000
N.R.
N.R.
N.R.
750
N.R.
250
N.R.
Not Recorded
By State
N.R.
500
500
5,000
N.R.
5
0
300
50
N.R.
10
750
N.R.
50,000
7,000
N.R.
N.R.
50
15,000
50,000
N.R.
1,000
200,000
50,000
N.R.
N.R.
N.R.
75
N.R.
3,500
N.R.
1,207,059
384,740
N.R. - No Response.
1. States have at least location and depth information.
i of abandoned wells of record based on the proportion of neighboring states.
2. Estimated proportion
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., June 1977.
Drilled Wells: IPAA, The Oil Producing Industry in Your State.
Arthur D Little, fn<
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30
8 25
3
O
ฃ 20
0}
O
15
O
to
i 10
X
01
New-Field Wildcats
01
1962
1967
1972
1977
Source: American Association of Petroleum Geologists.
FIGURE 11-6 EXPLORATORY WELL SUCCESS RATE, 1962-1977
Arthur D Little Inc
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
independents heavily focused in wildcat exploration
|
the integrated majors involved in development and pro-
I
jduction.
(The overall number of participants in the industry has j
1 !
jbeen variously estimated at between 5,000 and 10,000, ;
!
j i
Sbut we believe that the lower number is more representa-
l
i
jtive of the active companies. About 1,500 of these have
(entered the industry since 1971, and new ventures are
i
istill being formed at an active rate. It is estimated
!
i
'that about 300 companies have sufficiently broad stock
{ownership to be described as "public" companies.
i
)
JBased on evidence obtained from the annual Department
|
!
jof Commerce surveys, as well as other industry data, it: has
been estimated that the majors and independents now share
[exploration expenditures about equally. However, be-
jcause of their longer historical involvement in the
industry and also their tendency to take over or parti-
cipate in development of properties from the independents,
'the majors control a significantly higher fraction,
about 67%, of proven oil and gas reserves.
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jln terms of numbers of wells drilled, the independents
Ishow clear dominance, accounting for about 90% of the
jtotal exploratory wells drilled and over 75% of the
i
idevelopment wells drilled in 1977. (See Table II-6.)
I
s
'These ratios not only illustrate the significance of the
independents' role, particularly in exploratory efforts,
but also suggest that the average cost of the wells drilled
(by independents is significantly less than that of the
j
Swells drilled by the majors inasmuch as the overall
j
'spending levels are judged to be identical. This is
partly accounted for by the majors' recent activity in
i
'high-cost exploration and development projects offshore-
and in Alaska. ;
i
.Because the independents have maintained an aggressive
pace of exploratory efforts in recent years, they appear
,to be holding about a level reserve position overall
whereas the total U.S. reserves have been declining.
Even though the majors have been expending similar amounts
jfor exploration activities, their overall yield from
;this effort has not been as sizable as the reserve
.additions achieved by the independents with their greater
emphasis on onshore programs.
-------
TABLE 11-6
MAJOR/INDEPENDENT SHARE OF EXPLORATORY AND DEVELOPMENT WELLS
DRILLED, 1971-1977
(percent of welts)
1971 1974 1975 1976 1977
Exp. Dev. Exp. Dev. Exp. Dev. Exp. Dev. Exp. Dev.
Majors 12 24 11 25 9 21 8 20 10 21
Independents 88 76 89 75 91 79 92 80 90 79
Total 100 100 100 100 100 100 100 100 100 100
Source: Oil and Gas Journal, October 23, 1978.
Arthur P)
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iJSc 2 HYPHENS
^SS. A RED PENCIL DOT *
SPELL OUT COMฐA:\'Y
USE RcD PENCIL
III. UNDERGROUND INJECTION ACTIVITY IN
THE UNITED STATES
A. INTRODUCTION
There are three generic types of hydrocarbon-related
injection activity enhanced oil recovery, disposal
of produced water and hydrocarbon storage (Table III-l)!
I
i
Enhanced oil recovery includes secondary recovery and
tertiary recovery injection processes, even though the
term "enhanced oil recovery" is generally used by the
]petroleum industry to refer only to tertiary recovery
i
j processes.
,-The contribution of secondary recovery processes to
total U.S. oil production is over 50%. The contribution
jof tertiary recovery processes, on the other hand, is
jstill small--approximately 5% of U.S. production. Of ]
\
the total contribution to U.S. production from tertiary)
recovery processes, 90% is attributable to the thermal-
based processes and 10% to the miscible and chemical !
i
processes (Table III-l).
JThis chapter focuses on secondary recovery injection ;
I
activity, the thermal-based tertiary recovery processes!,
"and inj ection for produced water disposal. '
3AGc NUMBER
4-
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TABLE IH-1
PURPOSES AND PROCESSES OF HYDROCARBON-RELATED
SUBSURFACE INJECTION ACTIVITY
I. Enhanced Oil Recovery
A. Secondary Recovery/Pressure Maintenance Methods
1. Water Injection
2. Gas Injection
8. Tertiary Recovery Methods
1. Thermal Recovery Processes
Hot Fluid Injection (Cyclic and continuous steam, hot water, hot gas)
In-Situ Combustion
2. Miscible Recovery Processes
Gas (C02, flue, N2, etc.) injection
Hydrocarbon (LPG, high pressure gas) injection
3. Chemical Recovery Processes
Polymer/Surfactant Injection
Polymer Injection
Alkaline Injection
II. Disposal of Produced Water (including annular injection)
111. Hydrocarbon Storage
A. Crude Oil
B. Natural Gas
C. Liquefied Petroleum Gases
Source: Arthur D. Little, Inc.
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10 PiTCH
173 OR COURIER 12 UOOI-iED
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T'; INCHES 'BORDERS l\DiOATฃOi
uSE '. 1 :. I I ,',OT _ 1 ;j M
-.:HA,\GES, VVMTE OUT OR USE CORRECTING TAPE
JG DASHES USE 2 HYPHENS
3LLLETS USE A RED PENCIL DOT 3ป
AOL: SPELL OUT COMPANY NAVE
ECl-'NG USE RED PENCIL
j The overwhelming majority of enhanced oil recovery welljs
are of the secondary recovery type. The contribution >,
i
and extent of secondary recovery activity in the United)
States is discussed in Section F of this chapter. The
thermal-based tertiary recovery processes are of
particular significance to the state of California and
are discussed in Section G.
j Related to the growth of secondary recovery activity
i
jhas been the growth in produced water disposal. Sub-
i
j
jsurface disposal of increasingly large volumes of
jfluids has resulted from the increase in secondary
recovery activity, natural water drives in many oil
'fields, and restrictions on surface discharge. The
i
'disposal of produced water is discussed in Section H.
;The fluid injection processes associated with secondary!
!
! i
(and tertiary recovery as well as produced water disposail
apply almost entirely to oil fields and not gas fields.;
These activities are best understood in the context of i
jreservoir characteristics and their effect on oil
i
: recovery.
PAGE DUMBER
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B. RESERVOIR CHARACTERISTICS
Accumulations of oil and gas occur in underground for-
mations called reservoirs or "traps." Far from being
pools of liquid, these reservoirs are rock formations
|
that have sufficient porosity to hold the oil and gas j
and yet sufficient permeability to allow the oil and
gas to be transmitted through it. These reservoir rock
formations are generally composed of sands, sandstone,
limestone, or dolomite.
The oil and gas accumulations are contained in these
reservoir rocks as a result of the juxtaposition of
other different geologic formations that seal the reser
voir rock "trapping" within it the oil and gas. These .
"sealing" formations are sometimes called cap rocks ;
and are generally composed of clays and shales which
have much lower porosity and permeability than the
reservoir rock.
i
Oil and gas traps are of various types including anti- ;
clinal traps, dome and plug traps, fault traps, and
traps formed by uncomformities. The majority of U.S.
reservoirs are anticlinal traps as shown in Figure III-
1. The reservoir rock usually contains both oil and
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Gas/Oil Transition Zone
Oil/Water Transition
Source: Modern Petroleum Technology, Fourth Edition.
FIGURE 111-1 EXAMPLE OF AN ANTICLINAL ACCUMULATION OF OIL AND GAS
Arthur D Little In
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gas as well as water. As in Figure III-l, the total !
Igas content sometimes exceeds that which can be held in
f i
iSolution with the oil such that a free gas cap forms in)
ithe upper level of the reservoir rock structure. Under
this gas cap, in the middle level, is oil with gas in
solution. Sealing the reservoir rock is an impermeable
cap rock that traps the oil and gas in the reservoir
i
!
jrock. The lower level of the reservoir in an anticlinal
i
jtrap, is typically connected to water-bearing rock for-
smations called aquifers. Other types of traps may not
ibe connected to aquifers but rather are sealed on all
I
|sides by non-porous sealing formations or they may have
the same oil/gas/water relationships as anticlinal traps,
i
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jbut in different structural or stratigraphic conditions.
i
When oil is produced from an anticlinal trap, there are
several natural sources of reservoir energy that "drive
jthe oil through the pores of the reservoir rock to the
'producing wells. First, when there is a free gas cap,
the gas expands as the pressure falls because of pro-
duction and will displace oil produced from wells lower;
on the anticlinal structure. This energy drive is
called a "gas-cap-drive."
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Second, as oil is produced, the gas that is in solution
Iwith the oil escapes from the oil and expands as the ;
ipressure in the reservoir is reduced. This phenomenon '
is called "dissolved-gas-drive" and is less effective
jthan a "gas-cap-drive" in moving the oil. ,
i
[A third source of reservoir energy is a natural "water-1
^ :drive." Where aquifers are connected to reservoir rocks,
S;the water in the aquifers will move up the structure
i
;as the oil is produced from the reservoir. These ;
'natural energy sources initially have the effect of
maintaining enough primary reservoir pressure to drive ,
fl
ithe oil and/or gas through the reservoir and up the
IB iproducing wells without using artificial lift mechanisms
'These primary energy sources become increasingly less
I -effective over time, however, and the reservoir pressure
declines. The rate of pressure decline depends on the
~ .production rate as well as on many other factors that
f | vary from reservoir to reservoir. It can, in part, be ,
i
jarrested by injecting gas or water or both into the
j
!
ireservoir thereby prolonging "natural" flow.
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One consequence of producing fields with active natural^
water drives or of implementing large scale water injecj-
tion programs is that considerable volumes of water cans
i
be produced with the oil. This water, often high in
salt content, must be (1) reinjected into the producing;
i
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formation, (2) injected into another formation, or (3) }
i
disposed of in some manner which is environmentally andi
economically acceptable. !
C. OIL RECOVERY: PRIMARY, SECONDARY, AND TERTIARY i
PRODUCTION
The primary energy of "gas-cap-drive," "dissoIved-gas-
drive," and "water-drive" in the reservoirs themselves
is far from sufficient to recover all of the original
oil discovered in the reservoir. The extent to which
the original oil in the reservoir can be recovered
through primary production depends on the extent of
these primary energy sources as well as other factors.
Of the three primary energy sources, water-drives are
the most effective. Under highly favorable conditions,,
oil recoveries in water-driven reservoirs have reached
50% of the original oil in place. However, all
reservoirs are not connected to massive water drives,
and on average, only 15-25% of the original oil in
p..l_a_ce can .._be.._r_e..q_Qjyr.g..r_sd_ b..y using only primaryrreae rv.n.i,fc .
energy and artificial lift methods.
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Secondary recovery, i.e., water and/or gas injection,
typically yields another 15-20% of oil originally in
place. On average, the cumulative oil recovery after
primary and secondary methods is about 30-45% of the
original oil, thus leaving 55-70% in place.
While it is technically feasible to recover even more
of the oil remaining after primary and secondary
production, the costs of doing so rise considerably.
The average cost of a barrel of water used in secondary
:recovery injection is 4ฃ. The cost of an equivalent volume
of co used in tertiary recovery injection is
$2.50-$3.50/barrel--a per-barrel increase in cost of
|over 6,000%. Though less CO is used than water for
;any given project, the costs are still significantly
, higher.
As indicated earlier, the current contribution of
-tertiary recovery methods to enhanced oil recovery is
(extremely small. Its eventual contribution depends on \
improvements in technology and raw material availability
(chemicals) and on increases in oil prices that would
provide sufficient economic incentives for oil field
operators to undertake the risks involved.
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TYPE'.",
PAF'-i.J
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ELEMENT 1 73 0ซ COURIER '2 MODIFIED
SPACING- DOU3L5
MARGINS. V-, .NCHES 3CRDERS INDICATED'
JRAPH ENDING L-SS -, 1,1 1 ' 'MOT i. 1 - ' )
CHANGES: WHITE OUT OP USE CORRECT \'G TAPE*
LONG DASHES' USE 2 HYPhEMS 1
3ULLETS: USE A RED =ENCiL DOT ป 1
ADL SPELL OUT COMPANY NAME
EDITING- USE RED PENCIL ,
The potential contribution of tertiary recovery methods
to enhanced oil recovery is considerable, however. It
is estimated by some experts that an additional 20-30%
of the oil remaining in the reservoir after primary and
secondary production can be recovered through tertiary
methods.
D. INJECTION WELL POPULATIONS AND VOLUMES OF FLUID
INJECTED
At the request of Arthur D. Little, Inc., the EPA
Regional Offices distributed a survey to gather information
from officials of state oil and gas regulatory agencies
in June, 1977. The survey solicited, among other things
{injection well population data as of December 31, 1976.
Specific information was requested on the number of
"secondary recovery wells," "disposal wells," and pro-
ducing wells with "annular injection at an oil or gas
production well."
Based on the survey, there were an estimated 127,300
!
I
injection wells in active use at year-end, 1976. Of :
these, about 90,500 were secondary recovery wells,
25,400 were fluid disposal wells, and 11,400 were
producing wells with annular injection. (See Table III-2)
\ -> r* \ s 4 i *v ,1 o c o i
-* u c .N U iVi o t n . ;.
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TABLE 111-2
NUMBER OF OIL AND GAS RELATED INJECTION WELLS BY STATE
AS OF DECEMBER 31,1976
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky1
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Totals
Salt Water
Disposal Wells
13,000
1,570
500
1,300
85
238
6
2,900
800
41
20
61
60
2,500
404
40
541
40
47
1,000
50
198
2
0
0
0
N.R.
2
0
0
0
25,405
Secondary
Recovery
Injection Wells
31,051
745
13,4002
8,700
2,620
3,255
87
10,800
200
326
41
552
757
5,000
333
312
446
71
43
7,000
250
1,500
2,251
190
400
0
N.R.
0
0
150
0
90,480
Producing Wells
with
Annular Injection
11,409
Total
3,000
153
10
0
0
2
0
35
30
0
1
2
0
3,000
115
0
10
1
5,000
0
0
50
0
0
0
0
N.R.
0
0
0
0
47,051
2,468
13,910
10,000
2,705
3,495
93
13,735
1,030
367
62
615
817
10,500
852
352
997
112
5,090
8,000
300
1,748
2,253
190
400
0
N.R.
2
0
150
0
127,294
N.R. - No Response.
1. Kentucky estimated only a single total of 8,000 injection wells. Based on the proportion of SWD and ER
injection wells in nearby Appalachian states, Arthur D. Little, Inc. estimates that approximately 1,000 are
salt water disposal and 7,000 are secondary recovery injection wells.
2. Includes approximately 10,000 cycle and continuous steam injection wells.
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., June 1977.
Arthur H I iff IP
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'APE
In addition to injection well population data, the statje
agencies provided information on their respective 1976
total volumes of fluid injected at secondary recovery \
1 wells, disposal wells, and at producing wells with
annular injection.
Table III-3 presents the state-by-state estimates of
fluid volume as reported to Arthur D. Little, Inc. Of
the 19.9 billion barrels of water injected in 1976,
I
jll.3 billion barrels were injected at secondary recovery
iwells; 8.4 billion barrels at disposal wells; and 0.2
s
(billion barrels at producing wells with annular injection.
;Approximately 60% or 11.1 billion barrels of injected
i
I fluids were injected in only three states--Texas,
I
(California and Kansas.
jA summary of the individual state data on injection
\
jwell populations and total fluid volumes by type of
injection, activity is presented in Table III-4. Dis-
posal wells, which represent only 20% of all the injec-
tion wells, accounted for 42% of the total volume of
fluid injected in 1976. Secondary recovery wells, on
|the other hand, which represent 71% of all injection
i
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jwells, accounted for 57% of the volume of injected fluids.
PAGE NUMBER
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TABLE 111-3
VOLUME OF FLUIDS INJECTED AT OIL AND GAS RELATED INJECTION WELLS
(million barrels/year)
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky1
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Salt Water
Disposal
3,796
716
560
365
99
132
<1
1,241
254
28
22
29
25
730
117
0
162
18
2
39
3
58
<1
3
0
0
N.R.
<1
0
0
0
Secondary
Recovery
3,148
251
1,512
635
493
250
92
840
15
78
95
161
131
384
24
34
43
21
<1
91
36
1,095
1,825
2.0
29
0
N.R.
0
0
<1
0
Annular
Injection
<1
71
0
0
0
0
0
<1
1
0
<1
0
0
110
0
0
0
0
<1
0
0
2
0
<1
0
0
N.R.
0
0
0
0
Total
6,944
1,038
2,072
1,000
592
382
93
2,082
270
106
118
190
156
1,224
141
34
205
39
4
130
39
1,155
1,826
6
29
0
N.R.
<1
0
<1
0
Totals
N.R. No Response.
8,402
11,287
189
19,878
1. Kentucky's data reflecting total fluid volume were broken out by looking at known ratios of neighbor-
ing states.
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., June 1977.
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TAB LEI 11-4
U.S. INJECTION WELL
POPULATION AND INJECTION VOLUMES AS OF DECEMBER 31, 1976
Number of
Wells
90,480
25,405
1 1 ,409
127,294
Percent
71%
20
9
100%
Volume of
Fluid Injected
(MMbbls/yr)
11,287
8,402
189
19,878
Percent
57%
42
1
100%
Average
Volume of
Fluid Injected
Per Well
(Bbl/yr)
124,746
330,722
16,566
156,158
Type of Injection
Secondary Recovery
Fluid Disposal
Annular Injection
Total
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., June 1977.
Arthi irDLittle.il
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PEV/RITER ScTT;\G 10PITCH
ELEMENT 173 OR COURIER 12 MODIFIED
SPACi^iG' DOUBLE
VAR:3i\'3. 1': '\CHtS 3ORDERS'NOICATED!
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CHANGES, WHITs OUT OR USE CORRECTING TAP?
JG DASHES USE 2 HYPHENS
3L-LLSTS USE A RED PENCIL DOT *
AOL SPELL OUT COMPANY NAME
12'"":,'3 USE PSO 3 = >.C!L.
Produced water disposal wells, on the average, receive
jalmost three times as much fluid per well as secondary
recovery wells. Annular injection at producing wells
'accounted for only 1% of the total volume of injected 1
j j
!fluids.
E. REGULATORY ELEMENTS j
j
jThe activities of the oil and gas industry have long j
j
been, although not always, overseen by state regulatory!
i
j
agencies. Injection activity has not been exempted |
i
from regulatory guidelines and enforcement. Since the !
beginning of oil production in this country, several
I
factors have contributed to changes in state regulatory;
policy and industry practice.
Early practices with respect to well completions,
abandonment procedures, and surface discharge of produced
water were undoubtedly careless and are certainly not |
jcondoned today. The growing awareness of environmental)
deterioration caused by the discharge of produced wate:
into surface waters and open pits, the increasing
scarcity of subsurface water in some U.S. regions, and
the relationship of industry practice to the potential
'.detriment of these natural resources have all contributed
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"I-
10 PITCH
173 OR COURIER 12 MODIFIED
3CU3LE
Vi 'NCHES (BORDERS INDICATED)
1JSE .1.11 .'MOT .1 1 -. 1)
ES.
LONG CASHES-
SOL LETS
WHITE OUT OR USE CGRP.eC~ING TAPE
USt2 HYPHENS -- j
USE A RED PENCIL DOT * I
SPELL OUT COMPANY MAME
USE RED ?E\CiL
to the establishment of regulatory agencies and their
increasingly stringent 'policies.
It is widely believed that pollution problems arising to-
s I
day are largely attributable to early industry practice.
For example, the use of open pits--so called "evaporation
pits"--that were used for surface discharge of producedj
i i
isalt water have been known to create pollution problems}
j
30 years after a pit was covered. As the salt slowly
leaches through the ground, it contaminates underground
fresh water sources. The disposal of salt water, eitheir
i
into surface waters or disposal pits has largely been j
prohibited. Where there are exceptions to this, there {
i
is usually either no subsurface fresh water aquifer that
i
j
could possibly be contaminated; or the surface water
that the produced water is disposed into is a brine
lake; or the produced water is of high enough quality
that it can be used for agricultural uses such as
|
jirrigation or livestock watering.
The extent and nature of current state regulatory pro- ,
grams generally reflect each state's specific needs for
the protection of surface and underground water. By
and large, there are underground fresh water aquifers
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TTING 10 PITCH
MENT 173 OR COURIER 12 MODIFIED
OM: DOUBLE
^G.'.'S 1 'i INCHES :aGR3ERS INDICATED-
o.\o LSE :.!:,! {.JOT i. 1 A 1 j
CHANGES: WHITE OUT OR USE CORRECTING TAP
G DASHES. USE 2HVPHENS
BULLETS USE A RED PENCIL DOT ป
ADV.. SPELL OUT COMPANY NA.VE
c^iTiNG USE 3ED Pi=\C!L
I that are closer to the surface than the oil-producing
reservoir. In arid states, these fresh water aquifers
are virtually the only source for drinking water,
irrigation, livestock watering, and industrial use.
In the West and Southwest, there is insufficient rain-
fall to either replenish the underground fresh water
acquifer or provide alternative water supplies. In
i
I these areas, there is a critical need to protect the \
i
acquifers from degradation. In other states, however, j
I
ithere are, and continue to be, vast sources of fresh I
! i
jwater. Louisiana is a case in point. There is abundant
i j
rainfall and underground fresh water is available in many
parts of the state down to a depth of nearly 3000 feet.j
These vast sources of fresh water are in sharp contrast!
i
to the situation in those states where the Ogallala :
aquifer is the primary fresh water source and whose ;
overall thickness is in the 200-300 foot range. The
Ogallala aquifer is also slowly being drawn down by \
domestic, agricultural and industrial use due to the t
I
i
lack of adequate rainfall. j
Each state's climate, geology, surface, and underground!
water conditions have played an important role in the
establishment of individual state regulatory policies
covering oil and gas industry activity.
PAGE NUMBER
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Gouge on Injection tubing
Wellhead
Gauge on tubing-casing annulus
Fresh water zone (^$$
'ttw&^^
Confining layer
:':::::::&:::::::::::::::::::::j injection zone !&:&:':$
Surface casing
Annul us (positive pressure)
Cementing stage collar
Cement
Production casing
Injection tubing
Perforations
Confining layer
Source: Arthur D. Little, Inc.
FIGURE 111-2 INJECTION WELLS
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
.NG 10 PITCH
NT- 173 OR COURIER 12 iWO
ING DOUBLE
.'-Ja 1 . INCHES (BORDERS i'i
CHANGES WHITE OUT OR USE CORRSCT^G TA?
G DASHES: USE 2 HYPHENS
BULLETS USE A RED PENCIL DOT
AOL: SPELL OUT COMPANY NAME
e^'Tc.'MG USE P50 PENCIL
F. SECONDARY RECOVERY INJECTION
1. Historical Perspective |
I
As discussed in Section B on Reservoir Characteristics,!
the primary energy in the reservoir diminishes over i
s
i
time as oil and/or gas are produced. The technology j
to mitigate the effect of this declining reservoir j
pressure has been around since the early 1900's and ;
became economically attractive and fairly widespread '
during the period of the mid-1950's to mid-1960's.
\
t
t
In the early stages of a reservoir's life, it is some- ;
times desirable to inject water or gas to maintain '
pressure. Initially, gas was often the preferred
injection fluid for the purpose of pressure maintenances
because it was readily available, and (prior to the
early 1970's) because of its low cost, its use as a
i
secondary recovery injection fluid also increased. ;
However, in the recent past, the increasing cost of !
gas has reduced its use both for pressure maintenance |
S
and for secondary recovery. i
:The difference between pressure maintenance and secondary
Recovery is more one of timing and intent rather than
^technique. Pressure maintenance projects typically i
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYฐEV.DI ".AT'
CHANGES-
LONG DASHES
BALLETS.
VOL.
WHITE OUT OR L-Sc CO"-
USE 2 HYPHENS
USE A RED PEViCit. DOT
SPELL OUT COMP&NY ',
USE RED PET-iCiL
inject gas early in the oil field's life to maintain
or retard the decline of the reservoir pressure. This
may be followed by water injection (while maintaining
)gas injection) to help further retard pressure decline
and to physically displace the oil toward producing
wells. The results of pressure maintenance and
secondary recovery efforts are reflected in the fact
that only 20% of U.S. crude oil production was achieved
t
through these methods in 1955, whereas today, it is oveir
!
! 50%.
The growth of secondary recovery projects as well as
their attendant contribution to enhanced oil recovery
will be considerably more modest in the future. Approxi-
mately 75% of all reservoirs are conducive to secondary!
recovery techniques (production of some reservoirs <
requires going from primary directly to tertiary methodls)
r
However, it is estimated that the vast majority of thesie
are currently under flood.
2. Secondary Recovery Injection Activity
In actual practice, it is difficult to distinguish
ibetween secondary recovery and pressure maintenance
'injection activities since secondary recovery is often
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173 OR COURIER 12 MODIFIED
DOUBLE
'' INCHES .3OPDEHS INDICATE:
US- '.111 { \O~ _ 1 : " }
CHANGES:
_QNG DASHES-
BULLETS.
&DL
WHITE OUT OR USE
USE 2 HYPHENS
USE A RED PENCIL DOT
SPELL OUT COMPANY \
USE StO PENCIL
RRECTING TAP
begun before oil recovery rates reach the lower limits
experienced when pressure maintenance alone is utilized;.
Secondary recovery, also referred to as waterflooding ,
involves the injection of water into the producing
i
formation or reservoir to force oil to flow toward the i
producing wells. Figure III-2 depicts a typical injectiion
well where the "injection zone" is the producing zone.
The water is injected under pressure which is sufficient
jto drive the oil through the reservoir but not so great;
i
jas to fracture the rock formation. Injected water,
I
jwhich has relatively efficient displacement characteristics,
can raise a reservoir's pressure quickly, typically in
six months to a year.
While waterflooding increases the amount of oil that isi
produced from a. reservoir, it also increases the amount!
of water that is produced. In some of the older !
jsecondary recovery areas, the percentage of produced
I i
jwater has increased to 70-80% of the total volume of j
'.water and oil produced. The oil produced from any
field becomes increasingly more "wet" as the secondary
recovery project proceeds. Depending on the total volume
.of produced water, the water is either reinjected into
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10 PITCH
173 OR COURIER 12 ,ViOD!Ff=D
DOUBLE
r.j INCHES !BO"OERS ;,\Di"AT
USE i 1 l 1 ( -;OT _ : .. 1 }
CHANGES: WHITE OUT OR USE CORRECTING TAPE
LONG DASHES: USE 2 HYPHENS
5uL'_E~S USE A RED PEMCIL OGT *
OL. SPELL. Q'JT COMPANY NJ.VE
;3!T"'MC USE =>EO ?=,\C;L
reservoir and/or disposed of through disposal wells
into non-producing formations.
3. Injection Well Population
In 1976, Texas had over 31,000 secondary recovery
injection wells, over one-third of the U.S. total.
California had approximately 13,500 injection wells of
which about 9,000 were cyclic and continuous steam
wells. Kansas and Oklahoma had respectively 11,000
I and 9,000 secondary recovery injection wells. These
I
four states together had over 70% of the secondary
recovery wells in the U.S.
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ER SETT
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TliiS SHEET TO BE USED FOR SCAMMER COPY OiNILY
Is- ;H. PRODUCED WATER DISPOSAL ACTIVITY
] 1. Historical Perspective
i
'In secondary recovery projects, produced water is
generally reinjected into the reservoir. Sometimes
ithe volume of produced water may exceed that which is
I
s
{required for secondary recovery and disposal wells are
i
jused to dispose of unwanted produced water. In areas J
'where there is little or no secondary recovery activity,
iall produced water must be disposed of by injection j
;through disposal wells. In areas where there are massive
s
[water-drives, there is less need for secondary recovery*
".injection and a far greater need for disposal. This isf
/
i.
^particulary true along the Texas and Louisiana Gulf Coast,
\
\
i i
'While it is not a very widespread practice, some produced
water is disposed of by annular injection at producing
wells. In this type of situation, salt water is disposed
'of through the annulus between the long string and the
.tubing. The disposal zone is shallower than the pro-
I '
iducing zone in this case. The risks of contamination i
|
jare far greater with annular injection because of the
i
greater potential for casing failure. Because of this,,
'most state regulatory agencies discourage annular
injection and permit the practice only when there are
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10 PITCH CHANGES: WHITE OUT OR t_Sc CORRECTING TAP
173 OR COURIER 12 MOOTED '-0\G DASHES. USE 2 HYPHENS
DOUBLE 3UL-ET3 USE A RED PENCIL DOT ป
': NCHcS '3ORDSPS INDICATED! *3'~ SPELL OUT COMPANY \~Vฃ
j5E :. I .i 1 ( r,G~r : 1 \ 1 / --''"" v~ USE RED PENCIL
t very small volumes of water being injected under littls
1
or no pressure. In an effort to phase out this practice,
I many states revoke a well's permit for annular injection
1 i
j )
; when the well is shut in for a workover. This is !
i i
< i
especially true if there is inadequate or no cement j
above the injection/disposal zone. j
1 i
Because produced water is generally high in saline
J <
j content, produced water disposal wells are commonly i
I !
I referred to as salt water disposal wells. There are a I
i !
j few exceptions to this, where the produced water is of,
i !
| a higher quality and usable for some non-potable
| ;
{ purposes.
1 The disposal of salt water is an operating cost of pro-
1
! ducing oil that provides no economic returns (except to
; contract disposal operators) . One way of lowering the .'
i
i
| overall cost of salt water disposal is to select a
i
j disposal formation that will accept the water under
j
vacuum. The best disposal formations are generally ;
j pressure-depleted salt water aquifers or older producing
i
j reservoirs. When water can be injected under vacuum,
the operator does not have the added cost of pumping
1 that would be required if pressure were needed to inject
the water.
;MBER
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETT'NG
ฃL=V)f=,VT
1 73 OP COURIER 12 MODIFIED
DOUBLE
-2 ..NCHES iSQRCERS INDICATED)
CHANGES. VJHiTE OUT OR USE CORRECTING TAPE
LONG DASHES: USE 2 HYPHENS |
3ULL5TS. USE A RED PENCIL OOT J
AOL: SPELL OUT COMPANY N a IV! 5
= ~-iTp;G USE RED 3ENCIU
V
Disposal wells are often converted producing wells and
are most often operated by the leaseholder. If the
lease is large enough, and there are either no producing
i 1
; j
j wells that could be converted to disposal wells or no j
i i
suitable zones available, the leaseholder may contract
out the disposal of the lease's unwanted produced water
j
to a contract disposal operator. In this case, there i
I
are usually gathering lines that collect water from
tank batteries and pipe it to collection terminals ;
where it is chemically treated before disposal. Efforts
are made to construct the water gathering system such '.
that it operates by gravity rather than pressure flow,
thereby again reducing operating costs. ,
2. Salt Water Disposal Well Population
Based on state agencies data, there were approximately.
25,500 salt water disposal wells and 11,500 annular \
injection wells as of December, 1976. Texas had 13,000, swD well
or over 50%, of the U.S. SWD well total. (See Table ' ITT-2 . )
Kansas and Illinois had respectively 2,900 and 2,500
salt water disposal wells. Louisiana and Oklahoma
each had approximately 1,500 salt water disposal wells.'
These five states together accounted for almost 85% of
. .-._ -... _ _ __ - - --- -. -...;.__ !--.._.. .. ..... _. -. - "--.. ' -" ' ' ._ -.--_..-._...'
the total number of salt water disposal wells.
NUMBER
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
VBITERSETTING
ELEMENT
SPACING-
10 PITCH
173 OR COURIER 12 WOO'PI ED
DOUBLE
1'j INCHES (BORDERS INDiCAT
CHANGES. WHITE DLP" OR USE CORRECTING TAP!
3NG DASHES.
3ULLETS
ADL
~~-!~!fiG
USE 2 HYMENS
USE A a = Q PENCIL ~Q
SPELL GO"*" ;OVVi'.Y
USE r=3 ฐE-;C!_
CHAPTER IV
DESIGN AND CONSTRUCTION OF INJECTION PROJECTS
A. INTRODUCTION
This and the following chapter on injection well opera-
tions are designed to provide the information base from
which the incremental cost of compliance will be esti-
mated. This information base is composed of a:
ป statement of current state regulatory requirements
> profile of current injection operations, and
5 summary of current industry practices.
In June 1977, two surveys were distributed by Arthur D.
I
Little, Inc. as a first attempt at developing
i
Ithis data base. The first, mailed under a cover letter
from the Interstate Oil Compact Commission (IOCC) , was
sent to the appropriate state agencies and requested
information on current state regulatory practices
governing oil and gas injection wells. Responses were
received from all 31 of the states. The second survey
was mailed directly by Arthur D. Little, Inc. to the
EPA Regional Offices and requested that each office
respond to questions, with the assistance of individual
AGc NUMBER
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
;ซITER SET
NG 10 PITCH
ฃNT' 173 OR COURIER 12 MODIFIED
GA3. 1 'i INCHES :80RO;HS l
o:.-!G USE _ 1 il ; \.;r
CHANGES: WHITE OUT OR USE CORRECTING TAPE
_ONG DASHES. USE 2 HYPHENS
BULLETS USE A RED PENCIL DOT *
OL, SPSLL GOT COMPANY \AM~
="":'-',^G USE ?ED PENCIL
istate agencies, on the profile of current injection
operations in each state. Data were to include total
number of injection wells, construction profile, level
jof fresh water protected, and estimated number of pro-
ducing and abandoned wells within the, then half-mile,
radius of review. Wherever hard data were not availabl
best estimates were requested from knowledgeable source
within each state. Examples of these two questionnaire
are included in the Appendix.
j
i
'Following extensive analysis of the data supplied from
i
|the two questionnaires, EPA concurred with Arthur D.
Little, Inc. that additional information was needed on
i
current industry practices. Particularly needed was a
better determination of the extent to which existing in-
jdustry practices exceeded the regulatory requirements
1
Jin each state. To obtain these data, Arthur D. Little,
I ;
Inc. conducted in-depth field interviews with injection
well operators, oil field service companies, oil well
drilling contractors, and state regulatory agencies.
Interviews were conducted in October and November of
1978. Over 70 personal field calls were conducted in
all major oil producing regions of the country. Data
summarizing these field calls are included in Table IV-1 .
\ ^
GE NUMBER
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15 oB
CL ws QJ "**"
__ CQ O) C
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2 '5 g ac
ฃฃ 1 ซ
V)
"cu
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Percentage of SW
^j-
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LO
1
cq
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5?
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CM
*
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4-i "o S 0 ~ Z.ง<2
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Ss as gs 2=^"-
.Cio >.Q. oo- 0^2
cocj t-O -JO H5coO
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C8
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cu
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IJ
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w
*-*
cu
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3
o
00
-------
THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
10 PITCH
173 GR COURIER !2
DOU3L5
CHANGES. WHITE OUT OR USE CORRECTING TAPS
-ONG DASHES. USc 2 HYPHENS
3U(_,_ET3' USE A RED PENCIL DC"r 9
ADL SPELL OUT COMPANY %i,\:E
ED,-V!G USE RED 3EMC;>_
The major oil producing areas in the continental United
States are shown in Figure IV-1.
Data in this and subsequent chapters are displayed,
i
wherever possible, by region in order to detail the i
isignificant differences in practices from one part of
i 1
{the country to another. It is primarily these differences
'which make the calculation of an "average" cost of com-s
Ipliance both difficult and meaningless. As shown in
this report, the older, more fully exploited oil fieldsi
!
in the country (such as those in the Illinois Basin and.
j
JAppalachia) have the highest potential cost of compliance
as well as the least economic resource to cover compliance
i
jcost.
I
I
j !
i ;
SB. EXISTING STATE REGULATORY REQUIREMENTS
I 1. Background - i
Regulation of underground injection operations followed!
the same basic guidelines set by regulation of oil pro--
duction. State supervision of oil production developed;
in response to questionable production practices which, in
some cases, damaged the value of rights of adjoining
PAGE i\U,MSeR
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111
Q
LU
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cc
3
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IT
A _^i r-\ i . i i
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETTING-
EL
10 PITCH
173 OR CCLRiE
DOUBLE
r, INCHES so*
'A'HITE OUT OR L-SE CORRECTING
USE 2 -ivDHE;->S
-SE A ^EC PENCIL -C~ *
S'JE;.L. GUT COVP VIY }ฃ.:.=
landholders. Uncontrolled production sometimes
i
burdened the market with a glut of oil, thus depressing!
|
prices. State regulatory programs, usually administereja
}
by an oil and gas commission, brought a certain measures'
of stability to production operations by supervising
drilling practices and establishing production quotas, j
&
both to protect leaseholders and to limit production toj
(maximum sustainable yields.
As injection operations developed in association with
toil production, the state oil and gas agencies assumed
responsibility for regulating the new technologies. ini
eight producing states (Texas,
California, Alaska, Kansas, Pennsylvania, West Virginia!,
JNew York, and Maryland) responsibility for regulating
I
(underground injection operations is -also vested in the state
j
Jenvironmental or health agency. However, for the most
part, regulation of underground injection is clearly
the responsibility of the oil and gas agency.
t
2. Permitting
!
'Oil and gas agencies have extended the permit process
\
jused with exploration and production wells to underground
[injection. A permit for operation of an underground ;
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
CHA,ซ,G33, ,'/H!T= OUT OR USE COFPECTiMG TAPE
3 -A3HE5. USE 2 HYPHENS
(injection well is required in all 31 oil producing
|
jstates. Through this permit mechanism, the states en-
force minimum standards for the design, planning, and
j
construction of injection wells. These state standards!
are summarized in this chapter. State standards for j
monitoring injection wells after they are in operation j
j
and a discussion of the state resources invested in the
permitting and surveillance of underground injection
'
operations are detailed in Chapter V.
'in most states, a permit must be issued prior to drilling
an injection well for secondary recovery or brine dis- !
posal. Most states require that the well be completed
(within a fixed period of time after the issuance of a
j
(permit to drill. The last column in Table IV-2 lists
j
the duration of the drilling permit. In Texas, for
example, the permit to drill is valid for 180 days whil.e
in Louisiana, the drilling must begin within 90 days of:
issuance, but the permit is then valid for the life of '
i
t
the well. i
jonce an injection well is completed within the conditions
(of a permit, a second permit for operation is issued
iand is generally valid for the life of the well. Ex-
-------
TABLE IV-2
EXPIRATION PERIODS FOR INJECTION WELL PERMITS
Permit to Operate
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Enhanced Recovery
None
None1
None
None
None
None
25 Months
1 Year
None
N.R.
N.R.
None
None
1 Year
None
None
None
90 Days1
None
None
None
1 Year
N.R.
N.R.
N.R.
N.R.
None
90 Days1
None
None
None
Salt Water Disposal
None
None1
None
None
None
None
25 Months
1 Year
None
N.R.
N.R.
None
None
1 Year
None
None
None
90 Days1
None
None
None
1 Year
N.R.
N.R.
5 Years
N.R.
None
90 Days1
None
None
None
Permit to Drill
180 Days
None
1 Year
None
90 Days
90 Days
25 Months
None
6 Months
N.R.
180 Days
120 Days
90 Days
1 Year
1 Year
1 Year
90 Days
1 Year
180 Days
1 Year
180 Days
1 Year
1 Year-Shallow Wells
90 Days-Conservation Wells
120 Days
6 Months
90 Days
90 Days
90 Days
None
180 Days
None
N.R. - No Response.
1. Operations must commence within 90 Days; permit then valid for life of the well. One 90-Day extension
may be granted.
Source: Arthur D. Little, Inc./lnterstate Oil Compact Commission, Survey of State Agencies, July 1977.
Arthur D Little, Ii
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
CHANGES -VH1T5 CUT OR USE CORRECTING TAPE
LONG DASHES. USE 2 -'YRNE^S
3U-LSTS uSE A = = C Pc.NCiL OOT *
'captions are Illinois, Indiana, and Kansas, which requiire
I
Ian annual renewal of injection permits.
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! 3. Requirements for Injection Well Operating Permits
I I
The following material on injection well permit requiref-
1 i
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ments reflects state requirements in effect at the time
of the Arthur D. Little, Inc./IOCC survey in June 1977.j
i
State requirements for well design and construction have
j
been increasing over time. Since the date of this survey,
some states (e.g., Kentucky) have proposed or promulgated
i
new regulations in anticipation of a federal underground
i
injection control program. Because of this evolution ;
in state requirements, it is important to note that: ;
The requirements cited here do not govern
all injection wells currently operating;
projects pre-dating the regulation in effect
in June 1977 may have been designed, con-
structed, and permitted under a lower set
of standards. In general, state programs ;
have "grandfathered" the design and con-
struction of existing injection wells when
the new regulations were adopted.
'-GEDUMBER
-------
THIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 -ITCH
173 GR COUR.ER 12 MODIFIED
DCU3L=
1 - INCHES ioORDEPS INDICATED')
' '" 1 ' ' : V.:>r ^ 1 A 1 )
CHANGES,
MC DASHES
BULLETS
WHITE OUT OR USE CORRECTING TAPE
USE 2 HYPHEMS
USE A RED PENCIL DOT <
SP3LL OUT COMPANY NAM =
J3H 3ED PENCIL
o State requirements for new wells will be
more stringent in some states as a result
of regulations enacted since July 1977.
a. Review of Nearby Wells
To provide an indication of the possible implications
of the proposed injection project, states require appli-
cants to review and provide data on the area where in-
jection will occur. This requirement, usually referred
Jto as the "area of review," varies from state to state.
(State regulations specifying the area of review are
jshown in Table IV-3. States usually require the appli-
icant to submit a plat showing nearby wells within a
I
(specified radius. This radius is shown in the left-
hand column of Table IV-3. While a radius of one-half '
jmile is most common, Kansas requires a review only to
the limit of the applicant's lease for enhanced recovery
injection wells while Florida requires an across-the-
board 1.5-mile radius of review.
The effort invested in developing information for a permit
application is determined by the type of information
'required as well as by the radius of the area of reviewi.
i
Table IV-3 summarizes the data which must be shown in
% i~*ป C M 3 ป *
,-Vo Z. .NUiVi
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-------
THIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 PITCH
173 OR COURIER 12 VIODIFIED
DOUBLE
1', INCHES i SOLDERS INDICATED!
CHANGES: WHITE OUT OR USE CORRECTING TAPE
;.NG DASHES. USE 2 HYPHENS
BULLETS' USE A RED PENCIL DOT *
AOL. SPELL GUT COMPANY NAME
SITING 'J3E R2O PENCIL
the required plats. There is no uniformity in state
requirements. The majority of states require the applij-
cant to locate all wells associated with hydrocarbon
production (including abandoned wells) within the area
of review and identify the owner. Not every state which
requires this information requires the applicant to list
the depth of the well shown, the age of the wells, or
any details on the construction, completion, or abandon;-
i
ment. Most states do not require the applicant to identify
J
*
iwater wells within the area of review.
Many parties, such as nearby landowners, adjoining ;
! j
jhydrocarbon producers, farmers or families whose wells I
! i
may be contaminated, and public water supply agencies ,
(drawing from an aquifer penetrated by an injection well!,
j ';
\
ihave an interest in the effect of the proposed injection
operations. To allow these parties to comment on pro-
posed injection projects, some states have incorporated!
a public hearing in the permit review process. Table IV-4
details current requirements in the oil producing states.
For states that allow an administrative review, a permit
[may be approved only by the appropriate agency staff.
jstates which require a hearing are designated in the
jtable. In many states, the director of the oil and gasi
^GE NUMBER
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Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
TABLE IV-4
REVIEW PROCESS FOR PERMIT APPLICATON
Enhanced Recovery Wells
Admin. Review1
*
Admin. Review
Admin. Review
Hearing
Hearing
Admin. Review Following Hearing
Both
Both
Both
Both
Hearing
Either
Admin. Review & Site Visit
Either
Hearing
Hearing
Admin. Review1
*
Hearing
*
None
Hearing
Admin. Review
Both
#
Hearing
N.R.
Admin. Review
Either or Both
Salt Water Disposal Wells
Admin. Review
*
Admin. Review
Admin. Review
Hearing
Either
Admin. Review
Both
Both
Both
Both
Admin. Review
Either
Admin. Review & Site Visit
Either
Admin. Review
Hearing
Admin. Review1
*
Admin. Review2
*
None
Hearing
Admin. Review
Both
*
Hearing
N.R.
Admin. Review
Either or Both
1. Hearing held only if objections are received and deemed valid.
2. Hearing may be required in certain cases.
N.R. - No Response.
* Response to question unclear.
Source: Arthur D, Little, Inc./lnterstate Oil Compact Commission Survey of State Agencies, July 1977.
Arthur D Little, Inc.
-------
THIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 PITCH
!73 OR COURIER 12 MODIFIED
DOUBLE
1'j INCHES (BORDERS INDICATED!
USE il 1 A 1 ( \ ~)T .1 " 1 )
CHANGES: WHITE OUT OR USE CORRECTING TAPE
.ONG DASHES. USE 2 HYPHENS
3ULLET3- USE A RED PENCIL DOT ป
ADL. SPELL OUT COMPANY \|A\5 =
SDi~V.G USE RED PENCIL
jagency has the option of convening a hearing if the j
application is controversial or if additional information
is required. In Ohio, for example, the applicant must
notify adjoining landholders of his application for an
injection permit. A public hearing may be called if an
objection is raised by one or more of the abutters.
b. Construction of New Injection Wells
Most states have specified certain minimum re-
}
quirements for the construction of newly permitted wells.
These construction requirements are summarized in
Table IV-5. Although most states require cemented surface
casing through the fresh water zone, the definition of
fresh water varies so significantly from state to state
that the level of fresh water currently protected by
existing state requirements is undeterminable. The
state definition of fresh water along with the attendant
!regulatory language is detailed in TabJ.e IV-6 . The facrt
jthat most states require cement at the injection zone
PAGE MUMBc,"
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For SWD Annular in
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-------
TABLE IV-6
STATE DEFINITIONS OF FRESHWATER
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Current Definition of
Fresh Water
3,000
1,500
Not Quantified
3,000
Not Available
5,000
Not Defined
5,000 ppm chlorides
10,000
Not Defined
Not Defined
Not Defined
N.R.
5,000
Not Defined
Not Defined
Not Quantified
10,000
Not Quantified
Not Defined
N.R.
Not Defined
Not Defined
No Standards
1,000 or 250 ppm
sodium chloride
Not Defined
N.R.
N.R.
N.R.
Not Defined
N.R.
Applicable Language
"Freshwater zones.".. .waters suitable for irrigation
or domestic purposes.
"Freshwater supplies designated by the state engineer."
"all freshwater and waters of present or probable
value for domestic commercial or stock purposes."
. . .protect waters from preventable pollution
or as approved by the (oil and gas) supervisor
Freshwater
. . .adequate protection of fresh water acquifer
.. .prevent polluting the waters of the state
("5 parts/1,000 TDS")
"Freshwater resources"
"Water"
"not contaminate or pollute, .water, .in the sub-
surface"
"unreasonable damage to underground fresh. . .water
supply"
.. .prevent pollution of freshwater supplies; casing
reqt. to protect all utilized potable water stratum.
Water resources board "may promulgate" standards
for water quality.
Prohibits pollution of "potable freshwater"
All fresh water
'underground fresh water resources"
N.R. No Response.
1. ppm total dissolved solids (TDS) unless otherwise noted.
Source: State requirements as reported to Arthur D. Little, Inc., June 1977.
Arthur D 1 iftlp !m
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TH!S SHEET TO BE USED FOR SCANNER COPY ONLY
*HAi\GcS.
i DASnES.
'.VhlTE OUT OP jSECOrป
USE 2 HYPHENS
USฃ A RED ?E*:C. L. CCT
Sis indicative of the desire to keep injection fluids int
the injection zone. Of particular interest is that these
i
i
requirements apply to both newly drilled and converted i
'injection wells. Finally, a state requirement for the |
1 ]
use of tubing and packer in an injection well is becoming
i
more prevalent although it is not yet required in all
(states .
i
i
c. Mechanical Integrity Testing
Various tests are available to ascertain the water-tight
^integrity of an injection well. Most are aimed at de-
i
itermining if the pipe which forms the well is free of i
I
ileaks. Such a test is usually performed by pressurizing
Ithe well and observing any loss of pressure which might;
;indicate a leak. A number of states have adopted require-
ments for such "pressure tests" prior to the operation
of a new well. Table IV-7 details the state requirements.
JPressure tests provide no assurance that the injection .
fluid will not migrate up along the well bore out of '
i
jthe injection zone. Cementing requirements (either of
ithe surface casing or at the injection zone) are designed
,to prevent this fluid migration. A cement bond log is
the most common means of testing the adequacy of the
UM3E3
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TABLE IV-7
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexicc
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
MECHANICAL INTEGRITY REQUIREMENTS FOR PERMI1
Is a Test of Mechanical Integrity
Presently Required Before Operation?
New
ER
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Some
Yes
No
Yes
No
No
Yes
No
No
No
Yes
No
Yes
No
N.R.
No
No
Wells
SWO
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Some
Yes
No
Yes
Yes
No
Yes
No
No
No
Yes
Yes
Yes
No
N.R.
No
No
Convert
Existing Wells
ER
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Some
Yes
No
Yes
No
No
Yes
No
No
No
No
No
Yes
No
N.R.
No
No
SWD
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Some
Yes
No
Yes
Yes
No
Yes
No
No
No
Yes
Yes
Yes
No
N.R.
No
No
If Yes, Type of Test:
Pressure Test
N.R.
Water shutoff test.
Pressure test may be req'd.
Pressure test witnessed by
state field inspector
Pressure test
Gauge on annulus
Pressure test
None
Pressure test
Setting testing
Cement Bond Casing Integrity
Pressure & Packer
N.A.
N.A.
Pressure test may be ordered
N.R.
N.A.
Pressure test
Pressure test and cement bond log
None
Pressure test
N.A.
N.A.
"well fracturing generally ind.
integrity of casing"
Pressure test
Casing inspection may be req'd.
N.R.
N.A.
N.R.
N.A.
No injection wells currently in
ITING
Does This State Require Injection Through
Tubing Within A Casing With a
Packer Set Immediately Above the
Injection Zone ?
ER
Yes
Yes
Yes2
Yes
Yes
No (95% are)
Yes
Sometimes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
Yes dependent on
areas of state
No
Yes
No
No
Yes
Yes
Yes
N.R.
No
SWD
Yes
No1
Yes2
Yes
Yes
No
Yes
Sometimes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No3
No
Yes
No
No
Yes dependent on
areas of state
No
Yes
Yes
Yes
Yes
Yes can be exempted
by hearing
Yes
N.R.
No
operation
No
No
1. Requires two strings casing cement surface or casing cement plus tubing and packer.
2. Exceptions may occur in some cases.
3. For SWD annular injection (Tubing-Casing) may be allowed temporarily.
N.R. No Response.
N.A. Not Applicable.
Source: Arthur D. Little, Inc./lnterstate Oil Compact Commission Survey of State Agencies, July 1977.
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
CHANGES:
-ONG OASHES,
Jcement seal in the well. A few states indicated that
they required a cement bond log prior to operation of an
injection well, and these requirements are also shown
in Table IV-7.
4. Summary
State requirements for new injection wells are quite :
iextensive. Nevertheless, not every state has required .
[the full use of all technology which might be deemed
the "best available" in the industry. In addition,
istate requirements have evolved over time, and most
jwells operate with a lifetime permit. As a result, not:
I
all existing injection operations meet the current con-'
struction requirements in state regulations.
Most states require operators to submit some information
on nearby wells. Administrative review of this infor-
,mation is supplemented by public hearings in many states.
i
Although these requirements exist, it is important to
recognize that:
Policy on review of nearby wells varies
widely from state to state, and the injection
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
PYPEvVRITES SETTING
PLEMENT
SPACING.
10 PITCH
173 OR COURIER 12 V1CQlFi=D
DOUBLE
1'j I.VGHES ^BORDERS .NO!CATS2!
USE _1 ll ,' 'JOT _ : .1 1 i
CHANGES. WHITE OUT OP USE CORRECT ING TAPE
LONG DASHES: USE 2 HYPHENS
BULLETS: USE A RED 'SNCiL OCT -ป
A0L S3ELL CUT "OMPA.\V N AM E
EDITING US ?ED 3 = NC:_
well operator has had only a limited re-
sponsibility to identify possible channels
of communication between the injection zone
and fresh water zones.
* Many injection operations pre-date current
regulations on the review of nearby wells.
9 Many states do not specifically protect
aquifers by identifying the quantitative
level of fresh water to be protected with
surface casing or other construction
measure s.
C. STATE PROFILE OF INJECTION OPERATIONS '
1. Protection of Fresh Water
Information on the construction practices of existing
injection wells is meaningless unless it can be compared
to the level of groundwater protected by such practices!.
i
As discussed earlier, the definition of fresh water to i
Ibe protected varies significantly from state to state
and therefore makes comparison of practices difficult.
-However, Arthur D. Little, Inc. requested that state
!
iagencies provide estimates on the number of wells
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0 ฐITCH
73 3R CCLRI5R 1? MOO'i=l=G
T= OUT OR USE CO" HE
2 HYPHENS --
^ a = Q 3CMC1L C0~ it
u CU"1" COVPa.^V ., , .' =
PE
idesigned and constructed to protect fresh water at
I
J3,000 ppm total dissolved solids (TDS) and 10,000 ppm
I
JTDS. Generally, lower quality water (higher numerical
ippm TDS) occurs at a lower depth and a requirement to j
protect that lower quality of water would imply more j
i
extensive surface casing and/or cementing. Thus, the [
quality of water to be protected becomes the determining
i
factor for the depth to which cemented surface casing
must be set. Table IV-8 summarizes the state estimates;
on the number of production, injection, and abandoned :
wells which have cemented surface casing at 3,000 ppm
TDS and 10,000 ppm TDS. The data as reported from the
states for disposal and enhanced recovery wells are
detailed in Table IV-9. This question required a judg--
mental assessment of the level of protection implied by5
current and historical state practices and not all states
felt they had sufficient information or experience to
make that assessment. Therefore, data was received
i
from only 21 of the 31 oil producing states. These data,
however, account for over 85% of all producing, injecting,
and abandoned wells.
'Three factors determine a state's response to this
question: (1) the definition of fresh water which has
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TABLE IV-8
CEMENTED SURFACE CASING THROUGH 3,000 AND 10,000 TDS
(December 31,1976)
3,000 TDS 10,000 TDS
Disposal Wells
Secondary Recovery Wells
Injection Well Total
Producing Oil and Gas Wells
Abandoned Wells of Record
Note: Estimates are based on information received from 21 states and account for about 85% of the total well
population.
Source: EPA Regional Office Estimates as reported to Arthur D. Little, Inc., June 1977.
No. of Wells
With Casing
18,229
63,228
81 ,457
330,661
557,860
No. of Wells
Without Casing
5,883
21,952
27,835
216,426
489,966
No. of Wells
With Casing
5,614
24,530
30,144
152,637
257,051
No. of Wells
Without Casing
18,498
60,650
79,148
394,451
790,775
ArthurDLittlelrK
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TABLE IV-9
CEMENTED SURFACE CASING THROUGH 3,000 AND 10,000 TDS
(December 31,1976)
Disposal Wells
Secondary Recovery Wells
3,000 TDS
80
95
50
40
98
100
95
90
100
60
0
25
100
100
N.R.
20
50
100
0
50
100
10,000 TDS
0
30
0-5
40
98
100
90
50
100
40
0
25
90
100
N.R.
20
50
100
0
0
100
State
Texas
Louisiana
California
Oklahoma
New Mexico
Alaska
Kansas
Mississippi
Florida
Illinois
Michigan
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
South Dakota
Missouri
N.R. - No Response.
Note: Data account for 85% of injection wells.
Source: EPA Regional Office estimates reported to Arthur D. Little, Inc., June 1977.
3,000 TDS
100
N.R.
50
40
98
100
97
90
100
65
0
1
100
65
10
25
50
100
25
N.R.
100
10,000 TDS
0
N.R.
0-10
40
98
100
95
50
100
35
0
1
90
65
10
25
50
100
25
N.R.
100
Arthur D Little Inc
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
VRITER SETTING'
ELEMENT-
SPACING
10 PITCH
173 CH COURIER 12 MODIFIED
CHANGES.
_ONG DASHES.
BULLETS.
.VHITS OUT OR USE CORRECT'NG TAPE
USE 2 HYPHENS
U35 A ='ฃD ฐEPJC!L OO~ ป
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historically been used by the state; (2) the current
state requirements for cemented surface casing, and (3)
the length of time current requirements have been in
effect. In Texas, for example, most wells are protected
by cemented surface casing through aquifers with 3,000
ppm TDS, but none are protected to 10,000 ppm TDS. Thi
table must be used with care because states do not mainj-
tain this data in a readily accessible manner. The table
is based solely on the judgment of experienced state j
!
officials. However, it does indicate that some states j
1
(such as Texas) have had a long-standing program to j
require operators to protect underground aquifers at !
i
the 3,000 ppm TDS level. While not perfectly clear,
the data also suggest that about 25% of the injection
i !
Swells would not comply with a 3,000 ppm TDS requirement!
jfor protection of fresh water, and about 75% of injectipn
I
i
Iwells would not comply with a 10,000 ppm TDS requirement.
2. Construction Requirements
The characteristics of injection wells examined during
the survey of state agencies were the presence of
cementing at the injection zone, the presence of tubings
and packer, and the presence of cemented surface casing).
Emphasis was on states' methods of insuring that wells ;
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"H!S SHEET TO BE USED FOR SCANNER COPY ONLY
WHIT5 CUT OR USE CORRECTING TAP
USE 2 HY?h~-NS
USE A 3HD 3~NC!L CC~ -ป
SPELL CUT COMPANY ft-.::
"were designed and maintained in a manner that would prer
j j
jvent fluid leakage either from a hole in the well casing
lor upward along the well bore. Table IV-10 summarizes
ithe data on cementing, casing and the presence of tubinfcf
iand packers in the wells. Injection well operators
1
Igenerally regard the use of tubing and packer as an extra
I '
jmeasure of protection for the outer casing from corrosion.
. 1
These data suggest that about 25% of the injection wells
i
;do not have a tubing and packer. Table IV-11 summarizes
ithe state data as they were reported to Arthur D. Little,
I
Inc .
i
i
According to the survey, only 2,000 injection wells do
not have cementing at the injection zone. All of these
Iwells are located in Illinois and Indiana. ;
ID. CURRENT INDUSTRY PRACTICES
{This section is based on field interviews with industry,
t
joil field service, and state agency personnel. Since a
great deal of the earlier information had been supplied!
through state files and estimates by experienced agency
personnel, it lacks the detail that personal observation
can bring to the data base. Interviews were generally
conducted at the injection site and included a review
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TABLE IV-10
INJECTION WELL COMPLETION PROFILE
(December 31,1976)
Surface
Casing and
Cementing
with Packer
(no. of wells)
18,714
63,748
925
83,387
Surface
Casing and
Cementing
(no. of wells)
5,995
20,821
6,671
33,487
No Surface
Casing,
Cementing
or Packer
(no. of wells)
410
923
715
2,048
Total Number
of Wells
25,119
85,492
8,311
118,922
Salt Water Disposal Wells
Enhanced Recovery
Injection Wells
Annular Injection Wells
Total
Note: Estimates are based on information received from 21 states and account for about 95% of
the injection well population.
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., June 1977.
Arthur n I it-tip Inr
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TING
MENT
CING.
173 OR COURIER 12 MODiFIED
DOLrBLS
r, INCHES (SOPOERS !>%'DiCAT5[
CHANGES,
LONG CASHES.
WHITS OUT OR USE CORRECTING TAPE
USE 2 HYPHENS
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of the operator's files and a tour of the injection
facilities. Although the total number of wells visited
was only a small fraction of the total in operation,
details available from these interviews are valuable
jnot only in and of themselves, but also for gaining in-j
sight into an operator's incentives and decision-making
criteria. The interview program included a cross-section
i
iof companies in all regions of the country in order to :
i
provide representative data. However, there are certainly
some biases which must be taken into consideration. j .
Although the industry people interviewed were helpful
i j
jand had generally "good" injection practices, there re-
i >
imains a question about the practices of those many opera-
i j
jtors who were not interviewed. To compensate for this,
i
joperators were asked about adjoining operations, parti-:
j
'cularly how their practices compared. It was also possible
)
!
ito observe other operations from a distance when passing
jby. While it was not always possible to determine in
i ;
advance who was to be interviewed, the general impression
i
i
is that no one deliberately obscurred information or i
j
showed only exceptionally good injection operations. !
Fields visited accounted for about 10,000 injection
wells or about 8% of the total in existence.
PAGE DUMBER
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THIS SHEET TO BE USED FOfi SCANNER COPY ONLY
From this sample, a profile of casing and cementing-
practices was developed for both new and existing in-
jection projects. Given the limitation of the data,
estimates have been made only to the nearest 5%.
5
I 1. Injection Well Construction Classification
i :
(To facilitate the process of estimating the number of
injection wells potentially in need of remedial action,
all wells were placed into one of five types. The basis
of this classification was the casing and cementing program
'used relative to fresh water aquifers. Figure IV-2 presents
a schematic cross-section of each type. The depth,
irelative position of one type to another, and the location
I
:of the injection zones are of no significant importance:
iin this diagram. The depth of the surface casing and
the amount of cement at the injection zone, fresh water1
jzone, and outside the surface casing is important and
[are the distinguishing features of these well types.
iWell completions may vary from region to region and
|
company to company and have not been included in this :
j
' evaluat ion.
i
!
The well classification scheme is outlined below.A!A!
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till
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rtJ C
S O
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5
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-5 '
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:':': :'
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? ^ r-J -*n ^-V ,ป \ ป , j * j-y ,-v j-ป \ I*"* *, , ป i ?
rC,-< i.ป>A.x;,\s:H CO" f G\L r
Class A -- All water zones fully protected with casing ;
i *
< j
and cementing; injection zone(s) isolated with cement, i
i !
iExample - Surface casing through potable water zones j
j i
Jwith cement circulated to the surface; long string to
]
jtotal well depth cemented back into surface casing. ;
Class B -- All currently used potable water zones fully:
protected with casing and cementing; other fresh water ,
zones protected only with casing; cement used to isolate
injection zone(s). Example - Surface casing through :
potable water zones with cement circulated to surface;
.long string cemented only at the base up to the top of
injection zone.
;Class C All currently used potable water zones and
all other fresh water zones partially protected with
casing or cementing; one or more injection zones not
'isolated with cement (usually where an injection well
penetrates and passes through a second injection zone) .
jExample - Surface casing through potable water zones
with cement isolating lower injection zone; upper in-
jection zone not isolated with cement.
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7H3 SHEET TO 33 USED FOR SCANNER COPY ONLY
Class D -- All water zones protected by casing only; I
i i
jcement only at base of casing string which may not reach
the top of injection zone. Example - Slim hole com-
pletion; single pipe string from surface to injection zone
with cement only at the base of the string.
Class E -- Shallow multiple string well with little or
!
jno cement. Example - Cable tool well with only small
amount of cement at the junction of two strings; no
cement at the injection zone.
As a result of the field interviews with industry, in-
jection wells were broadly divided into each of the
five well classifications. This was done on a regional
basis to detail the significant differences in practices
from one region of the country to another. Well populations
in the eight regions we have defined for this analysis
account for about 93% of existing salt water disposal
wells and about 96% of existing enhanced recovery in-
jection wells. Tables IV-12 through IV-15 detail this ;
!clas sification for new and existing projects by injection
!
;well type (salt water disposal or enhanced recovery in-
jection). Not too surprising, the data suggest that
ithe older oil field areas in Illinois and Appalachia
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TABLE IV-12
INJECTION WELL COMPLETION PROFILE BY REGION
EXISTING SALT WATER DISPOSAL WELLS (DECEMBER 31, 1976)
% of Wells in Each Class
Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
A
10
10
80
85
75
70
15
B
40
70
15
10
20
20
40
45
C
50
20
5
5
5
10
40
40
D E Number o1
6,407
5,411
5,014
5,352
6,469
4,928
5 15 148
509
Total 34,238
Note: Data in this table account for about 93% of the existing salt water disposal
wells.
Source: Arthur D. Little, Inc., estimates, number of wells: EPA Regional Office
estimates as reported to Arthur D. Little, Inc.
Arthur D Little, IIK
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TABLE IV-13
INJECTION WELL COMPLETION PROFILE BY REGION
EXISTING ENHANCED RECOVERY WELLS (DECEMBER 31,1979)
% of Wells in Each Class
Region A B C D E Number of Wells
11,197
10 5,200
27,144
24,046
998
10 1,663
5 15 3,179
13,434
Total 86,861
Note: Data in this table account for about 96% of the existing enhanced recovery
injection wells expected to be operating on December 31, 1979.
Source: Arthur D. Little, Inc., estimates, number of wells: EPA Regional Office
estimates as reported to Arthur D. Little, Inc.
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
10
80
85
75
30
15
40
30
15
10
20
30
40
45
50
60
5
5
5
30
40
40
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TABLE IV-14
INJECTION WELL COMPLETION PROFILE BY REGIONS
NEW SALT WATER DISPOSAL WELLS1
Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
A
20
10
95
95
95
95
5
95
% of Wells
B
60
80
5
5
5
5
95
5
in Each Class
C D E
20
10
Number of
New Wells2
175
147
136
145
176
134
4
14
Total
931
1. New wells refers to newly permitted wells which may be either newly drilled or
converted older wells.
2. Estimated number of wells to be permitted each year, 1980 through 1984, by region.
Note: Data in this table account for about 93% of the expected number of new salt
water disposal wells to be permitted each year.
Source: Arthur D. Little, Inc., estimates.
Arthur D Little, Inc
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TABLE IV-15
INJECTION WELL COMPLETION PROFILE BY REGIONS
NEW SECONDARY RECOVERY WELLS1
% of Wells in Each Class Number of New
Wells2
495
230
1,197
1,060
45
73
140
592
Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
A
20
10
95
90
90
75
30
B
60
60
5
10
10
15
60
70
C
20
20
5
30
0
5
5
E
5
10
Total 3,832
1. New wells refers to newly permitted wells which may be newly drilled or
converted older wells.
2. Estimated number of new wells to be permitted each year, 1980 through 1984,
by region.
Note: Data in this table account for about 96% of the expected number of new
enhanced recovery injection wells to be permitted each year.
Source: Arthur D. Little, Inc., estimates.
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account for the majority of existing Class C injection i
jwells. Since many new injection wells are actually conj-
. i
iverted older producing wells, even new injection projects
j |
;in these parts of the country have a significant per-
jcentage of Class C wells. j
1 i
i i
jThe distribution of well types in the Rocky Mountain '
1 ;
|area is somewhat unusual and is accounted for primarily
iby its geology. Because of the solid rock formations
i
Rencountered when drilling new wells, significant amounts
i
of cement were not required to insure a good production
jcasing. Additionally, there are a large number of cable
'tool wells still in active use, both for production and
'injection. Although many of the cable tool wells have
1
i
jbeen modified to insure adequate containment of the
'injection fluids, there are many which, according to
i
'industry sources, are potentially leaking.
jFinally, the injection fluid is not so brackish as to
!pose a significant threat to groundwater supplies. In
fact, ranchers in the area have tried to prevent injection
of formation fluids in order to force oil companies to
release that fluid into surface streams for irrigation
and livestock waterina. '.
-------
,East Texas and California also have substantial percen-j
I '
:tages of Class C wells as a result of significant or ซ
Suncontrolled development of oil resources in the early ,
oil days. The East Texas oil field and the Signal Hill
unit in California, are examples of this uncontrolled {
oil field development. !
Table IV-16 details the ratio of converted injection
i
{wells to newly drilled injection wells for both existing
i
j
and new projects. This table suggests that most newly ;
drilled wells are for production while injection wells
(are mostly old producing wells that are either strate-
gically located for injection or are simply not paying
,out in terms of production.
j 2. Summary
Injection well construction practices vary significantly
from one region of the country to another based both on
that region's specific needs as well as on the age and
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TABLE IV-16
CONVERTED AND NEWLY DRILLED INJECTION WELLS BY REGION1
Existing Projects New Projects
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
Converted
90
90
80
75
60
70
85
75
Drilled New
10
10
20
25
40
30
15
25
Converted
85
80
65
50
30
60
75
60
Drilled New
15
20
35
50
70
40
25
40
1. Table includes data on both enhanced recovery injection wells and salt water
disposal wells.
Source: Arthur D. Little, Inc., estimates.
Arthur D Little Inc
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'HIS SHEET TO 8E USED FOR SCAlXsNER COฐY ONLY
'state of oil field development. While newer oil fields!
1
:in parts of the country with scarce groundwater supplies
jhave taken an active role in the protection of those
iresources, older fields in parts of the country with
jpresently adequate surface water supplies have not been
subjected to such strict requirements.
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V. INJECTION WELL OPERATING DATA
I
' I
:A. OVERVIEW :
.Operators of injection wells typically monitor their
Iwell operations by observing selected performance data.;
This chapter describes current operator practices and
i
i
'existing state requirements for the 'collection and
'reporting of injection well operating data.
|B. MONITORING PRACTICES
O -This section briefly describes the overall monitoring
^ process and the types of monitoring activities that are1
M i
:commonly practiced.
tl . Performance of Monitoring Operations
i
Monitoring of injection well operations typically
'involves the reading of various gauges at the wellhead,
''visual observation of operation of associated surface
^ .equipment, and the noting of audible noises and sounds
.associated with operation of injection well equipment.
Field monitoring involves traveling from well
ง'
, to well and field to field.
Typically, monitoring of injection wells; is performed
by the pumper, an operating level oil field employee, who
V-/
-------
JE USED FOR 3CA>;ri L3 COPY O^LY
' is often responsible for overseeing the integrated
! 5
1 operations of several types of equipment, including '
; producing wells, injection wells, pumping units, and
tank batteries, as well as several miles of connecting
i piping.
i i
i '
,
. Ongoing monitoring tends to be performed in a "trouble-
i
shooting" mode. Pumpers, who are usually experienced
in the operating and maintenance of field equipment,
drive through the oil fields looking for indications ;
that something may be out of order or about to go out
i of order. Their principal job is to keep their assigned
equipment functioning and to be on the lookout for
irregularities.
When irregularities are discovered, pumpers investigate
, the probable causes and report on the situation to
their supervisor, the lease foreman. Minor repairs or
' corrective adjustments are often accomplished by the
j pumper; however, routine maintenance and major repairs
are not typically performed by the pumper.
Often a monitoring visit only involves a pumper driving
by an injection well, pausing briefly to look for
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^ symptoms that something may be wrong. Companies establish
i
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ings of injection well performance data must be checked
B and the frequency that it is recorded. It is not un-
I common for operators of injection wells to require
งi I
|pumpers to visit or drive by injection wells on an even
'more frequent basis.
^ Monitoring tends to be accomplished daily with a "relief
.pumper" assigned on weekends. Weekend monitoring may
be less involved than weekday monitoring due to both
3 fewer personnel and reduced on-site supervision. A
limited number of operators interviewed reported that
they utilized a "night pumper" who roamed the fields
during the hours of darkness. However, it appears that
I
^ "night pumpers" are principally used as a security
measure to deter vandals rather than to monitor field
operations.
2. Types of Monitoring
The principal means of surveillance of injection well
operations at present is monitoring at the wellhead of
the volume of injected fluids and injection pressure.
The principal purposes of monitoring the volume of
injected fluids is to allow for estimates of the
-------
7HS SHEET TO 8E !jSซED FOP. SCANNER COPY ONLY
I distance of fluid travel, to allow for the interpreta-
j
j tion of pressure data, and to provide a permanent
}
! record of the volume of emplaced fluid. Also, a
j record is frequently needed as evidence of compliance
!
with restrictions, as well as for interpretation of
well behavior.
Injection pressure is monitored to provide a record
! of reservoir performance and as evidence of compliance
i with regulatory restrictions. Injection pressures are ;
. often limited by state permit to prevent hydraulic
; fracturing of the injection reservoir in confining
; beds and/or damage to well facilities. Injection
; pressures are typically read visually from a gauge
that is either permanently attached to the wellhead
or inserted into a quick-connecting fitting. A limited
number of injection wells are fitted with continuous
: recording devices for injection pressure.
Annular pressure (pressure between the casing and tub-
j
ing) can be monitored to detect any changes that might
indicate leakage through the injection tubing or the
tubing- casing packer. However, annular pressure of
injection wells is not commonly monitored on a routine,
recurring basis.
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T"ri!S 3htฃT TO 3ฃ USED rOR SCANNER COPY ONLY
Analyses of injection fluids are not commonly performed
! _ i
- on a routine recurring basis by operators of injection '
iwells after an injection operation has been started and
f
]once compatability of the injection fluid with the injec-
jtion zone fluid has been established. At present, analysis
i *
I
jof injection fluids tends to be accomplished only on a .
!situational basis when there is reason to suspect problems
due to the characteristics of the injection fluid. In
! such situations, the scope and extent of the analysis
,may range from simple monitoring of pH to more elaborate
chemical analyses, depending on the particular problem
that is suspected. However, most injection fluids are
not regularly analyzed.
'C. COLLECTION AND REPORTING
Although most injection wells receive a lifetime permit,
state agencies maintain some control over compliance wi.th
permit conditions by requiring the reporting data on
injection operations. These requirements usually call
for the submission to the state agency of periodic repoirts
of basic monitoring data on injection volume and pressure.
Data are reported which are observed by the pumper or
other staff in the oil field. Some states require that
these data be supplemented with results of periodic tes.ta
for mechanical integrity, fluid migration, or chemical
analysis of the injection fluid.
\/-5
-------
T'J:S SHEET TO 85 USED =CP SCANNER COPY ONLY
Table V-l summarizes state requirements on the collec--
I
: tion and reporting of data on injection operation. :
! State requirements are broken out by type of well so '
' that differences between salt water disposal wells and
i enhanced recovery wells can be observed. Frequencies
i '
i with which such operating data must be submitted to the
j state are also shown. Some major producing states, :
such as Texas and Louisiana, require submission of
' monitoring data only on an annual or even less frequent
basis.
1. Collection of Monitoring Data
Data collected from field interviews with production
superintendents, foremen, pumpers, and other oil field
personnel by Arthur D. Little, Inc., staff indicated
that operators frequently collected monitoring data
more often than required by the state. Table V-2
summarizes by geographic region the monitoring data
collection habits of salt water disposal operators.
It can be noted that while volume and pressure data
j
i are typically collected at least weekly, only a limited
; number of operators collected annular pressure data at
. equivalent frequencies.
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-------
TABLE V-2
SALTWATER DISPOSAL WELLS
CURRENT MONITORING PRACTICES
Geographic Region
Illinois Basin
Appal achia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
Remainder of U.S.
Total2
Percent of Weils with Operators Performing
Weekly or More Frequent Monitoring1 of:
of Wells
6,855
5,789
5,365
5,726
6,921
5,273
158
545
2,723
95
80
95
95
95
95
90
85
Volume
95
80
95
95
95
95
90
85
Pressure
95
80
95
95
95
95
90
85
Annular Pressure
20
10
10
33
50
20
10
15
36,632
1. Reading a gauge and logging the results.
2. Data in this table account for approximately 93% of all SWD wells.
Source: Arthur D. Little, Inc., estimates.
Arthur D Little, Inc
-------
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. Table V-3 displays similar data for enhanced recovery
; injection wells. It should be noted that enhanced ;
1i i
; recovery monitoring is measured against monthly or .
more frequent monitoring, while salt water disposal
w monitoring was compared to weekly monitoring. In each
tease, the benchmark was chosen to reflect the require-1
I
ments of the proposed UIC program. :
I
_ Field interviews and observations indicate that many
** injection well operators visually observe monitoring
9 data more frequently than they record it for their own
internal record-keeping purposes. Estimates contained
in this chapter, however, are based only on monitoring
^ practices that include both the observation of operat-
^ ing data and the recording of such data in an internal
M record-keeping system.
2. Reporting of Monitoring Data
Field interviews confirmed that operators typically do
ฃ not report additional data in excess of minimum state
j requirements, nor more frequently than required by
state programs. Accordingly, existing state regulatory
programs can provide an accurate basis for developing
profiles of operators' current reporting practices.
-------
TABLEV-3
ENHANCED RECOVERY INJECTION WELLS
CURRENT MONITORING PRACTICES
Percent of Wells with Operators Performing
Geographic Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
Remainder of U.S.
Total2
ivumuer
of Wells
12,387
5,752
30,027
26,600
1,104
1,840
3,517
14,861
4,227
96,088
Volume
98
98
95
98
98
98
90
95
Pressure
98
98
95
98
98
98
90
95
Annular Pressure
20
10
10
33
20
20
10
10
1. Reading a guage and logging the results.
2. Data in this table account for 96% of all ER injection wells.
Source: Arthur D. Little, Inc., estimates.
Arthur D Little, Inc
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'3 SHEET 73 ^c LGzD -~CS SCAM.NEn COPY O^LY
I
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, . .
When comparing and tabulating the reporting require-
w ' ments of the various state programs, one is faced with
, wide variety of specific requirements, provisions and
I ; regulatory language that make it quite difficult to
summarize state requirements in comparable terms. A
categorization scheme was developed to enable compari-
ฃ son of the combined requirements of 28 of the oil and gas
producing states with provisions of the proposed UIC
t regulations. As shown in Table V-4, certain benchmarks
, were established for reporting requirements for both
JB salt water disposal wells and enhanced recovery wells.
, These benchmarks were developed to reflect the EPA's
thinking on the various reporting requirement alter-
I natives. For example, the salt water disposal well
reporting requirement categorization scheme reflects
five categories ranging from no recurring reports
1ft (Category A), to quarterly or more frequent reporting
of weekly operating data (Category E). A similar
categorization scheme was developed for enhanced
; recovery injection wells. However, the enhanced
recovery categorization scheme contained one major
V modification from the salt water disposal categories.
Category E for enhanced recovery wells was modified to
reflect the EPA's thinking that this class of injection
-------
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wells would need monthly rather than weekly operating
data .
Table V-5 profiles the current reporting practices for
salt water disposal wells. It has been developed on
the basis of the categorization scheme discussed above;
and the existing state regulatory requirements as
! reported in a July 1977 joint Arthur D. Little, Inc./
] Interstate Oil Compact Commission survey of state
: agencies. As indicated in the table, while only 7 of
l
the 28 states indicated that they did not require any
routine recurring reporting of salt water disposal
operations, those states comprise 62% of all salt
water disposal wells in the country. Combining
Categories A and B, it can be noted that 91% of all
salt water disposal wells report operating data to the
, respective state agency on an annual or less frequent
basis, if at all.
Table V-6 displays similar data for enhanced recovery
wells. A significantly higher percentage of enhanced
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5E Li,;ED FOR
recovery wells report data on some recurring basis
than do salt water disposal wells. For example, only
18% of all enhanced recovery wells are in Category A
(no recurring reports) as compared to 62% of all salt
water disposal wells. Nevertheless, there are far
more enhanced recovery wells in operation than salt
water disposal wells and, therefore, Category A
enhanced recovery wells will comprise a sizeable number.
D. SURVEILLANCE BY STATE AGENCIES
Reporting of monitoring data (pressure and volume) gives
state agencies some opportunity to determine if an
operator is complying with the volume and injection
restrictions in his permit. States do not rely solely
on these reports to supervise injection operation. All
the producing states replying to the Arthur D. Little,
Inc. survey in July 1977 indicated that they maintained
a field inspection program based upon random visits to
well sites. Many of these inspections were made for
the primary purpose of reviewing production operations,
but they do allow state inspectors an opportunity to
identify major problems or verify monitoring data
reported by the permittee. In addition, state
agencies respond to complaints of surface or underground
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
contamination allegedly caused by oil production or
; injection, and this gives further opportunity for
review of injection operations. Table V-7 provides a
summary of the number of complaints and problems
handled in 1976 by state agencies responsible for
i
! >
I underground injection control activities.
Table V-8 shows how state agencies allocate their
resources to permitting of new injection operations
and surveillance of existing projects. The total
state budget for fiscal year 1977 is shown, along with
the percentages (and $ amounts) allocated to permitting
and surveillance of injection operations. The sum of
the two percentages is substantially less than 100%,
with the rest of the budget (usually a majority) going
to the permitting and surveillance of oil and gas
production. Note that the effort a state puts into
field surveillance of injection operations usually
exceeds the effort expended in permitting new injec-
|
! tion welIs.
The comparison of permitting and surveillance efforts
by state agencies is carried further in Table V-9.
This table uses the well population data to determine
_V=1!
-------
TABLE V-7
NUMBER OF COMPLAINTS AND PROBLEMS RELATED TO POLLUTION OR
CONTAMINATION OF GROUND WATER
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Total Complaints
and Problems
18
N.A.
646
0
223
0
46
715
N.R.
0
10
0
422
6
0
10
34
25
0
'Very few"
N.R.
13
32
10
0
0
0
25
Oil and Gas
Production Wells
12
N.A.
0
133
0
5
550
N.R.
0
0
244
N.A.
0
0
0
0
'Very few"
36
12
18
10
0
0
0
25
ER
Injection Wells
0
N.A.
0
65
0
17
15
N.R.
0
0
111
N.A.
0
0
0
0
"Very few'
N.R.
0
14
0
0
0
0
0
SWD Wells
6
2
0
25
0
24
150
N.R.
0
0
67
N.A.
0
0
0
0
'Very few"
N.R.
0
0
0
0
0
0
0
N.A. - Not Available.
N.R. - No Response.
Source: Arthur D. Little, Inc./lnterstate Oil Compact Commission Survey of State Agencies, July 1977.
Arthur D Little, Inc
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State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
W. Virginia
Missouri
N.R. -No
Source: State
were
STATE
Total No. of
Injection
Wells
47,051
2,270
13,477
10,000
N.R
3,495
93
13,735
1,030
367
62
615
71
10,500
852
352
460
112
5,090
8,000
300
1,748
2,253
52
150
Response.
TABLE V-9
AGENCIES COSTS FOR PERMITTING AND SURVEILLANCE
Permits Issued Total Cost of
for New
Injection Wells
1,257
146
319
464
N.R.
N.R.
11
312
63
N.R.
3
6
0
465
59
21
45
5
25
41
10
80
59
16
48
Permitting
New Wells
$695,303
182,826
199,750
121,464
N.R.
9,048
5,770
206,260
9,626
N.R.
9,161
7,590
24,055
18,750
N.R.
25,873
3,756
33,518
28,075
20,400
1,401
22,489
N.R.
94,620
N.R.
agencies as reported to Arthur D. Little, Inc., July 1977.
asked to estimate the percentage of effort on permits and
Cost/Permit
$ 553.14
1,252.00
626.00
262.00
N.R.
N.R.
525.00
661.00
153.00
N.R.
3,054.00
1,265.00
N.R.
40.32
N.R.
1,232.00
83.47
6,704.00
1,123.00
498.00
140.00
281.00
N.R.
5,914.00
N.R.
Costs are from
surveillance.
Total Cost of
Surveillance
$1,042,955
182,826
171,214
121,464
N.R.
15,000
2,784
132,596
96,258
N.R.
18,322
37,950
36,033
37,500
N.R.
25,873
22,538
100,554
28,075
20,400
7,004
22,490
N.R.
94,620
N.R.
fiscal year 1977 budget.
Cost/Well for
Surveillance
$ 22.17
80.54
12.70
12.15
N.R.
4.31
29.94
9.66
93.45
N.R.
296.00
61.70
508.00
3.57
N.R.
73.50
49.00
897.80
5.52
2.55
23.35
12.87
N.R.
1,819.00
N.R.
State officials
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the costs of surveillance for each existing injection
well and the cost for each new injection permit.
Several states spend over $1,000 reviewing each new
injection permit. A very wide range is shown for
field surveillance expenditures. In Louisiana, the <
cost per well would suggest the feasibility of an '
i annual inspection, while inspections of such frequency
appear unlikely in Kansas and New Mexico.
, E. CONCLUSION
- A comparison of state requirements with current
practices in the oil field shows that injection well
; operators are generally collecting volume and pressure
data more frequently than required. Standard practice
for well monitoring exceeds state requirements.
All states maintain a field inspection program. This
field program usually takes more than half of the
resources which the states devotes to the regulation
I
| of underground injection, but staff limitations prevent
many states from annual inspection of existing wells.
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CHAPTER VI
| PROPOSED UNDERGROUND INJECTION CONTROL PROGRAM
1
!
!A. OVERVIEW I
I I
JHaving previously described current industry practice^
!
'and state regulatory requirements in Chapters II through
i t
|V, the proposed UIC regulations are discussed in this
jchapter. Then in Chapter VII the methodology for com- \
jputing the incremental cost of complying with these !
Regulations is detailed while in Chapters VIII through :
'XIII the actual cost analysis is presented for each of
i :
!the regulatory elements. :
jThe regulatory elements used in this analysis are a hybrid
j
!of the purely "functional" elements used in preparing |
!
jthe regulations and the "product" elements used by in- i
i :
jdustry in analyzing cost impact. These elements are:
i j Area of Review,
j Existing Injection Wells: Testing and .
Remedial Action,
3 New Injection Wells: Incremental Action,
9 Permitting,
9 Collecting and Reporting Monitoring Data, and
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! 73 CR CCURi-3 '2 MCD'.F
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1'., INCHES 'BORDERS NDi
use j.1^1 ( -io- _ ',.
'_c
ป State Agency Costs.
A matrix showing the relationship of these six element^
to the specific subsections in the regulations is detailed
I
in Table VI-1. !
Following a discussion on the statutory framework pre- j
ceding the UIC regulations, a detailed analysis of the '
regulations is presented along with Arthur D. Little,
Inc.'s interpretation of their application to the oil
and gas industry. This interpretation, together with ;
ithe well population estimates and assumptions presented
j !
(Chapter VII, provide the basis for preparing the incre-'
i '
\
jmental costs of compliance.
B. STATUTORY FRAMEWORK
1. The Safe Drinking Water Act
Increasing concern about the contamination of public
drinking water sources led to the passage, late in 1974,
jof the Safe Drinking Water Act (SDWA). Prior to passage
I
of the Act, the federal government had exercised no direct
control over local drinking water supplies; however, it!
was involved in testing and regulating water supplies
for interstate carriers.
/I-
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In considering the SDWA, Congress determined that ex-
isting federal authority to protect drinking water supplies
was inadequate. Pollution controls under the Federal
;Water Pollution Control Act (FWPCA) applied only to j
: 1
navigable waters, thus excluding some underground aquiffers
'which form major drinking water sources. The definition
i j
;of pollutants subject to federal control in the water ;
{pollution law was found to be too restrictive to prevent
s
Contamination of drinking water supplies.
iThe SDWA focuses on the creation of a system to monitor
'and control maximum allowable levels of contaminants in
Ipublic drinking water supplies. The act creates a system
jto specify and enforce standards for public water
i
'supplies -- defined as those serving fifteen connections
i
;or twenty-five individuals.
; 2. Controlling Underground Injection
!To protect underground reserves of water which currently
are, or may become, sources of drinking water,
Congress required the creation of an underground injection
control (UIC) program. The House report notes that the
program is needed, in part, because federal programs
for the control of air and surface water pollution have:
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(led to an increase in underground disposal of pollutants.
This finding parallels field observations in the oil j
and gas industry where disposal of oil field brines in )
!
unlined surface pits and by discharge into surface streiams
has been replaced by deep well injection. EPA admini- j
strator Russell Train asked Congress to defer action
on a UIC program to await the implementation of 1972
i
j amendments to the FWPCA which gave EPA some control ovesr
underground injections ancillary to control of surface .
pollution. Congress rejected the delay. '<
\
I
\
\
\The UIC program established by the SDWA recognized the
I existence of state programs for injection control, and
[placed priority on the use of state enforcement agencies.
i
|EPA was required to identify states which needed a UIC
]
Iprogram. Standards for state programs were to be pub-
i
i
jlished in draft form by July 1975. Following final
i -;
'promulgation of these regulations, states were allowed
|a maximum of 540 days to establish a UIC program meeting
the requirements. If the state failed to develop the i
|required regulatory program, EPA would be required to
j
promulgate and enforce a program regulating
I ;
! ;
underground injection. It was originally anticipated
f .
that states would have federally approved UIC programs
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in place by December 1977,
The state UIC programs are required to prevent under-
ground injection which endangers drinking water sources!.
jEndangerment occurs, according to the statute, where
i
"injection may result in the presence in underground
water which supplies or can reasonably be expected to
I supply any public water system of any contaminant, and
i
lif the presence of such contaminant may result in such
]
isystems not complying with any national primary drinking
j
iwater regulation or may adversely affect the health of ;
i i
Ipersons." The operator of an injection well must satisfy
|the state that the well will not "endanger" drinking water
i
i t
| sources in order to receive a permit. States must de-
[ ;
velop requirements for inspecting, monitoring, record-
j
jkeeping, and reporting as part of the permit program. ;
! The House report supplements this language, indicating
that the program is designed to protect underground
drinking water sources from any contaminant, whether or
i
jnot such contaminant is subject to the primary drinking
I !
water regulations. Well operators are expected to
} j
!employ the "best available" techniques for design, siting,
1
42 USCA '300h (d) (2)
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CHANGES:
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3ULLETS.
ADL.
EDITING.
SPELL OUT COMPANY MAMS
| construction, operation, maintenance, and abandonment
jof injection wells.
3. Applicability to the Oil and Gas Industry
Applicability of the UIC program to the oil and gas
industry was a subject of substantial debate during
Congressional consideration of the SDWA. Industry ad-
i
jvocates argued for an exclusion such as that contained
in Section 502(b)G of the FWPCA which states that the
definition of a pollutant does not include "water...or
other material injected to facilitate production of oil
or natural gas, or water derived in association with
oil and gas production and disposed of in a well" if
the state regulates such injection and finds that degrai
i
jdation of underground waters will not occur. Congress
i
(rejected this exemption.
iInstead, the law states that the implementing regulations
i
may not prescribe requirements which interfere with or
i
impede the underground injection of brine for disposal I
or enhanced recovery unless such requirements are essential
to assure that underground sources of drinking water
will not be endangered. The law further requires that
the UIC program provide for consideration of varying
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" " pC
geologic, hydrologic, or historic conditions in different
i
states or in different areas within a state. To the j
i
! extent possible, the new federal UIC program is to avoiid
i 1
!requirements which would unnecessarily disrupt state 1
j
UIC programs. The statute states that a federal requirje-
ment will "disrupt" a state program only if it would ba
| s
jinfeasible to comply with both state and federal requirte-
i j
jments. An "unnecessary" disruption would occur, according
I
to the statute, if underground water sources will not
Ibe endangered in the absence of the federal regulation.
However, $$b(3) (c) states that
> i
nothing shall be construed to alter or affect the duty
to assure that underground sources of drinking water
will not be endangered by any underground injection.
It seems clear from the statutory language that Congresfs
was giving some special status to the oil and gas in-
jdustry, while recognizing the long history of state
regulation of oil and gas production, including state
control of underground injection. Rejection of the
j
(Statutory exclusion also makes it clear that Congress
i wanted some minimum federal standards to protect under-t
i
! .
ground water from contamination by oil and gas operators
PAGE MU-V1BEF?
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I1. INCHES 309CS-S
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1": INCHES iBORGcHS INDICATED)
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C. INTERPRETATION OF THE UIC REGULATIONS I
i i
i !
f 1 . Introduction j
!
JEPA received extensive comment from the oil and gas in-]
I
dustry as well as state regulatory agencies on the regu-
lations initially proposed in 1976. Substantial modifi-
cations have been made to reflect many of these comments,
as well as to reflect additional data obtained by EPA
and Arthur D. Little, Inc. in the course of this study.
j
Revisions to the draft regulations have been so extensive
that revised regulations have been re-proposed on :
!
*
April 20, 1979. Interpretation of these proposed regula-
tions as they apply to the oil and gas industry, together
with the relevant textual portions, are included herein;
to provide the reader with a clear understanding of the]
basis for preparing the cost analysis. ;
2. Subpart A -- General Provisions
146.04 Underground Sources of Drinking ;
Water j
i
The Director, by regulation and subject ,
to the approval of the Administrator, shall
designate as underground sources of drinking
water in the State, after public hearing,
all aquifers or parts thereof currently
ฐAGE NLMBER
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serving as a source of drinking water or
which contain water with fewer than 10,000
milligrams per liter of total dissolved
solids, except that the Director need not
designate an aquifer or part thereof with
fewer than 10,000 milligrams per liter of
total dissolved solids if the aquifer or
part thereof :
(a) does not currently serve as a
source of drinking water; and
(b) cannot now and will not in the
future serve as a source of drinking water
because:
(1) it is mineral, oil, or geo-
thermal energy producing;
(2} it is situated at a depth
or location which makes recovery of water
for drinking water purposes economically
or technologically impractical; or
(3) it is so contaminated that
it would be economically or technologically
impractical to render the water fit for human
consump ti on.
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The impact of this requirement falls mainly on state \
agencies. While early drafts of the regulation clearly!
required states to perform detailed mapping of all undeปr-
jground aquifers, the language has been revised to allow* more
j ;
flexibility. States will be allowed to designate potenjtial
i
!
I drinking water sources through the use of narrative staite-
j
ments in geographic and/or geometric terms. However, as more
i
i rigorous analysis will be required to determine those aireas
|of the state which are to be exempted from designation.,
While this is the interpretation used in the preparation of
!
1 this cost analysis, it is possible that states will undertake
I
I
ia detailed aquifer mapping study. In this case, the coists
to state agencies will be substantially greater than th:ose
i estimated.
! This interpretation, as used in the cost analysis, clos;ely
^parallels current state practices for designating under:-
;ground aquifers to be protected from injection.
-146.06 Area of Review
(a) The Director shall, by regulation
or rule, select the methods by which the
area of review shall be established for
each injection well or each field, pro-
ject or area of the State.
(b) The area of review may be de-
fined as either:
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(1) the zone of endangering
influence as determined in accordance
with subsection (c) of this Section; or
(2) an area within a fixed
radius around each injection well as de-
termined in accordance with subsection
(d) of this Section.
(c) The zone of endangering in-
fluence shall be that area the radius of
which is the lateral distance from an in-
jection well or injection well pattern
in which the pressure change resulting
from the injection operation may cause
the migration of the injection and/or
formation fluid into an underground
source of drinking water. .
(d) A fixed radius around the
well of not less than 1/4 mile may be
used. In determing the fixed radius,
the following factors shall be taken
into consideration: (1) the toxicity
of the injected fluids; and (2) the
geology, hydrology, population, ground
water use, and historical practices in
the area.
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jIn some parts of the country, it would benefit an opera-
jtor to demonstrate that the zone of endangering influence
l
is less than, a fixed radius of one-quarter mile. How-
j
I ever, in no case does this regulation require that the ]
1 !
area of review extend beyond a one-quarter mile radius.
For purposes of this analysis, a one-quarter mile radiqs
of review was used for all new injection wells. While
this may be a worst case assumption, there was insufficient
information available to determine the impact of the
alternate definition allowing the use of the Theis
equation or otoher- suitable technฑ'cal""criteria .
c146.07 Corrective Action
In determining the adequacy of corrective
action proposed by the applicant under
40 CFR 122.38 and in determining the
additional steps needed to prevent fluid
migration into underground sources of
drinking water, the Director shall con-
sider the following criteria and factors:
(a) toxicity and volume of the
injected fluid;
(b) potentially affected population;
(c) geology;
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(d) hydrology;
(e) history of the injection operation,-
(f) completion and plugging reports;
(g) abandonment procedures in effect
at the time the well was abandoned; and
(h) hydraulic connections with un-
derground sources of drinking water.
For new injection wells, the permit applicant must pre-
scribe corrective action to wells in the area of review)
which are improperly completed or plugged. The proposed
jaction (or inaction) will be reviewed by the Director
i
{and if found inadequate, additional corrective action
prescribed and taken prior to the issuance of a permit.,
This review process permits an operator to present evi-
dence to the state director supporting his position.
The overall estimates of affected well population account
for this orocess.
-.146.08 Mechanical Integrity
(a) An injection well has mechanical
integrity if:
(1) there is no significant leak
in the casing, tubing, or packer; and
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(2) there is no significant
fluid movement into an underground source
of drinking water through vertical channels
adjacent to the injection well bore.
(b) Some combination of the following
tests shall be used to evaluate the
absence of significant leaks under para-
graph (a) ( 1 ) :
(1) TV monitoring;
(2) monitoring of annulus
pressure;
(3) radioactive tracer survey;
(4) casing inspection log;
(5;
pressure test with fluid
or gas ,-
(6) temperature survey;
(7) flowmeter survey; or
(8) pack er test.
(c) The absence of fluid movement
under (a)(2) may be shown by:
(1) well records demonstrating
the presence of adequate cement to prevent
such migration; or
(2) by the results of a cement
bond log, sonic log, or dual neutron log.
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(d) The Director may allow the use
of a test to demonstrate mechanical in-
tegrity other than those listed in sub-
sections (b) and (c)(2) with the written
approval of the Administrator. . . .
(e) In conducting and evaluating the
tests enumerated in this Section or others
to be allowed by the Director, the owner
or operator and the Director shall apply
methods and standards generally accepted
in the industry. When the owner or opera-
tor reports the results of mechanical
integrity tests to the Director, he shall
include a description of the test(s) and
the method(s) used.
It is clear that two integrity tests are required; first,
to prove there are no leaks, and second, to prove there
!is no fluid migration. In the cost analysis, these tests
l
have been referred to respectively as a mechanical in-
|tegrity test and a fluid migration test.
i
|
i
I Since there is no specification regarding the timing ofi
I
ithese tests, it was assumed that tests would be conducted
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]during a normal well shutdown for repairs or other pro-
l
1
duetion-related activities. Therefore, the cost of cori-
t
i
!
ducting the tests includes only the cost for wire line j
I
i
service and log interpretation. |
While EPA states that technical guidance on acceptable
i
methods for conducting and evaluating the tests will j
be issued at a later date, it has also been assumed ;
that existing oil field practices will prevail and theue
5
will be no new costs associated with the development ;
and implementation of new testing practices. ;
J146.09 Special Requirements for Wells
Managing Hazardous Wastes
(a) As provided in 40 CFR 122.44, the
owner or operator of any well that is used
to inject hazardous wastes accompanied by
a manifest or delivery document shall obtain
authorization to inject as specified in 40
CFR 122.35 and 36.
(b) In addition to the applicable re-
quirements in 40 CFR Part 122 and 40 CFR
Part 146 Subparts B-F, the Director shall,
for each facility meeting the requirements
'AGE NUMBER
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"3 OP CCUR!EQ '2 ,MODi= ED
CL-BLE
: INCHES ;8OROSRS INDICATE!!
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VvhiTE OUT CR USE CORRECT
USE 2 HYPHENS
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SPELL OUT COMPANY NAVE
USE RED PENCIL
of paragraph (a) of this section, require
that the owner or operator comply with:
(1) The notification requirements
of 40 CFR Part 250, Subpart G (proposed at 43
FR 29911 (July 11, 1978); and
(2) The manifest system, record- j
| keeping, and reporting requirements of 40 CFR ;
'
i 250.43-5U); (b)(6); (c)(5)(i)-(iii); (c)(5) i
{ |
) I
i (iii)(A)-(F) and (H); and (c)(6)(proposed at i
I i
; 43 FR 59003 (December 18, 1978)). j
( \
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It is not certain whether oil production brines will
be classified as a hazardous waste or what the impli- |
ications of that classification will be. However, for
Ipurposes of this analysis, these fluids were considered!
inon-hazardous and, therefore, not subject to any addi- ;
tional requirements as specified in this subsection.
.Appendix D summarizes in more detail the impact of the i
\ '
lHazardous Waste regulations on the UIC program. .
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!~3 ?R COLRlER 12 MCOiFIED
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i-2 INCHES BORDERS INOICATEDI
USS ฃ 1 .11 ! "iGT .1 " : ;
3. Subpart C -- Criteria and Standards Applicable
!
to Class II Wells
i
146.21 General I
|
(a) This Subpart sets forth require- !
s
i
ments for underground injection control I
programs to regulate enhanced recovery,
hydrocarbon storage, produced fluid and >
other Class II injection wells described
in 40 CFR 122.34 (b) . !
(b) Except as provided in (d) , no '
existing Class II well may continue to t
i
operate for more than 5 years after an ;
underground injection control program '
becomes effective, unless the owner or ;
i
operator has obtained a permit for such i
operation pursuant to 40 CFR 122.36. ;
(c) No new Class II well may begin :
to operate after an underground injection
control program becomes effective unless ]
the owner or operator has obtained a per- i
mit for such operation pursuant to 40
CFR 122.36. ',
(d) Notwithstanding the provisions ;
of (b) above the Director may regulate j
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LONG CASHES.
81/-L.E73
existing enhanced recovery and existing
hydrocarbon storage wells by rule as
provided in 40 CFR 1 22 . 35 ( a) ( 2) .
(e) The Director may disregard
the provisions of ;146.06 (area
of review) and 146.07 and 40
CFR 122.38 (corrective action) when
reviewing applications to permit an
existing Class II well.
(f) If the monitoring required
under 146.24(b) indicates the
migration of injection or formation
fluids into underground sources of
drinking water, the Director shall
prescribe such additional require-
ments for construction, corrective
action, operation, monitoring or
reporting (including closure of the
injection well) as necessary to pre-
vent such migration.
This subsection provides the framework for regulating
Class II wells. It requires that all new injection wells
I receive a permit before commencing with injection, that:
i
I all existing salt water disposal wells receive a permit
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Swithin the first five years of the UIC program, and !
that all existing enhanced recovery injection wells nead
only be regulated by rule. Furthermore, existing salt
water disposal wells are not required to conduct an
area of review or provide a statement of corrective
action in order to receive a permit.
While the exemptions stated in paragraphs (d) and (e)
above are clear, the final decision is left to the dis-
cretion of the state director for incorporation of these
exemptions in the state program. For purposes of this
analysis, state programs are assumed to be based
on the requirements as set forth in this subsection.
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THIS SHEET TO 3E USEC FOP. 3CA
1. z;vp,-cp SSTTPi.j iJ.'iTCH
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3CITING USE RED PENCIL
146.22 Construction Requirements
The Director shall prescribe requirements
for the construction of Class II injection
wells. Existing wells shall
pliance with such requiremen
to a specific compliance sch
lished by the Director as a
the permit under 40 CFR 122.
achieve com-
ts according
edule estab-
condition of
42 (a) ( 1 ) .
Existing enhanced recovery and hydrocarbon
storage wells shall be subject to general
compliance schedules establi
as provided in 40 CFR 122.35
shed by rule
(a) (2) .
,
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New wells shall be in compliance with
construction requirements before in-
jection operations begin. The owner
or operator of a proposed injection well
shall submit plans for testing, drilling
and construction to the Director and ob-
tain the approval of the Director of the
initial plans and any modifications of the
plans before incorporating them into the
construction of the injection well.
At a minimum, such requirements shall speci-
fy that:
(a) All new Class II wells shall be
sited in such a fashion that they inject into
a stratum which has confining beds that are
free of known open faults or fractures within
the potential zone of endangering influence.
(b) All Class II injection wells shall
be cased and cemented to prevent migration
of fluids into or between underground sources
of drinking water. In determining and speci-
fying casing and cementing requirements, the
Director shall consider the following factors
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(1) depth to the injection
zone ;
(2) injection pressure (ex-
ternal pressure, internal pressure, axial
loading, etc.);
( 3) hole siz e;
(4) size and grade of all casing
strings (wall thickness, outside diameter,
nominal weight, length, joint specification,
construction material, etc . ) ,-
(5) corrosiveness of native
fluids; and
(6) lithology of possible injec-
tion and confining intervals.
(c) The Director need not impose the
requirement in paragraph (b) of this section
on Class II wells located in existing injec-
tion fields if:
(1) regulatory controls existed
prior to the effective date of the applicable
underground injection control program with
respect to casing and cementing;
(2) the Director imposes those
regulatory controls which have historically
been present; and
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(3) well injection will not
result in the migration of fluids into
an underground source of drinking water
so as to create a significant risk to the
health of persons using the source as
drinking water.
(d) Logs and other tests shall be con-
ducted during the drilling and construction
of new Class II wells. A descriptive report
interpreting the results of such logs and
tests shall be prepared by a qualified per-
son and submitted to the Director. At a
minimum, such logs and tests shall include:
(1) Directional surveys conducted
on all holes, including pilot holes, at
sufficiently frequent intervals to assure
that vertical avenues for fluid migration
in the form of diverging holes are not
created during drilling.
(2) For surface casing intended
to protect underground sources of drinking
water :
(i) resistivity, spontaneous
potential, and caliper logs before the casing
is installed; and
P^GE MU.'.iaER
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10 PITCH
173 CR CCtR!ฃR 1 2 VCQIFiED
CQU3LE
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(ii) a cement bond long
after the casing is set and cemented.
(3) For intermediate and long
strings of casing intended to facilitate
injection:
(i) resistivity, spontaneous
potential, porosity, and gamma ray logs
before the casing is installed;
(ii) fracture finder logs
in appropriate situations as prescribed by
the Director; and
(iii) a cement bond log
after the casing is set and cemented.
(e) At a minimum, the following in-
formation concerning the injection forma-
tion shall be determined for new Class II
wells and submitted to the Director in an
integrated form:
(1) Fluid pressure.
(2) Temperature.
(3) Fracture pressure.
(4) Other physical and chemical
characteristics of the injection matrix.
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F*~- :C
PS.
(5) Physical and chemical charac-
teristics of the injection fluid.
(6) Compatibility of injected
fluids with formation fluids.
cementi
Paragraph (c) of this subsection exempts all injection
wells located in existing injection fields, including
new injection wells, from complying with casing and
requirements more severe than those which are currently
being enforced by state agencies. The converse is,
that new injection wells in _n_e_w_ injection fields must
comply with the full text of subsection b.
Interpretation for purposes of the analysis has been as
follows: !
9 Existing injection wells will require no
modification to the casing or cementing in
the injection well except to repair a casing
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1 ;::_, = IT; .-3 3 = ;\
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S \\ INCHES (BORCE^S I.\0!C^'30) AฐL SPELL OUT COMPAQ
USE i: ' " ' \'~ " ' ' ' EDITING USE RED PENCIL
leak or prevent fluid migration as detailed
in ^146. 08.
9 New injection wells in existing injection
fields will be required only to conform
with the casing and cementing program of
the state regulations currently in force.
.j New injection wells in new injection fields
are required to meet the full requirements
of subsection b.
i
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The specific testing requirements for new injection wellls
described in paragraph (d) are typical of industry praqtices
<
for drilling new wells. However, about 65% of new injgc-
tion wells are actually converted producing wells, and it
is possible that strict interpretations of this paragraph
might require all new injection wells to submit test rs-
sults. While adequate well records might be available to
submit to the director on the conversion of a producing
well to an injection well, this will not always be the '
case. Without the specific test results, the director i
j
, may decide not to issue a permit. '
i !
On the other hand, the state director may interpret this
! requirement as being inapplicable to converted wells be-
i cause of the precise language in paragraph (d) referencing
the "drilling and construction of new Class II wells."
For purposes of this analysis, it has been assumed there
would be no impediment, other than the testing and remedial
action requirements, to the permitting of converted in-
i !
I jection wells; that is, the specific construction require-
ments in paragraph (d) will not apply to converted injec-
' tion wells.
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j146.23 Abandonment of Class II Wells
(a) Class II wells shall be abandoned
in a manner, to be prescribed by the Director,
which will not allow the migration of fluids
either into or between underground sources
I
of drinking water. At a minimum, the well
to be abandoned shall be in a state of static
equilibrium with the mud weight equalized
I
top to bottom, either by circulating the
mud in the well at least once or a com-
parable method prescribed by the Director,
prior to the placement of the cement plug(s) .
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USE :. lAl { \OT i 1 , 1 !
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USE A RED PE\C!L 00" ป
SPELL OUT COVP^NY N~*.'5
USE RED PENCIL
(b) Owners or operators shall assure, ;
j
through a performance bond or other appropriate j
i
means, the availability of resources necessary I
for the proper abandonment of the well as
required in 40 CFR 1 22 . 42 ( a) ( 7) .
JThis subsection applies to well abandonments subsequent!
i i
to the promulgation of a state program. Paragraph (b) ;
requires owners or operators to demonstrate the means
for the proper abandonment of the well. It has been
assumed that companies would have to either demonstrates
'adequate financial resources or purchase a plugging
i
'bond, but that a plugging bond, per se , would not always
\
!be required. ;
d. ~146.24 Operating, Monitoring, and
Reporting Requirements
(a) Operating Requirements:
The Director shall prescribe requirements
governing the operation of injection wells
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'HIS SHEET TO
,R.ER 12 W.
'= 'NCHES BORDERS i.NDiCA~E:
J3E :. 1^1 ( "iCT i I _ ' ;
FOR SCANNER COPY ONLY
,Y~MT5 CUT OR
USE A ซ5DPENCIL'
;UT COMPA,"
USE RED PEMCiL
in the permit. Requirements for Class II
wells shall, at a minimum, include that:
(1) Injection pressure at the
surface shall not exceed a maximum which
shall be calculated so as to assure that
the bottom hole pressure during injection
does not propagate fractures in the injec-
tion zone, initiate fractures in the con-
fining strata or cause the migration of
injection or formation fluids into an
underground source of drinking water.
(2) Injection between the
outermost casing protecting underground
sources of drinking water and the well
bore shall be prohibited.
(b) Monitoring Requirements:
The Director shall prescribe monitoring
requirements in the permit. Such monitoring
requirements shall, at a minimum, include:
(1) Monitoring of the nature of
injected fluids at intervals sufficiently
frequent to yield data representative of
its characteristics.
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(2) Monitoring of injection
pressure, flow rate, and cumulative volume
at least with the following frequencies:
(i) weekly for salt water
disposal operations;
(ii) monthly for enhanced
recovery operations;
(iii) daily during the in-
jection or withdrawal of stored hydrocarbons;
and
(iv) daily during the injec-
tion phase of cyclic steam operations.
(3) Demonstration of mechanical
r
integrity pursuant to ^146.08 at least once
every five years during the life if the in-
jection well.
(4) Maintenance of the results
of all monitoring for at least three years
as prescribed in 40 CFR 122.14.
(c) Reporting Requirements:
The Director shall establish the form,
manner, content and frequency of reporting
by the owner or operator. The owner or
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L 70T -*
operator shall be required to identify the
types of tests and methods used to generate
the monitoring data. At a minimum, require-
ments shall include: ]
I
(1) An annual report to the Di-
i
rector summarizing the results of the moni- !
toring required under (b) above. ;
(2) The immediate reporting to '
the Director of any violation of a permit
condition or rule, or any malfunction of !
the injection system which may cause the \
migration of fluids into underground sources !
of drinking water.
(3) Written notice to the Di- i
rector within 30 days after any compliance ',
schedule date of whether the permittee :
has or has not complied with the require-
ment in question. !
i
As with other subsections in the UIC regulations, con- |
siderable discretion is left to the state directors.
Thus, the requirements specified here are minimum ones
which can be exceeded by individual state programs. i
For purposes of this analysis, it has been assumed that
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172 CH CCLRiER 1: VCD
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jstates will implement the UIC program in its minimum
i
i
(form or at a level which does not exceed current state
!
1
!requirements.
In paragraph (b)(1)(Monitoring Requirements), "intervals
sufficiently frequent to yield data representative" has!
I
been interpreted to mean that operators will not be re-j
I j
Squired to conduct fluid analyses at a frequency greater!
"than their current practice. It has also been assumed
i
* *
that representative data on the "nature of injected
fluids" would require no additional fluid analysis beyond
current industry practice. If a comprehensive chemical
j i
and physical analysis is required on a regular basis,
there would be a significant additional incremental
. cost. This is discussed more completely in Chapter XII.
I
For reporting requirements, it has been assumed that
data currently reported to the states would continue
j to be reported to the states in the same format and
that new data would be reported through the existing
proce s s.
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e. \146.25 Information to be Considered byj
the Director Prior to the Issuance of
a Permit
Prior to the issuance of a permit for an
existing or new Class II well, the Director
shall consider the following information.
For an existing Class II disposal well, the
Director may rely on the existing State
permit file for those items of information
listed below which are current and accurate
in the State file. For a new Class II well
the Director shall require the submission
of all of the information listed below.
The information required in (b), (c), and
(f) below may be included by reference if
the reference is specific in identifying
the information in question and if it is
readily available to the Director. In
cases where EPA issues the permit, all
the information in this Section is to be
submitted to the Administrator.
(a) Information required in 40 CFR
122.36, as appropriate.
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-33 1 1 J. 1 ( ^1^- _ '
(b) A map showing the injection
well(s) for which a permit is sought and
the applicable area of review. Within the
area of review, the map must show the number,
or name, and location of all producing wells,
injection wells, abandoned wells, dry holes
and water wells. Only wells of public record
are required to be included on this map.
This requirement does not apply to existing
Class II wells.
(c) A tabulation of data on all wells
within the area of review of a new Class II
well within the area of review of a new Class
II well which penetrate the proposed injection
zone. Such data shall include a description
of each well's type, location, depth, record
of plugging and/or completion, and any addi-
tional information the Director may require.
This requirement does not apply to existing
Class II wells.
(d) Operating data:
(1) Anticipated average and maxi-
mum daily rate and volume of injected fluids;
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(2) Anticipated average and
maximum injection pressure; and
(3) Source and analysis of the
physical and chemical characteristics of
the injection fluid.
(e) Appropriate geological data on
the injection zone and confining strata
including lithologic description, geo-
logical name, thickness, depth and area
of extent;
(f) Geologic name, lateral extent
and depth to top and bottom of all under-
ground sources of drinking water which may
be affected by the injection;
(g) Logging and testing program
data on the well;
(h) Engineering drawings of the sur-
face and subsurface construction details
of the system;
(i) Formation testing program;
(j) Stimulation program;
(k) Injection procedure;
(1) Contingency plans to cope with
all shut-ins or well failures so as to pre-
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V: INCHES .S
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vent migration of contaminating fluids
into any underground source of drinking
water;
(m) Plans for meeting the monitoring
requirements of -146.24 (b);
(n) In the case of new injection wells,
the corrective action proposed to be taken
by the applicant under 40 CFR 122.38.
(o) A certificate that the applicant
has obtained a performance bond which assures
resources to close, plug or abandon the well
as required by 40 CFR 1 22 . 42 (a ) (7} .
(p) A satisfactory demonstration of
mechanical integrity as required in M22.36(d).
'Much of the detailed data in paragraph (b), (c), and j
i !
i i
j (f) can be included by reference, and therefore spelled!
j :
jout for only one permit application. Information in ;
i
[existing state permit files is allowed to be used for j
I
!
permitting existing Class II wells under the new federall
i
regulations. Operators are assumed to take full advan-^
i
tage of these guidelines in applying for injection well
i
i . i
i permits. |
"3 ,-\ -*< ^ !<*, "3 r- v
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33 "CLSiE^ 12MOO!F:E3
'JBLS
,,-;c:-5S BORDERS INDICATED)
O.-.ArJGgS. ,'/H!T= Q'^T OR ;JSฃ CORRECT
;"3 DASHSE, USE 2 HYPHENS
3!JL_ETS. USE A RED PENCIL DOT *
ADL. SPELL OUT CC-V1P",NY NAME
= ClTI.NG USEREDPEMCiL
In addition, requirements for Operating Data (d), Geo-
I
logical Data (e), Logging and Testing Program (g),
I
'[Engineering Drawings (h) , Formation Testing (i) ,
fStimulation Program (j), and Injection Procedure (k) ,
jare assumed to be readily available to the operator as
part of routine study prior to beginning injection
Joperations. The requirement for a water analysis has
'the potential for increasing the permitting cost for
4
Jail injection wells. However, it has been assumed that
'new injection wells would perform a water analysis as ]
;a matter of current practice prior to beginning injection
'operations and would therefore bear no incremental costs.
' i
On the other hand, existing SWD injection wells would have
.no reason for conducting such an analysis except to matae
;application for a Federal UIC permit. Therefore, ex- ,
listing injection will bear an incremental cost as a :
i
result of this requirement. [
iWhile the requirement for a contingency plan has the
potential for requiring operators to submit a detailed !
I
statement similar to a spill prevention control counteu-
measure (SPCC) plan, the interpretation used for this
analysis requires only that operators make a simple state-
ment in the permit, in no more than a paragraph, stating
that plans have been considered for reacting to well
ฐ-^GE NUMBER
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shut-ins or well failures. j
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The subjects raised in paragraph (m) , (n) , (o) , and (p)j
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have been discussed elsewhere in this chapter. j
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f. ^146.26 Regulation of Existing Enhanced!
Recovery Wells and Hydrocarbon Storage
j
Wells by Rule i
\
Rules adopted to regulate existing enhanced
recovery wells and hydrocarbon storage wells !
shall, at a minimum apply the relevant con- j
struction, abandonment, operating, monitoring ]
and reporting requirements in 146.22,
146.23 and 1 46 . 24. ':
jThis statement essentially requires that all existing j
i !
(enhanced recovery wells and hydrocarbon storage wells
I ;
comply with the full extent of the regulations except :
I that they need not apply for a permit. .'
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EDITING
VII. APPROACH TO COST ANALYSIS
|A. INTRODUCTION
The national costs of compliance arising out of the EPA11 s
UIC program requirements for oil- and gas-related i
* I
(injection wells include both costs of compliance incurred
I '
; by the U.S. oil and gas industry and costs of program
!
'administration insurred by state governments. Wherever,
(possible, compliance costs have been estimated on an \
I i
iincremental basis; that is, only the program costs oven and
!above current practices have been considered. This chapter
I <
i '
[describes the general approach and methodology that has
'been used to develop the UIC program cost estimates. i
(Subsequent chapters provide details of the cost calculai-
I ,
itions as well as any specialized methodology used in
^their development.
|
iB. OVERVIEW OF COSTING METHODOLOGY
1 Estimates of the incremental costs of compliance to the
j 1
|U.S. oil and gas industry during the first five years ]
i !
iof the UIC program have been developed using a seven-
i
i
istep approach (chapter notations refer to locations
i
within this report):
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:S I'i, iU-iES 3GHOHPS PiD'CATc
Current injection practices have been identified
and profiled (Chapters III through V) . ]
* Requirements of the proposed UIC program have j
i
!
been identified and categorized into cost com- !
ponents (Chapter VI). ;
)
* UIC requirements were then compared with profiles
of current practices to determine both the extent
and the magnitude of incremental requirements
(Chapters VIII through XII) .
9 Unit cost estimates were developed (Chapters
VIII through XIII) .
ซ A census of injection wells was taken (Chapter III) ,
and population projections were developed for the
five-year cost analysis period (Chapter VII).
j
* Compliance cost estimates were computed for each
incremental UIC requirements by multiplying unit
costs by the number of wells estimated to be
affected by the particular requirement (Chapters
VIII through XIII) .
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9 Cost elements for all incremental UIC program :
i
requirements were then summed to develop a total
j
t j
i direct incremental cost of compliance to the oil
1 !
; and gas industry (Chapter XIV). (
i j
! ]
i i
! i
j State agency incremental costs have been estimated in a
|
manner similar to the above approach. A discussion of
\ the specific steps used in estimated state agency costs
i
) is contained in the introduction to Chapter XIII. (
I
!
' Cost projections are the total of the direct incremental
; costs to the oil and gas industry, and the incremental'
i costs of administering the UIC program that will be borne
i by the state agencies. The impacts resulting from any (
i
inequities in the distribution of these costs among the
j oil and gas companies has not been considered. Likewise,
! impacts resulting from potential well closures or pro-
| duction losses are not included in this analysis.
C. GENERAL APPROACH
_ _ ._ . ^r _,, ,_
: This section of the report describes in detail the seven-steps oj
the general approach that has been highlighted in the above
overview.
AZii
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DR OSS
- v c
1 ..
C u r_r_ea t P r as . t ic e
As discussed in Chapters III and IV, profiles of state
requirements and industry practices were developed from
survey data, field interviews, industry meetings, and
published sources. These profiles provided a descriptive
characterization of both the typicality and the variability
of a number of major components of injection operations:
permitting, design and construction, on-going operations,
testing, and reporting to state authorities. Separate
profiles were developed for both enhanced recovery wells
|
and salt water disposal wells because of the inherent >
differences in these two types of injection operations.
Moreover, because of the effects of differences in
j
! geology and geography, regional (and in some cases,
]
\ state) profiles were often developed. '
' The overall set of current practices depicted in the
I profiles served as a baseline for assessing the incre-
i mental requirements of the UIC program. Only regulatory
j \
\ requirements above and beyond current practices were
t
j considered in our cost analysis.
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2. Identification and Cataloging of UIC
Program Requirements
As discussed in Chapter VI, the requirements of the
proposed UIC program have been identified and
arranged into six major regulatory components according
to general focus. The six major cost components are:
a. Area of Review. Requirements for the
I
I
j review and, if necessary, repair of producing and
i
*
i abandoned wells that are located nearby an injection
well.
b. Existing Injection Wells: Testing and
Reme_di_a.l__Action. Requirements that pertain to the
testing, repair and/or modification of oil- and gas-
related injection wells that are in operation before
promulgation of a state UIC program.
(Existing injection wells include both older
wells that have been converted for use as injection weLls
and wells that have been drilled for the express purpose
of injection operations/)
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j c. New Injection Wells: Incremental Action, j
i ~ i
i !
iRequirements relating to the design, construction, andj
testing of oil- and gas-related injection wells that
begin operation after promulgation of a state UIC
program. New injection wells include
both newly drilled injection wells and newly converted
injection wells. This is particularly significant
because historically there has been a strong propensity
for a substantial number of injection wells to be con-
verted from existing wells rather than drilled for the
express purpose of an injection operation. Hence, new
injection well requirements affect both construction
of new wells and conversion of existing wells.
d. Permitting. Requirements for the applica-
tion, issuance, and renewal of state program permits
for underground injection wells.
e. Monitoring Data. Requirements for the :
,
collection and reporting of injection well operating
data.
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CHES 'BORDERS iND'CATED
WHITE CU- C? ;_,SE OC^P = C~:
USE A P~D J;NC: L 30
SPELL CU~ COMPLY
USE RED =>ENCIL
I f. State Program Requirements. Operating
requirements for the state agencies responsible for
I
\ implementation and administration of an approved UIC
t
i
\ state program.
3. Determination of Incremental Requirements j
UIC program requirements identified in Step 2 were com-
i
pared with the baseline profiles of current practices
developed in Step 1 to arrive at an estimate of both the
j
extent and the magnitude of incremental requirements to
i,
the oil and gas industry and to the state agencies I
responsible for overseeing injection operations.
Although simple in concept, this proved to be an extremely
complex determination because of considerable variation
in current practices. ;
4. JDeveJLopment of Unit Cost Estimates
Unit cost estimates were developed for all incremental
I requirements. Estimates reflect the "average" costs
associated with each incremental task or requirements. !
As "averages," the unit cost estimates can be mislead-
ing and are subject to considerable misinterpretation. ,
In some cases, unit costs were developed by weighting
the costs of accomplishing the specified incremental
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"-<; 3nEZT TO 3s USED FG?. JCA.NNSR COPY ONLY
; task according to varying industry practices. In other
I i
j cases, regional unit costs were developed and used to ]
! i
i i
| arrive at a weighted national average "unit cost." j
j 1
| In yet other cases, unit costs were developed by assess-
i i
s \
ing the range of possible costs and adjusting the mid- j
I
point to reflect our judgments as to the distribution }
i
j :
j of costs that would be incurred. i
j In all cases, unit cost estimates were developed by !
I
j taking full account of the diversity of situational l
i '
i. ',
i differences found in injection well operations. As a
i \
I result, the unit cost "averages," like any average, ara
; not necessarily representative of a typical cost of a ''
:particular action. Instead, a unit cost represents a
', weighted national (or in some cases, "regional") average
J cost of the incremental requirements.
Numerous sources of information were utilized in the
development of unit costs including in-depth interviews
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with injection well operators, oil field service com- i
i
j
panies, oil well drilling contractors, and state regu-j
i
latory agencies. Cost estimates prepared at our request
I
by the American Petroleum Institute and in response to j
earlier UIC drafts by the Western Oil and Gas Associa-
i
tion were considered. Additionally, Subsurface, Inc.,
an engineering and service company in the business of :
injection well design and operation, was retained to
develop an assessment of key unit costs relating to :
;
drilling, completion, testing, operation, and rework
i
iof injection wells. j
I
j
i '
i
i
Methodologies for the development of each unit cost
has been described, and source data have been identified
i ,
Jin Chapters VIII through XIII. For the convenience of
i
j the reader, a complete listing of units costs, as well ;
| as their location in this report, is provided in
Table VII- 1 .
5. ___ Wjs^l Population JPrp j ections Were Developed :
j "~ "~ ' """" ...... .....
I As described in Chapter III, a census of state injec-
jtion well populations was taken by Arthur D. Little,
S
line., in the summer of 1977. The results of this censuis,
jwhich appear in Table III-..2 of this report, required '.
\)\V-
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TABLE VI 1-1
SUMMARY
Name/Description
I. Collection and Reporting of Monitoring
Data Costs
SWD Collection of Monitoring Data
ER injection well collection of monitoring data
Average SWD reporting cost
Average ER injection well reporting cost
II. Permitting Costs
Average cost per existing SWD well of prepara-
tion of a UIC permit application
Average cost per new SWD well of preparation
of a UIC permit
Average cost per new ER injection well of
preparation of a UIC permit
III. Testing and Remedial Action1
Average cost of reviewing records of existing
injection wells to determine adequacy of
cement or other compelling evidence of lack
of potential for fluid migration
Report mechanical integrity test
Average cost of surface monitored downhole
test to locate casing lead in injection wells
Average cost of surface monitored downhole
test to detect the migration of fluids along the
exterior of an injection or production well bore
Surface monitored annulus pressure test to
detect casing leaks (only for wells with tubing
and packer)
Remedial action for wells failing Tests:
Cement squeeze (average cost)
Cement Seal (average cost)
Abandon and redrill (average cost)
OF UNIT COSTS
Location Within
This Report
XII-B
XII-C
XII-E
Xll-E
IX-G
IX-G
IX-G
IX-C
X-D
IX-C
IX-C
IX-C
IX-D
IX-D
IX-D
Cost Unit Cost
Basis ($)
1 98.73
F 27.55
1 6.16
1 1.08
F 240.00
F 620.00
F 367.00
F 20.00
I 25.00
F 1 ,500.00
F 1,500.00
F 30.00
F 25,000.00
F 30,000.00
F 1 50,000.00
1
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Arthnr-HI irtlelnc
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TABLE VI1-1 (Continued)
Location Within Cost Unit Cost
Name/Description This Report Basis ($)
IV. Area of Review Requirements
Average cost per well record for location,
retrieval and review of well completion
records
Producing well record VIII-F F 17.00
- Abandoned well record VIII-F F 50.00
Testing producing well for fluid migration VIII-F F 2,500.00
Remedial action to producing wells
Cement squeeze (average cost) VIII-F F 30,000.00
Average cost of reabandoning plugged wells VIII-F F 20,000.00
F = full cost
I = incremental cost
1. Includes only the cost of performing the actual test or remedial action. Does not include costs to shutdown
well and prepare for work since the work is assumed to be scheduled during routine maintenance shutdowns.
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7ri!S SHEET T'2 3 = USED FOR 8CANMSR COPY ONLY
updating in order to be representative of the well j
populations that would exist during the five-year time-
I i
i frame of our cost analysis. Updating was required to I
J ;
jreflect the growth of injection wells, resulting from \
both drilling of new injection wells and conversion of I
i
existing wells to injection operations, net of the i
l
normal plugging and abandonment of injection wells ]
resulting from declining production yields, changes in I
reservoir engineering, and the like.
Based on recent trends and discussions with state '
agencies, we estimate that approximately 5000 new injec-
tion wells have been placed into operation each year
during the period 1977 through 1978. Allowances for
the abandonment of existing injection wells reduce the
overall growth from 5000 new wells per year to about
4000 net new wells, or a net growth rate of about 3.15%
per year.
We estimate that about 4000 of the 5000 new injection !
[wells placed in operation during each of the past two
j
iyears were enhanced recovery wells, while only 1000 were
i
{
| for disposal of produced fluids.
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;Using these data as a basis for developing future pro-i
3 I
i jections, we estimate that the net growth of enhanced j
ซ i
I recovery injection wells will be 3.5% per year, compared
, I
| to 2.25% for salt water disposal wells. These estimates
i j
I suggest an ov"erall net growth rate of 3. 15% per year '
i for oil- and gas-related injection wells. Table VII-2 !
jdisplays the well population projections developed for ;
,use in analysis of costs of compliance of the UIC
i
! program.
!The differences in the estimated growth rates for salt [
,water disposal and enhanced recovery injection wells
iwill account for a further decline in salt water disposal
iwells as a percentage of total injection wells from 29%
I
I in 1976 to less than 27% in 1985.
|
I Table VII-3 presents Arthur D. Little, Inc.'s estimates
-of injection well populations by state for year-end 1979,
jassuming even growth across all states. While growth
i
,'- } " !
| rates will undoubtedly vary from state to state, 6~ur'
i analysis uses state and regional population projections:
J
isolely for purposes of weighting the inputs to an
'overall national compliance cost estimate and not
;for development of individual state or regional cost
vJU-
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CM
TABLE VII
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TABLE VII-3
INJECTION WELL POPULATION PROJECTIONS BY STATE FOR
BASE YEAR DECEMBER 31,1979
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Totals
Salt Water
Disposal Wells
17,116
1,841
545
1,389
91
256
7
3,136
887
43
22
67
65
5,877
554
42
589
43
5,394
1,069
53
265
2
0
0
0
0
2
0
0
0
39,355
Source: Arthur D. Little, Inc., estimates.
Secondary Recovery
Injection Wells
100,315
Total
34,409
826
14,861
9,648
2,905
3,610
96
1 1 ,977
222
362
46
612
839
5,545
369
346
495
79
48
7,763
277
1,664
2,496
210
444
0
0
0
0
166
0
51,525
2,667
15,406
1 1 ,037
2,996
3,866
103
15,113
1,109
405
68
679
904
1 1 ,422
923
388
1,084
122
5,442
8,832
330
1,929
2,498
210
444
0
0
2
0
166
0
139,670
A _ปi n, i .
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THIS SHEET TI} 3E USED FOR SCANNER COPY ONLY
(estimates. Accordingly, projections developed
! ^r -- -
j utilizing a uniform net growth rate across all
j
\
\ thirty-one oil and gas states were deemed appropraite
t
] for our purposes. Table VII-4 shows a geographic dis-
tribution of injection wells adjusted to reflect overall
national growth in injection well population.
j 6 . Computation of __Increme_n tal Costs for Each
I
i Regulatory Component
\ ~~~"
i Compliance costs were computed for each incremental
sUIC requirement by multiplying the estimated unit cost
j
jby the number of wells estimated to be affected by the
particular requirement. This set of calculations was
1
j relatively straightforward and involved application of
;the unit cost estimates to the relevant segments of thg
swell population projections for each of the five years
included in our analysis.
7. Summation of Cost Elements
Cost elements for all incremental UIC program require-
ments were then summed to develop a total direct
incremental cost of compliance to the oil and gas
industry for each of the five years included in the
analysis .
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Arthur D Little I
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HIS SHEET TO BE USED FOR SCANNER COPY ONLY
-TS
DL.
Costs have been broadly divided into two groups:
ฎ R s cur r i ng Costs . Those costs, such as the
collection and reporting of monitoring data,
that will be borne each year of the program.
It should be noted that recurring costs will
extend beyond the first five years of the
program.
Non-recurring Costs. One-time-only costs for
complying with the regulations, such as the
replugging of abandoned wells in the area of
review. These costs will extend beyond the
first five years of the UIC program as UIC
permits are issued for new injection wells.
! D. ESTIMATES AND ASSUMPTIONS J
A number of estimates and simplifying assumptions were
developed in order to calculate the estimated cost of *
compliance. These estimates and assumptions are based on our pro-l
1 U .- .. ^'u *
fessional judgment and our analysis of field data, survey data, publishe
information, and in-depth interviews with administrators I
of state agencies, representatives of the oil and gas _
industry, and officials of industry associations. A *
listing of estimates and assumptions follows.
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JCH5S .'BORDERS INDICATE
LONG DASHES, USE 2 HYPHENS
2!J'_Lฃ~3. -SE A RED PENCIL DOT ป
ADL. SPELL OUT COMFANV \ซV =
= CiTi MG USERED=eNCIL
WELL POPULATION ESTIMATES AND ASSUMPTIONS
USED FOR COST ANALYSIS
I. ESTIMATED
1. As of December 31, 1976, there were about 127,000
active injection wells (including annular injection!
wells which number 11,400). Current projections
indicate that there will be 140,000 injection wells!
by December 31, 1979.
2. Five thousand new injection wells will be permitted!
each year; 4,000 will be new enhanced recovery injec-
tion wells, while 1,000 will be new salt water disposal
: wells. :
3. Seventy-five percent of existing enhanced recovery
. injection wells, and 75% of existing salt water disposal
wells (not including annular injection wells) have '
> tubing and packer allowing for annular pressure testing.
\ i
J4. There are about 505,000 oil-producing wells and about
; 135,000 gas-producing wells in the United States.
i
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5. There are 1.5 million abandoned wells, of which 1.2
million are "of record" (i.e., some information on the
well exists in state files).
D^GE NUMBER l/U-"(
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II. ASSUMED
A. Injection Wells-General
1. State regulatory agencies implementing the UIC>
'. |
; program will require that all fresh waters of
j 10,000 ppm TDS or less (higher quality) be pro-
I
; tected by an approved casing and cementing pro-
gram for newly drilled injection wells located
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' in new injection fields. The program will speci-
\
| fy that:
i
a) Cemented surface casing be set through all
potable water zones--currently used or
future potential; and
b) Cement be present on the outside of all
casing strings where they pass through other
fresh water zones; and
c) Injection zones be isolated from each other
i and from all other zones with cement
above the injection zone (and below the
injection zone as applicable) for all
wells penetrating or passing through any
injection zone.
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"HIS SHEET TO 3E USED FOR SCA^MER COPY ONLY
73 DRCCORISP '2MCDl = i=D
DOUBLE
1 : INCHES fSCROERS INDICATED'
USE ,:, 1 J. 1 ; \OT
'.VHiTt GUT OP 'ซ_$ = CORRECT'NG
Jj5E 2 HVPHENS
t3S A RED PENCIL COT ป
SPELL OUT CCMPAiViY \AYH
USE 3ED PENCIL
4.
5.
The yearly net increase in injection wells will '
i
be less than the total number of new wells per- '
mitted as a result of injection well abandon-
ments in the normal course of operation. The
expected net growth rate is projected to be
2.25% per year for salt water disposal wells,
and 3.5% per year for enhanced recovery injec-
tion wells.
While state programs will undoubtedly become effec-
tive over a span of many months, existing injec-;
tion wells are defined, for analysis purposes, ',
as the projected population of injection wells as
of December 31, 1979. \
Injection Wells-Disposal Operations '
1. Seventeen percent of salt water disposal wells '
do not have cement between the injection zone
and the fresh water zone. One-half of these I
I
wells will be able to present compelling evidence
demonstrating the lack of fluid migration; the
other half, or 8.5%, will be tested for fluid ',
migration along the exterior of the well bore using
a test such as a radioan-t-iv^ j-.y.ac
estimated cost of $1,500 each.
ฐAGE MA1BER
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2. State regulatory agencies will recognize that
a new injection well converted from an existing
producing well may not be able to comply explicitly
!
with the program described above. It is impossible
to add casing strings to an already completed '
well and it may be difficult or even impossible
to squeeze cement in many cases to the extent .
required above. Therefore, state agencies will
require a fluid migration test for all wells '
that cannot demonstrate compelling evidence
either from existing well records or geological
data of the lack of fluid migration.
3. New injection wells (both newly drilled and con-
verted) located in existing injection fields are
required only to comply with state regulations
in effect at the time a Federal UIC program is
promulgated.
\J\\
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HIS SHEET TC 3E USED FOH SCANNER COPY C^ILY
10 -^TGi-i
1?3 DP CO'-RISR 12 \!GOI = iED
CC'JBLc
1": INCHES iBORDERS INDICATED!
US3 ..III ( 'JOT ,_ 1 _ : )
pp-.-^-
'JSc A RED ?5\G!L DOT
SPSL- COT COMPANY N i?-'
USE PED =ENC;L
4. Ten percent of the wells tested for fluid migra-
tion will require remedial action; 9% will require
installing a cement seal at the top of the injeic-
tion zone at an estimated cost of $30,000 each;;
1% will be abandoned and redrilled at a cost of
$150,000 each. No additional cement is requirad
at the fresh water zone.
5. Five percent of existing disposal wells without
a tubing and packer and 1% of existing disposal
i
wells with a tubing and packer tested for leaks,
will have a leak and require squeeze cement to .
i
repair the leak at a cost of $25,000 each.
6. Annular injection wells that do not have cement!
between the injection zone and the fresh water '
zone will cease injection and be used only for
production. Testing and repairing these
annular injection wells is impractical. The ;
i
costs of securing replacement injection capacity
have not been estimated.
ฐAGE NUMBER
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THIS SHEHT TC 3E JSED FOR SCANNER COPY ONLY
r,i INCHES (BORDERS iNCICATHDi
USE ..\ 1 -l 1 ( M0~ :. " : " }
WHITS OUT OR USE CO PI
USe 2 HYPHENS
USE A RED PENCIL DCT
SPELL. OUT COMPANY M AM
USE RHD PENCIL
1C. Injection Wells-Enhanced Recovery Operations
1 .
2.
3.
Twenty-three percent of existing enhanced recoviery
injection wells do not have cement between the
injection zone and the fresh water zone. One-
-half of these wells will be able to present
other compelling evidence demonstrating the lacJc
of fluid migration; the other half, or 11.5%,
will be tested for fluid migration along the
exterior of the well bore using a test such as
a radioactive tracer at an estimated cost of
$1,500 each.
Ten percent of the wells tested for fluid migra
tion will require remedial action; 9% will require
installing a cement seal at the top of the injec-
tion zone at an estimated cost of $30,000 each;
1% will be abandoned and redrilled at a cost of
$150,000 each.
Seventy-five percent of existing enhanced recovery
wells without tubing and packer and 0.75% of
wells with tubing and packer tested for leaks, will
have a leak and require squeeze cement to repair
the leak at a npst-. n-F $9^,nnn each. I
PAGE -\LMBER
*l
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THIS SHEET TO BE UScD FOR SCANNER COPY ONLY
D
10 PITCH
173 OR COURIER 12 MODIFIED
DOUBLE
T'2 INCHES (BORDERS INOICAT
USE .:> 1 i 1 ( MOT .1 1 .i 1 )
>,'/r>ST= OUT OR ,$ฃ C
oSE 2 HYPHENS
USE A RED PENCIL D
SPELL OUT COMPANY
USE RED PENCIL
Wells Within Area of Review-General
1 .
2.
3.
4.
The area of review is assumed to be the area :
I
within a one-quarter mile radius of either a I
i
new enhanced recovery injection well or a new '
!
I
salt water disposal injection well. j
The total potential area of review for new
injection wells is broadly defined to include
all wells in and around enhanced recovery opera-
i
tions, and 50% of the wells in and around salt j
water disposal operations; these areas are
assumed to be mutually exclusive,
Oil producing wells are either: (a) in and
around enhanced recovery operations; (b) in and!
around salt water disposal operations; or ;
(c) geographically isolated from either enhanced
recovery operations or salt water disposal
operations . j
i
All gas wells are geographically isolated from
both enhanced recovery operations and salt water
disposal operations and, therefore, not in the '
potential area nf
PiGSMUMBEF
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i HIS SHEET TO 3E UStD FOR SCA^iNSR CC?Y ONLY
DOUBLE
;'2 !NChcS .aO
8.
INDICATED!
."/Hi i = CUT OR USE CCRREC
^SE 2 HYPHENS
t'SE A RED PENCIL DOT *ป
SPELL OUT COMPANY NAME
JSE .=?ED PENCIL
6.
7.
I
5. Twenty-five percent of the 1.2 million abandoned
1
wells "of record," are located in geographically
I
isolated "abandoned" fields and, therefore, willl
j
not be located in a potential area of review. !
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Abandoned wells are distributed throughout the i
regions in the same proportion as oil producing!
wells. |
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f
Abandoned wells in the area of review for which!
existing records do not show sufficient cement
i
to prevent fluid migration from an injection .
zone to the fresh water zone and for which com-'
pelling evidence of non-migration cannot be prer
sented will be reabandoned. The costs of testihg
for fluid migration are high and results are
not definitive, therefore, it is unlikely a
person would test the well prior to reabandonment.
I
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!
In general, there is a positive relationship
between the number of producing wells in or
nearby ER projects and the amount of oil produced
from ER methods in any state.
3AGE \LMBE\ljV
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HIS SHEET TO BE USED FOR SCANNER CCPY ONLY
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i E
10 PITCH
' 73 OR COURIER 12 MODIFIED
C 0 U 8 L E
1 2 INCHES BORDERS INDICATED)
USE - 1 i i ( NOT i 1 A, 1 )
C-ANGES. .VH'TE CUT CR uSc CORRECTING TAP!
LUNG DASHES USE 2 HYPHENS
3LLLฃ'S vSE A RED PฃNCJLDO"r "ป
AOL SPELL OUT COMPANY MAVIS
irji-r-iG, JSE^ED PENCIL
9. In general, there is an inverse relationship
between the number of producing wells in SWD
!
projects and the amount of oil produced from EF3
i
methods in any state. I
Wells Within Area of Review-Disposal Operations
1 .
2.
Seven-and-a-half percent of abandoned wells ',
\
penetrating the injection zone will not be able)
to demonstrate either adequate cement or the ;
lack of fluid migration and will require plugging
at an estimated cost of $20,000 each. j
Ten percent of existing producing wells in the i
area of review will not be able to demonstrate i
either adequate cement or compelling evidence '.
i
of the lack of fluid migration between the
injection zone and the fresh water zone. Statei
agencies will allow testing for fluid migration
at producing wells to be conducted during |
scheduled well breakdown. Therefore, the incre-
mental testing cost will be $2,500.
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THIS SHEET TG 3S USED FOR SCANNER COPY ONLY
3.
SPELL GUT COMPANY \
Ninety percent of the 10% of producing wells
without adequate cement will conduct a test for
fluid migration. Ten percent of the tested wel^s
will require squeeze cement at $25,000 each.
Ninety percent will demonstrate no fluid migration
4. Ten percent of the 10% of producing wells in the
area of review will not be able to test or will,
| choose to squeeze cement without testing for
j
. fluid migration at a cost of $25,000 each.
i
.F. Wells Within Area of Review-Ehanced Recovery Operations
: 1. Enhanced recovery is usually a unitized operation
; where fluid injected through an injection well
; forces oil toward a pattern of producing wells.':
The operator has an incentive to make sure that;
the injected fluid is not dissipated through
leaks or other nearby wells. Therefore, the
likelihood of producing and abandoned wells near
i
an enhanced recovery well requiring remedial
action is 25% less than for the same wells near,
a disposal well.
AGcDUMBER
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"HIS SHEET TO BE USED FOR SCANNER COPY ONLY
CHAMGES.
LONG DASHES:
3ULL-TS
ADL:
EDITING
WHITE OUT CR USE CCRPcCTI.X
'^SE 2 HYPHENS
USE A RED PENCIL DOT '9
SPELL OUT COMPANY ,\AM5
L-SE RED PENCIL
4 .
2. 5.6% (7.5% x .75) of abandoned wells penetrating
t
the injection zone cannot be shown to have adequate
1
cement and will require plugging.
3. Seven-and-a-half percent (10% x .75) of existinta
I
producing wells in the area of review will not j
be able to demonstrate adequate cement or compeil-
ling evidence of the lack of fluid migration '
between the injection zone and the fresh water \
zone. State agencies will allow testing for !
i
fluid migration at producing wells to be con- '
\
ducted during scheduled well breakdowns. There-
fore, the incremental testing cost will be $2,500,
Ninety percent of the 7.5% of producing wells i
without adequate cement will conduct a test for;
fluid migration. Ten percent of the tested wells
will require squeeze cement at $25,000 each.
Ninety percent will demonstrate no fluid migration
5. Ten percent of the 7.5% of producing wells in
i
the zone of endangerment will not be able to
test and will choose to squeeze cement at $25,000
each without testing for fluid migration.
PAGE MU\iBE\J\\
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THIS SHEET TO 3E USED FOR SCAMNER CC?Y ONLY
'/.-HITE CUT OR USE CO-
uSE 2 HYPHENS
USE A RED PENCIL uO~
SPELL OUT COMPANY \
USE RED PENCIL
! G. Permitting
i
1. UIC permit applications for existing wells will
be reviewed evenly over the first five years
of the UIC program.
2. Permits for new ER wells can be sought in groups
on a project-by-project basis. Accordingly,
based on field interview data, it is assumed th,at
UIC permit applications for new ER injection !
i
wells will average 3 injection wells per applica-
tion . !
rf.
' -i o E M U M B E \|\\
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THIS 3HSET TC 3 = *,.SED FCfl SCANNER COPY CMLY
E E_XTENT__AND_LIMITAT10 N _0 F ANALYSIS
Cost of compliance projections are the total of the
direct incremental costs to the oil and gas industry
and the incremental costs of administering the UIC
program borne by the various state agencies responsible
for overseeing the control of underground injections.
As such, our analysis is not an economic impact
analysis. The impacts resulting from uneven
distribution of these costs among the oil and gas com-
panies has not been considered; nor have impacts resulti-
ing from potential well closures or loss of production
opportunities due to higher costs of current projects
or reduced incentives for the development of new enhanced
recovery projects been included in this analysis. Our
i, - - j---..
analysis is strictly a tabulation of those incremental costs to
borne directly both by the oil and gas industry and the
various state regulatory agencies.
=3 \>\\-
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VIII. AREA OF REVIEW '
?
A. INTRODUCTION
The costs of complying with the area of review require-
ment of the proposed UIC program represent the largest
share of the total costs to injection well operators-- '
over 63%. The area of review requirement is estimated
to cost injection well operators $409 million over a
five-year period. Of this, approximately $315 million
represents the cost of reabandoning improperly plugged
wells, and the remaining $94 million is associated with,1
testing and cementing producing wells.
No other single cost component included in this analysis
has the potential to vary as much as this one. There
are several factors underlying this potential for
variation. One factor is the possibility of higher
costs than those estimated for reabandoning improperly
plugged wells. This issue is discussed in Section F.
I
!
;
The concept behind the area of review requirement is
that producing and abandoned wells near an injection
.well that penetrate the injection zone have the potential
to become cond-uits for fluid migration. The extent of
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this potential is a function of how the nearby wells ;
were completed or plugged. Potential for leaking is :
also related to other factors such as anticipated '
pressure, fluid volume, and the specific geology and/or:
hydrology of the reservoirs. The emphasis in this
requirement, however, is on the condition of nearby
wells in terms of cementing. Producing wells that were:
considered "adequately" completed at the time of their
I
;completion may be considered inadequate by today's
.regulatory standards and industry practice. Similarly,
'abandoned wells may be considered improperly plugged
today even though the procedures used for abandonment
_ may have been considered "proper" at the time of
* abandonment.
I
For all new injection wells, the area of review would
| require the review of completion or plugging records of
ซ _, nearby wells that penetrate the injection zone. Existing
^injection wells are exempted from this requirement.
;
jThe purpose of this review is to identify wells that ;
require action in terms of testing, cementing or reaban-
donment to prevent fluid migration from an injection
zone to a fresh water zone.
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The requirement provides for two methods of determining
the radius of the area of review: a fixed radius of
not less than a quarter-mile from any new injection weLl
i
ior the calculation of a radius of the "zone of endan-
> i
:gering influence" using an objective equation such as
,a Theis equation. The radius of the "zone of endangering
:influence" could vary from location to location and
|could conceivably have a radius that is less than a
quarter-mile from the injection well. The reason for
, this is that the size of the radius of the "zone of
endangering influence" is derived from a calculation
that is based on formation, fluid flow, and pressure
characteristics. These physical characteristics might
be such that it would be impossible for fluid to flow
beyond a certain lateral distance from the well bore
of an injection well. The maximum lateral distance
might be less than a quarter-mile.
;Arthur D. Little, Inc.'s analysis of the area of review!
requirement is based on a quarter-mile radius of review
and not on the alternative "zone of endangering
influence" formula. The area of review used in this
analysis therefore is the area whose radius is a quarte-r-
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mile around all new injection wells. Producing and
abandoned wells located within this area would be reviewed
and may require remedial action if they penetrate the
injection zone.
:B. BACKGROUND OF AREA OF REVIEW REQUIREMENT
The analysis assumes that new injection wells will be
placed in existing projects. This assumption is explained
'in Section D and acknowledges that most oil fields that
could be flooded are now under flood and that much of the future
growth in injection wells will come from the expansion
i
of existing projects. The program exempts both existing
ER injection and SWD wells from the area of review
requirement, thus it would appear that producing and
abandoned wells located near existing injection wells
would never be included in an area of review. This is
true only to the extent that existing ER injection or
SWD projects add no new injection wells after state
promulgation of a federally approved UIC program.
j
^
Most of the oil and gas-producing states do not have an
explicit requirement that completion or plugging records
of wells located nearby hydrocarbon related injection
wells be reviewed for the adequacy of cementing. As
discussed in Chapter IV, most states require that
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joperators submit plats that show the location and some-*
*
;times the depth and ownership of nearby wells. It is
i
'less frequently required that operators provide details;
'on the completion and plugging of these nearby wells.
|
iTwo notable exceptions to this are California and New
i >
.Mexico which both have an area of review requirement
;that includes a tabulation of nearby wells including
the specific details of their completion or plugging.
\
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(Generally the operator specifies repair action to the
regulatory agency when the permit is applied for. The
(state agency staff also reviews the completion or plugging
details and repair action, if different than that
specified by the operator, is ordered before permit
issuance. The nature of the repair action is therefore-
preventive in that it is required at the "front-end"
before the injection well or injection project permit
is issued. This position is different from many other
states where the emphasis is on remedial action at the
:time a nearby well becomes a problem.
V.B..R
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' J 3 2 2 H v c u *" I "-
^Sc'-^REC.^C'iC ^,'7'^"" "I
GpEuL OL^ CO"'" VV ,A -
The emphasis in the UIC regulation's area of review ;
requirement is preventative in concept and it is believed
that these regulations also allow for state regulatory
agencies to exercise judgement and reasonableness in
deciding which wells will need to be repaired.
'While most states do not have an explicit requirement
'that the records of nearby wells be reviewed and
i
(remedial action taken, this does not mean that operators
in those states never review nearby wells or take action
^on those that appear to have the potential for leaking.
There are in fact real economic incentives for ER
operators to ensure that the effect of their project
is not dissipated by leaking wells. To maintain or
increase reservoir pressure and drive the oil through
the reservoir, it is important that injected water goes
to and stays in the designated reservoir. The efficiency
of the project is reduced to the extent that injected
.water "leaks" through inadequately cemented producing
| ;
wells or improperly plugged abandoned wells. This
results in lower oil recovery and a higher than necessary
ratio of cost to revenue.
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!C. ANALYTICAL APPROACH AND LIMITATIONS OF THE ANALYSIS
To estimate the compliance cost of the area of review
requirement, it was necessary to develop estimates on
essentially three separate data components.
1. Number of Wells to be Reviewed
"This component includes estimates of both the number of;
producing wells and the number of abandoned wells that ,
.would be reviewed as part of the area of review require-
\
!ment for an estimated 20,000 new ER injection wells \
and 5,000 new SWD wells projected during the five-year
^analysis period.
2. Percent of Reviewed Wells that Require Remedial
Work
This component includes estimates of the percent of
those producing and abandoned wells that penetrate the
injection zone that would require action prior to permit
issuance. This action would be either testing and/or
cementing in the case of producing wells and reabandon-
ment in the case of improperly plugged abandoned wells.
j ;
1
! 3. Unit Costs
This component includes estimates of the unit costs to
comply with the area of review requirement: reviewing
'well records, testing and/or cementing producing wells
and reabandoning improperly plugged abandoned wells.
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iThe derivation of each of these data components is j
;explained in detail in three separate sections of i
i
this chapter. However, there are general comments that;
can be made about all three.
Because the proposed area of review requirement is not '
generally required by state regulatory agencies, there
=are only limited data available on which to base the
estimates of this incremental compliance cost. While
California and New Mexico have some experience with an
:area of review requirement, these states may not be
| typical of a national experience either because of the
im age and condition of their respective wells or the
regulatory stringency with respect to the enforcement
of their regulations.
| Many states require that nearby wells be reviewed and
repaired before permit issuance of industrial disposal
wells. In many cases this area of review has a radius
i
^from 2.0 - 2.5 miles. Because of the highly toxic
nature of the materials being disposed of, state
regulatory posture is considerably more stringent than
it would be in regulating hydrocarbon related injection
wells. So the experience in this area may overs tate
the need for action.
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3 2E USED FOR SCAr
D. ESTIMATED NUMBER OF WELLS IN AREA OF REVIEW
1. General Assumptions for Methodology
Although existing injection wells are exempted from the
area of review requirement, producing and abandoned
wells located nearby these estimated 140,000 existing
injection wells are not necessarily exempted. In fact,,
the majority of existing producing wells are all poten-
tially in the area of review of new injection wells.
]
.One reason for this is that new secondary recovery
injection wells (the majority of ER injection wells) ar-e
jlikely to be located in existing secondary recovery pro-
j
jects since it is believed that the vast majority of
oil fields that could respond to waterflooding are
currently under flood. The future increase in secondary
recovery activity therefore will come from the expansion
of existing projects by either the drilling of new :
injection wells or the conversion of producing wells
to injection wells.
!For other types of new ER injection wells (i.e., tertiary
'recovery), it is believed that in the main, they too
will be located in fields that are either now under
t
thermal-based tertiary recovery production (i.e., cyclic
or continuous steam projects in California), or under
V3E % 'JVSER
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secondary recovery. There are, of course, exceptions '
to this where tertiary recovery methods will be used
in fields after primary production when secondary
recovery methods are inappropriate.
On the other hand, new SWD wells could be located either
in existing ER projects or in existing primary production
fields (water-driven reservoirs) that depend primarily
on disposal wells to dispose of produced water rather
than on reinjection of produced water for secondary
recovery. It is not known how many existing SWD wells
:are located in ER projects and how many are located in
'primary production fields that produce from water-
driven reservoirs. To accommodate this unknown, a
simplifying assumption was made that there are no SWD
wells in existing ER projects even though it is known
that they are not mutually exclusive. These fields
producing from water-driven reservoirs shall be
preferred to as "salt water disposal projects" for the
I
jpurpose of this analysis.
While some existing ER projects may not be expanded by
the addition of new injection wells, it was not part of.
this analysis to identify the number or size of these
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projects. Therefore, it has been assumed that new ER I
[injection wells could be placed anywhere in existing
|ER projects. This assumption means that all producing '
I
:wells presently located in existing ER projects could
potentially be in an area of review of new ER injection:
wells. Likewise, it has been assumed that new SWD wells
could be located anywhere in existing salt water disposal
"projects" and that the producing wells presently
located in these "projects" might potentially be in an
area of review of new SWD wells.
Based on these assumptions, it was possible to develop
a framework that categorized all existing producing wells
as either (1) in or nearby ER projects, (2) in or near-
by SWD projects, or (3) geographically isolated from
either ER or SWD projects. It was assumed that not
more than 5% of all producing wells were geographically
isolated from either type of injection activity and that
the remaining 95% were in or nearby one or the other.
The location of existing abandoned wells is difficult
if not impossible to ascertain. Abandoned wells were
therefore assumed to be distributed in the same manner
as producing wells with respect to ER projects, SWD
projects, or in geographically isolated areas.
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Arthur D. Little, Inc. was requested to distribute the
compliance costs to ER and SWD well operators. With
respect to the area of review requirement, that meant
estimating how many producing wells would be in the
area of review of new ER injection wells and how many
would be in the area of review of new SWD wells. As
explained, new ER wells will be located in existing ER
i
iprojects and new SWD wells will be located in existing
1
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-SWD projects. Therefore, it was first necessary to
estimate how the 505,000 existing oil-producing wells
were distributed. The estimated distribution of oil-
producing wells into either ER or SWD projects was based
on two assumptions:
1. There is a positive relationship between
the number of producing wells in or nearby
ER projects and the amount of oil produced
from ER methods in any state.
2. There is an inverse relationship between
i the number of producing wells in SWD
projects and the amount of oil produced
from ER methods in any state.
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; 33 USED =CR SCANNER COPY OMLY
... J
JThe first assumption is that in states with a high
I 1
jpercentage of ER oil, there will be a greater number of!
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producing wells in or nearby ER projects than in states;
that have little or no ER oil. This assumption seems
reasonable since there would be a greater number of ER
producing wells in states that produce a greater amount,
of ER oil. The relationship is probably not linear
since it is believed that ER producing wells are less
efficient than primary producing wells. This means
.that if 10% of a state's oil is produced from ER,
.probably more than 10% of its producing wells are
involved in that recovery.
The second general assumption is that in a state with
little or no ER oil production, there will be a large number
of producing wells in or around SWD projects. With fewer
producing wells in or nearby ER projects there will be a
greater need to dispose of produced water through
disposal wells.
2. Number of Producing Wells in Existing ER
Pro jects
The Bureau of Mines published a report in 1977 entitled
Liquid Hydrocarbon Production in the United States,
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1946-1975 and 1980 Projected, Highlighting Enhanced
Recovery. This report provides information on the
total amount of crude oil produced as well as the
amount of crude oil produced from ER methods on a
state by state basis. These two pieces of information
were used to derive a percent of crude oil production
from ER methods for each state.
As shown in Table VIII-1, each of the thirty-one oil-
producing states was assigned into one of five groups.
The assignment criterion was the percent of the state's;
ER oil production. Each of the five groups was arbi-
trarily defined by some range in percent of ER oil
production. For example, the first group included all
states whose percent of production from ER methods
ranged from 70-100%; the second group included all states
whose percent of production from ER methods ranged from;
50-70% and so on. The fifth group included all states
that had essentially no ER oil production. It should
be remembered that the basis for this methodology was '.
1975 data. The current situation may be different,
but it is believed that it is not significantly
different given the projections for ER oil recovery in
1980 as contained in the Bureau of Mines circular.
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TABLE VI11-1
CLASSIFICATION OF OIL PRODUCING STATES BY PERCENT OF
1975 OIL PRODUCTION FROM ENHANCED RECOVERY1
Group
1
Range in Percent of
Production From
Enhanced Recovery
for Each Group
70-100
50-70
30-50
10-30
0-10
States
Percent of
Production From
Enhanced Recovery
by State2
Alaska (Pre-North
Slope)
Kentucky
Montana
Florida
New York
Wyoming
Illinois
Colorado
California
Alabama
Texas
New Mexico
Oklahoma
North Dakota
Indiana
Pennsylvania
Nebraska
Utah
Missouri
Arkansas
Mississippi
Kansas
West Virginia
Louisiana (Onshore)
Michigan
Virginia
South Dakota
Tennessee
Arizona
Nevada
Ohio
96
87
86
80
79
75
72
68
64
63
61
60
54
50
50
46
44
34
30
28
23
21
21
19
13
0
0
0
0
0
0
Group's Average
Percent of
Production From
Enhanced Recovery3
80
60
40
20
1. Enhanced oil production as defined by the Bureau of Mines: fluid injection methods included are
pressure maintenance, secondary, thermal and tertiary recovery.
2. Percent of enhanced oil production was calculated for each state by dividing total barrels of enhanced
oil production by total barrels of crude oi! production.
3. Each group's average percent of production was calculated as in 2 above. The average percent of
production for each group is also the mid-point for the group's range in percent of production.
Source: Arthur D. Little, Inc., estimates developed from U.S. Department of the Interior. Bureau of Mines
circular 8734: Liquid Hydrocarbon Production in the U.S., 1946-1975and 1980 Projected, High-
lighting Enhanced Recovery, 1977.
l I Ittlo Ir
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cc :;-- ;cซ,:-":
Having aggregated the states into these five groups, an|
| i
;average percent of ER oil production was calculated for
i
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ieach group. Actual production volumes were used to
:calculate each group's weighted average percent of ER
joil production. Interestingly, the average for each
i
group was also the mid-point of each group's range in
percent of ER production.
;This classification framework permitted two distinct
analyses first to derive an estimate of the number of :
producing wells potentially in the area of review of
new ER injection wells and secondly, to derive an ',
estimate of the number of producing wells potentially
in the area of review of new SWD wells. Having
established that the potential number of producing
wells that could be in the area of review of new ER
f -injection wells are all the producing wells that are
_ now in or nearby ER projects, this framework aided in
establishing such an estimate. The difficulty in
1
.estimating the number of such producing wells is that '
many producing fields are multi-zoned; therefore,
| producing wells that are under primary production could,
_ ^conceivably be in or nearby ER projects. Since these
primary producing wells might penetrate an injection
-73JT-
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zone and therefore be included in an area of review re-l
(quirement, they could not be ignored. Based on discussions
with industry in several of these oil-producing states
(mostly states in groups 1 and 2 on Table VIII-1) it
,was possible to estimate the percent of all producing
wells (primary, secondary, tertiary) that are in or
nearby ER projects.
These estimates are shown graphically in Figure VIII-1,
Curve (a). The vertical axis in this figure is the
percent of all oil-producing wells. The horizontal
axis is the percent of oil produced from ER methods.
The slope of Curve (a) is based on a composite of data
estimates and assumptions. The shape indicates that at.
0% ER oil production, there are no producing wells in
or nearby ER projects while at 80% ER oil production,
80% of all producing wells are in or nearby ER projects.
However, the slope of the curve is non-linear since the,-
first ER injection well placed in any given oil field
would include a disproportionately greater number of
producing wells assuming non-random placement. While
this general slope is probably correct, there is insig-'
nificant data to determine the extent to which this
curve is "bowed". However, in spite of its limitations,
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O)
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'o
-a
o
O
14
o
c
cu
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100
90
80
70
60
50
ฃ 40
30
20
10
(a) Percent of Oil Producing
Wells in or nearby Enhanced
Recovery Projects
(b) Percent of Oil Producing
Wells in or nearby Salt
Water Disposal Projects1'
_| I i L
10 20 30 40 50 60 70 80
Percent of Oil Produced from Enhanced Recovery
90
100
1
Curve (b) is derived from curve (a) such that their sum = 95% of all producing wells.
Source: Arthur D. Little, Inc., estimates.
FIGURE VIII-1 RELATIONSHIP BETWEEN PERCENT OF ENHANCED RECOVERY OIL PRODUCTION
AND PERCENT OF PRODUCING WELLS IN OR NEARBY ENHANCED RECOVERY
PROJECTS AND (B) IN OR NEARBY SALT WATER DISPOSAL PROJECTS
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it is reasonable and is a constructive framework for
estimating the number of producing wells that could
potentially be in an area of review of new ER injection;
wells .
Curve (a), in Figure VIII-1. was used to calculate the :
number of producing wells potentially in the area of
review. Table VIII-2 shows this calculation. The
percent of all producing wells read from the vertical
axis in Figure VIII-1 appears in the fourth column in
Table VIII-2. The estimated number of producing wells
that could potentially be in the area of review is then;
simply a product of the estimated percent and the actual
number of producing wells in each group.
;From this analysis, there are approximately 315,000
wells or 60% of all producing wells in the United States
that are in or nearby ER projects and therefore poten-
tially in the area of review of new ER injection wells.
j ;
3. Number of Producing Wells in Existing SWD
Proj ects
The same framework used to estimate the producing wells<
in ER projects was used to estimate producing wells in
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TABLE VI11-2
ESTIMATED NUMBER OF OIL PRODUCING WELLS POTENTIALLY IN THE
AREA OF REVIEW OF NEW ENHANCED RECOVERY INJECTION WELLS
State Group
1
2
3
4
5
Total
Group's Average Percent
of Production From
Enhanced Recovery
80%
60
40
20
0
Adjusted for 1978
Total Number
of Oil Producing
Wells in
Each Group
55,554
289,921
40,966
93,441
16,862
496,744
505,000
1. Figure VI11-1, curve A. depicts these estimates graphically.
2. The product of columns three and four.
Source: Arthur D. Little, Inc., estimates.
Estimated %
of Producing
Wells Potentially
in the Area
of Review1
80%
70
60
40
0
Estimated Number
of Producing Wells
Potentially in
the Area of Review2
44,443
202,944
24,579
37,376
0
309,342
314,600
_ปI
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SWD projects. The inverse relationship between percent!
i \
!of ER oil production and producing wells located in or j
i
jnearby SWD projects is predicated on the assumption \
', i
I that where there is little or no ER activity, produced '
j S
iwater must be disposed of through SWD wells. This saysj
i j
that there is a greater dependency on SWD wells in those
states with little or no ER oil production. This
inverse relationship is depicted graphically in Figure
i
', l
!VIII-1 , Curve (b) . Curve (b) is derived from Curve
(a); so that the sum of the two curves equals 95% of all
',
producing wells [If X = the percent of producing wells
in or nearby ER projects (Curve a) , 95 - X = the percent
of producing wells in or nearby SWD projects (Curve b).]
Curve (b) in Figure VIII-1 was used to calculate the
:number of producing wells that are in or nearby SWD
projects (or dependent on SWD wells). Table VIII-3
shows this calculation. The percent of producing wells,
read from the vertical axis in Figure VIII-1 appears in
i !
!the -fourth column in Table VIII-3. As shown, 95% of
all producing wells located in those states that have
no ER oil recovery (Group 5) will be dependent on SWD
wells to dispose of produced water. At the opposite
extreme, 15% of all producing wells will be dependent
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TABLE VI11-3
ESTIMATED NUMBER OF OIL PRODUCING WELLS
'DEPENDENT' ON SALT WATER DISPOSAL WELLS
State
Groups
1
2
3
4
5
Total
Group's Average
Percent of
Production from
Enhanced Recovery
60
40
20
0
Adjusted for 1978
Total Number of
Oil Producing Wells
55,554
289,921
40,966
93,441
16,862
Estimated % of
Producing Wells
Dependent on
SWD Wells1
15%
25
35
55
95
496,744
505,000
1. Figure VIII-1, curve 8. depicts these estimates graphically.
2. The product of columns three and four.
Source: Arthur D. Little, Inc., estimates.
Estimated Number
of Producing Wells
Dependent on
SWD Wells2
8,333
72,480
14,338
51,392
16,018
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on SWD wells in those states that have an average of
80% ER oil production (Group 1).
Given this analysis, there are approximately 165,000
producing wells that are dependent on SWD wells. However,
unlike producing wells in ER projects, it is believed
that the density of producing wells around SWD wells
is considerably less than producing wells around ER
injection wells. While it is not known exactly what
that density is, it was assumed that it was about half
that of producing wells around ER injection wells.
Therefore, a second curve was drawn that reflected, for:
every group, 50% fewer producing wells. Both these
curves are shown in Figure VIII-2. Curve (a) is the
percent of producing wells dependent on SWD wells, and
Curve (b) is the percent of producing wells that are
both dependent on SWD wells and potentially in the area.
or review. Using Curve (b) in Figure VIII-2, it was
possible to estimate the number of producing wells that,
would be in the area of review of new SWD wells. Tabled
VIll-4 shows this calculation. There are approximately5
83,000 producing wells that are potentially in the
area of review of new SWD wells, about half the number
of wells dependent on SWD wells.
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c
'o
D
TJ
O
O
"5
c
to
o
I
100
90
80
70
60
50
40
30
20
10
(a) Percent of Oil Producing Wells
Dependent on SWD Wells
(b) Percent of Producing Wells
in Potential Area of Review
of New SWD Wells (50% less
than curve a)
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10 20 30 40 50 60 70 80
Percent of Oil Produced from Enhanced Recovery
Source: Arthur D. Little, Inc., estimates.
90
100
FIGURE VIII-2
RELATIONSHIP BETWEEN PERCENT OF ENHANCED RECOVERY Ol L PRODUCTION
AND (A ) PERCENT OF PRODUCING WELLS DEPENDENT ON SALT WATER DISPOSAL
WELLS AND (B ) PERCENT OF PRODUCING WELLS POTENTIALLY IN THE AREA OF
REVIEW OF NEW SALT WATER DISPOSAL WELLS
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TABLE VIII-4
ESTIMATED NUMBER OF PRODUCING WELLS POTENTIALLY IN THE AREA OF REVIEW
OF NEW SALT WATER DISPOSAL WELLS
Group's Average
Percent of
State Production from
Groups Secondary Recovery
1 80%
2 60
3 40
4 20
5 0
Total
Adjusted for 1978
Total Number of
Oil Producing Wells
By Group
55,554
289,921
40,966
93,441
16,862
496,744
505,000
Estimated % of
Producing Wells
Potentially in the
Area of Review1
7.5%
12.5
17.5
27.5
47.5
Estimated Number
of Producing Wells
Potentially in the
Area of Review2
4,167
36,240
7,169
25,696
8,009
1. These percentages reflect 50% of the estimated 165,324 producing wells dependent on salt water disposal
wells (See Table VIII-3). These estimates are depicated graphically in Figure VIII-2, curve B.
2. The product of columns three and four.
Source: Arthur D. Little, Inc., estimates.
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; 4. Summary of Producing Wells in the Area of
' Review of New ER Injection Wells and New
: SWD Wells
;Based on the preceding analysis, 78% or approximately
397,000 producing wells are estimated to be reviewed
as part of an area of review requirement for new
injection wells (Table VIII-5). Of the 78%, 62% or
314,600 wells are included in the area of review of
; new ER wells and 16%, or 82,662 wells are included in
'the area of review of new SWD wells. Based on an
^estimate of 505,000 total oil producing wells, there ;
are approximately 108,000 producing wells that would not
be part of an area of review requirement. These 108,000
wells include 25,000 that were estimated to be the 5%
of producing wells that were geographically isolated
from either ER or SWD activity. The remaining approxi-'
mately 83,000 are estimated to be those producing wells
that are dependent on SWD wells for disposal of pro-
duced water, but unlikely to be reviewed because of the
;lower density of producing wells around SWD wells.
Another way of saying it is that there is a much
greater ratio of producing wells to SWD wells than
producing wells to ER injection wells where the ratio
is sometimes 1 to 1.
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TABLE VI11-5
PRODUCING WELLS POTENTIALLY IN THE AREA OF REVIEW
OF NEW ENHANCED RECOVERY INJECTION WELLS AND NEW
SALTWATER DISPOSAL WELLS
Number of Percent of Wells in
Area of Review of: Producing Wells Area of Review
New Enhanced Recovery
Injection Wells 314,600 62
New Salt Water Disposal Wells 82,662 16
Total Wells in Area of Review 397,2621 78
Wells Not in Area of Review 107,738 22
Total all Producing Wells 505,000 100
1. This estimate reflects the total number of wells that will be reviewed but goes
beyond the five year scope of this cost analysis. The number of producing
wells that will be reviewed by the end of year five of the U.I.C. program are
displayed in Table VI11-8.
Source: Arthur D. Little, Inc., estimates.
A rtki ir Pi I il-Ho In/"
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5. Number of Abandoned Wells in the Area
i
1 of Review
-Estimating the location of abandoned wells is more
difficult than for producing wells. Therefore, it has
been assumed that abandoned wells are distributed in \
" !
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'the same way as producing wells with one exception. Of
the 1.2 million abandoned wells "of record" it is
assumed that 25% or 300,000 wells (as compared to 5%
'of the producing wells) were located in geographically
isolated "abandoned" fields and therefore could not
'possibly be in an area of review. As shown in Table
VIII-5 for producing wells, Table VIII-6 shows for
abandoned wells "of record" the number that are poten-
tially in the area of review of new injection wells.
Sixty-two percent of the 900,000 abandoned wells, or
558,000 abandoned wells are potentially in the area
of review of new ER wells, and 16% of the 900,000, or
144,000 are potentially in the area of review of new
SWD wells.
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TABLE VI11-6
ABANDONED WELLS OF RECORD POTENTIALLY IN THE AREA
OF REVIEW OF NEW ENHANCED RECOVERY INJECTION WELLS AND
AND NEW SALT WATER DISPOSAL WELLS
Number of Percent of Wells in
Area of Review of: Abandoned Wells Area of Review
New ER Injection Wells 558,000 62
New SWD Wells 144,000 16_
Total Wells in Area of Review 702,0001 78
Wells not in Area of Review 198,000 22
Total Abandoned Wells of
Record not in Geographically
Isolated Fields 900,000 100
1. This estimate reflects the total number of wells that will be reviewed but
goes beyond the five year scope of this analysis. The number of abandoned
wells that will be reviewed by the end of the fifth year of the U.I.C. program
are displayed in Table VIII-9.
Source: Arthur D. Little, Inc., estimates.
A _*i
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:/V;.XJER CCPY -:-\L ,'
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! 6. Number of Wells in Area of Review in First
1 Five Years
Having established the number of total producing and
i
'abandoned wells that could potentially be in an area
jof review of new injection wells, it was necessary to
I
;estimate how many would be reviewed in each of the
first five years of the program.
I
'The total population of producing and abandoned wells
would not all be reviewed during the first five years
(of the program. Based on actual well location and
spacing data taken from maps of seventy-seven fields
in thirteen states, a computer program was designed to
estimate the percent of wells in a total population
jthat would be reviewed in each year given some number
of new injection wells per year. Appendix A of this
report explains in detail how this program was designed,.
The results of the computer program are shown in Table
.VIIl-7. As shown in this Table, if 140,000 new injection
j
jwells were added (equal to the existing number of
injection wells which would be added over 28 years at
5,000 injection wells per year), then 32% of all wells
.would be reviewed given a quarter-mile radius of review.
If the radius of review were a half mile, then 89% of
all wells would be reviewed.
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TABLE VI11-7
PERCENT OF WELLS REVIEWED
GIVEN 5,000 NEW INJECTION WELLS PER YEAR1
Percent of Wells Reviewed
Year
1
2
3
4
5
10
15
20
28
New
Injection Wells
5,000
10,000
15,000
20,000
25,000
50,000
75,000
100,000
140,000
If Radius is
Quarter-Mile
9%
17%
24%
31%
36%
57%
68%
72%
82%
If Radius is
Half-Mile
11%
21%
30%
38%
45%
69%
81%
86%
89%
1. See Appendix A for details on the derivation of these estimates.
Source: Arthur D. Little, Inc., estimates.
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THIS SHEET TQ 3E USED FOR SCAiNNcR COPY 0.VJLY
;Based on this computer program with 25,000 new injectioin
'wells, by the end of the fifth year (5,000/year) an
1
lestimated 36% of the total potential population of well
would be reviewed. Table VIII-8 shows the number of
;
'producing wells reviewed by the end of the fifth year>
i
'approximately 113,000 in the area of review of new ER
injection wells and approximately 30,000 in the area of!
ireview of new SWD wells.
.Table VIII-9 shows the number of abandoned wells reviewed
!by the end of the fifth yearapproximately 201,000
abandoned wells in the area of review of new ER injection
.wells and approximately 52,000 abandoned wells in the ;
iarea of review of new SWD wells.
Table VIII-10 is a summary of Tables VIII-8 and VIII-9
'showing both producing and abandoned wells in the area
of review of both ER and SWD wells.
E. REMEDIAL ACTION TO NEARBY WELLS i
1. Completion and Plugging Practices
.Completion and plugging practices have changed signifi
i
icantly since the beginning of oil production in this
country. Current regulations require that surface
i= riLMBER
jean
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TABLE VIII-8
PRODUCING WELLS IN THE AREA OF REVIEW
Quarter-Mile Total in
Area of Review of Total Potential Five Years
(36% of potential)1
New ER Injection Wells 314,600 113,256
New SWD Wells 82,662 29,758
Total Wells 397,262 143,014
1. Given a quarter-mile radius and 5,000 new injection wells/year an estimated
36% of all wells potentially in an area of review would be reviewed by the
end of the fifth year.
Source: Arthur D. Little, Inc., estimates.
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TABLE VI11-9
ABANDONED WELLS IN THE AREA OF REVIEW
Quarter Mile Total in
Area of Review of Total Potential Five Years
(36% of potential)1
New ER Injection Wells 558,000 200,880
NewSWDWells - 144,000 51,840
Total Wells 702,000 252,720
1. Given a quarter-mile radius of review and 5,000 new injection wells/year, an
estimated 36% of all wells potentially in an area of review would be reviewed
by the end of the fifth year.
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TABLE VI11-10
PRODUCING AND ABANDONED WELLS TO BE REVIEWED BY THE END OF THE FIFTH YEAR
New ER
Injection Wells New SWD Wells Total
Producing Wells 113,256 29,758 143,014
Abandoned Wells 200,880 51,840 252,720
Total Producing and Abandoned Wells 314,136 81,598 395,734
Source: Arthur D. Little, Inc., estimates.
A -.-U, ,f T^l I ittlo In/-
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THIS SHEET TC 3= USED FOH SCA.NiNER CCPY ONLY
casing be set below the lowest fresh water zone with
i
|cement circulated to the surface. Generally, current
regulations require that cement be set across all
producing zones as well as other fresh water zones not
protected by cemented surface casing. However, many ;
wells were drilled and plugged prior to adoption of
jthese standards. For example, some producing wells may
i
! not have cement across or above a producing zone becaus-e
jthe zone was thought to be economically infeasible to
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^produce at the time the well was completed. Changes
?
tin prices and the technology of secondary recovery,
(however, have made possible the recovery of oil from
'reservoirs that were not economical to produce under
Iprimary production practices.
jln older wells, surface casing was often not set to
'protect fresh water, and in the case of cable tool
'wells, when the well reached total depth, all of the
:outer casings were removed. The casings were not
'cemented because the cementing process had not been '
:invented. Therefore, producing wells whose completion
;was considered adequate at the time the well was
Completed are often considered "inadequately" completed!
i
'by today's practices and recovery activity. In addition
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THIS SliEET TO BE USED FOR SCANNER COPY ONLY
". to this, few people imagined pressurizing reserviors
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with gas or water when primary production was the only j
known recovery technique. i
Current plugging regulations require that bottom hole !
1
plugs be placed to assure that all oil> gas, and salt '
water will be retained in the producing formation.
Further cement plugs (100-150 feet thick) are required j
at the base of the surface casing with an additional
plug (25-50 feet thick) at the top of the surface
casing. In the past, some wells were plugged by filliag
the well bore with drilling mud and using cedar posts '
or a flat rock at the surface.
Many wells that have been abandoned since the adoption
jof more rigid state abandonment regulations have been
cut off from 3-10 feet "below plow depth" in recognition
of the surface owner's use of the land for agriculture.
!This practice means that it may be difficult to even
.locate abandoned wells before remedial action can be
:taken. Frequently there are not markers to show where
an abandoned well is located after it has been cut off,
i
and it is necessary to use metal detectors and
?
^heavy earth moving equipment to locate and gain access '
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FOR SCA.V'i-ER CCrY O^L -f
TO" aB"a~n"d' a'n a1 d1 ~w e i is~
tire
jwell is, it is sometimes necessary to build access roads
(in wetlands or marshy areas) on which to move heavy
equipment and rigs and/or to pay damages to surface ;
owners for access. The variables of well location and :
past abandonment practice can contribute to wide variation
in the cost to reabandon any given well.
Given the pressures required to drive the oil through
the reservoir, inadequately cemented wells may not be
able to withstand the added pressure and could become
'conduits for fluid migration into other producing zones,
j
i
to the surface, or potentially into fresh water zones.
^Based on estimates received from the EPA Regional Offices,
there are 15% or approximately 84,000 oil and gas pro-
ducing wells that do not have surface casing. Table VIII-11
shows these estimates. As shown, there are an estimated
103,000 producing wells or 19% that do not have cement
across zones below the fresh water zone except at the
jproduction zone. Table VIII-12 shows data on the percent
i
of producing wells that either have no cement at zones
.below the fresh water zone and/or have no surface casing.
.Table VIII-13 shows estimates on the percent of abandoned
we lls that h~a v e fT) no cement below tTFe fresh water zone ;
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TABLE VII1-11
SUMMARY OF U.S. OIL AND GAS PRODUCING WELL COMPLETION PROFILES
Producing wells cemented at the production
zone with surface casing through the fresh
water zone with cement below the fresh
water zone.
Producing wells cemented at the production
zone with surface casing through the fresh
water zone but without cement below the
fresh water zone.
Producing wells without surface casing.
Totals
Total Wells in
Respondent States1
363,116
102,773
84,318
550,207
Total Wells in
Non-Respondent Total Wells in
States United States
89,793
640,000
1. There were seventeen states that provided well completion profile information. The wells represented
by these respondent states are approximately 86% of all U.S. oil and gas producing wells.
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., July 1977.
Arthur D Little. Inc
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TABLE VIII-12
OIL AND GAS PRODUCING WELL COMPLETION PROFILES BY STATE - 1976
Percent of Producing Wells Cemented at the
Production Zone with Surface Casing Through
the Fresh Water Zone that have:
Cement Below the
Fresh Water Zone
100%
70
90
40
N.R.
95
100
40
N.R.
N.R.
100
N.R.
N.R.
25
N.R.
N.R.
N.R.
N.R.
40
<5
100
25
50
14
N.R.
N.R.
N.R.
75
N.R.
100
N.R.
No Cement Below the
Fresh Water Zone
0%
0
10
25
N.R.
0
0
60
N.R.
N.R.
0
N.R.
N.R.
60
N.R.
N.R.
N.R.
N.R.
60
<5
0
60
50
11
N.R.
N.R.
N.R.
25
N.R.
0
N.R.
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
N.R. = No Response
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., July 1977.
Percent of
Producing Wells
Without
Surface Casing
0%
30
0
35
N.R.
0
0
0
0
N.R.
0
0
N.R.
15
N.R.
N.R.
N.R.
N.R.
0
>75
0
15
0
75
N.R.
N.R.
N.R.
0
N.R.
0
N.R.
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TABLE VIII-13
ABANDONED WELL COMPLETION PROFILE BY STATE - 1976
Percent of Abandoned Wells Plugged Below
Fresh Water Zone With Surface Casing Through
State
Texas
Louisiana
California
Oklahoma
Wyoming
New Mexico
Alaska
Kansas
Mississippi
Utah
Florida
Colorado
Montana
Illinois
Michigan
North Dakota
Arkansas
Alabama
Ohio
Kentucky
Nebraska
Indiana
Pennsylvania
West Virginia
New York
Tennessee
Arizona
South Dakota
Nevada
Missouri
Virginia
Cement Below the
Fresh Water Zone
90%
70
90
40
N.R.
95
100
90
N.R.
N.R.
100
N.R.
N.R.
10
N.R.
N.R.
N.R.
N.R.
10
<5
100
25
2
10
N.R.
N.R.
N.R.
75
N.R.
99
N.R.
No Cement Below the
Fresh Water Zone
0%
N.A.
10
20
N.R.
0
0
10
N.R.
N.R.
0
N.R.
N.R.
30
N.R.
N.R.
N.R.
N.R.
5
<5
0
35
3
10
N.R.
N.R.
N.R.
15
N.R.
1
N.R.
Without
Surface Casing
10%
28
0
15
N.R.
0
0
0
0
N.R.
0
N.R.
N.R.
35
N.R.
N.R.
N.R.
N.R.
85
N.R.
0
30
95
80
N.R.
N.R.
N.R.
7
N.R.
0
N.R.
IWl 1 IUIJ\JQU
Below the
Fresh Water Zone
0%
2
0
25
N.R.
0
0
0
0
N.R.
0
N.R.
N.R.
25
N.R.
N.R.
N.R.
N.R.
0
N.R.
0
10
0
0
N.R.
N.R.
N.R.
3
N.R.
0
N.R.
N.R. = No Response
Source: EPA Regional Office estimates as reported to Arthur D. Little, Inc., July 1977.
i ir Pt I it-tip Inr
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1(2) have no surface casing; and (3) are not plugged '
| 4
:below the fresh water zone. Table VIII-14 shows that 8%
|or approximately 90,000 abandoned wells of record are !
jnot plugged below the fresh water zone and do not have j
jsurface casing. There are also approximately 103,000 '
! i
[abandoned wells, or 9% of the total, that are plugged
below the fresh water zone and have surface casing but
do not have any cement across other zones below the fresh
water zone. It is possible that if abandoned wells
.plugged in this manner penetrated an injection zone,
water could migrate vertically into other zones if not .
a fresh water zone. It is impossible however to estimate
precisely where these higher risk abandoned wells are
located--whether they are geographically isolated, in
.non-productive fields, or in active fields. Another
'important question is whether or not these higher risk
wells are also shallow wells and therefore do not even
penetrate an injection zone. If they are shallow wells,
.then there would be an overall lower cost for reabandon-
ment since shallow wells would probably not pose a threat
in terms of leaking from an injection zone.
2. Abandoned Wells in the U.S.
Table VIII-15 shows the number of abandoned wells from
1959 to 1974. It has been estimated by knowledgeable
industry individuals that the majority of wells abandoned
prior to 1930 are improperly plugged. If this were
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TABLE VIII-14
SUMMARY OF U.S. WELL COMPLETION PROFILES FOR
ABANDONED WELLS OF RECORD
Abandoned wells plugged below the fresh
water zone with surface casing through
the fresh water zone and cemented below
the zone.
Abandoned wells plugged below the fresh
water zone with surface casing through
the fresh water zone but without cementing
below the zone.
Abandoned wells plugged below the fresh
water zone but without surface casing.
Abandoned wells not plugged below the
fresh water zone and without surface
casing.
Totals
Total Wells in
Respondent States1
704,294
102,604
229,941
89,908
1,126,747
Total Wells in
Non-Respondent
States
Total Wells in
United States
73,253
1,200,000
1. There were seventeen states that provided well completion profile information. The wells represented
by these respondent states are approximately 95% of all U.S. abandoned wells of record.
Source: EPA Regional Office estimates as reported to Arthur D, Little, Inc., July 1977.
Arthur D Little. Inc
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TABLE VIII-15
NUMBER OF ABANDONED WELLS IN
THE UNITED STATES, 1859-1974
(Includes Dry Holes)
Years
1859-1890
1891-1900
1901-1910
1911-1920
1921-1930
1931-1940
1941-1968
1969-1974
Abandoned Wells
47,314
40,436
107,758
92,821
161,010
125,706
874,263
198,353
Cumulative
47,314
87,750
195,508
288,329
449,339
575,045
1,449,308
1,647,661
Source: American Petroleum Institute data:
Petroleum Facts and Figures, 1971 Edition;
Annual Statistical Review, 1965-1974.
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THISSHEcT 'C 2ฃ JStD "OR 3CA-\,McR COPY ONLY
;true, there would be approximately 450,000 improperly
iabandoned wells. However, wells completed prior to
I the 1900's (88,000 wells) are generally no deeper than
j
,2,500 feet and therefore possibly too shallow to be of
|concern. If all these wells are too shallow to be of
:concern, there are still 362,000 that are improperly
|plugged, perhaps located in active fields and penetrate
|an injection zone.
There are 1,200,000 abandoned wells of record. It has ;
'been assumed that 25%, or 300,000 of these, are in :
.geographically isolated non-productive fields. If all
of these 300,000 wells are among those 362,000 that
were abandoned between 1900 and 1930, there would still.
be 62,000 located in active fields. If this were true,
these 62,000 wells would represent 7% of the estimated
900,000 abandoned wells that are assumed to be in
active fields.
j
! 3. Producing and Abandoned Wells Requiring '
Remedial Action
New Mexico and California have area of review require-
ments that are somewhat comparable to those proposed in,
the UIC program. State regulatory agency orders for
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remedial action are generally based on how many sacks ;
of cement were used and where the cement if located. :
JSince abandoned wells cannot be tested, they are ordere;d
to be reabandoned if there is inadequate cement (as
i
jshown from the plugging records) to prevent fluid
[migration. In the case of producing wells, testing
:for potential fluid migration is not always allowed.
j
, Producing wells whose completion records show insuffi-
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jcient cement across or above injection zones are
j
.generally ordered to be recemented prior to the
issuance of a permit for injection. The state regula-
tory posture often requires repair before there is a
problem, not when there a problem. The regulatory
posture may be more stringent in these states than the
posture that either exists now or would be adopted in
:other states after the promulgation of a federal UIC
program. Therefore, experience in these states may
not reflect a national experience.
JThe age and condition of wells in New Mexico and Cali- :
fornia also may not be typical of the national experience.
.There are considerably older producing areas whose
;wells might presumably require more remedial action.
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- , .S E Z =O P ฃC.-'ป,"'; M 5 R C C ? Y C NIV
Based on the experience in these two states, from 6-11%!
of the producing and abandoned wells have required j
either recementing or reabandonment before an injection^
project permit was issued. Arthur D. Little, Inc.
contacted state agency officials and major producers ;
I
in these two states to discuss their actual experience
:since the area of review requirements have become
:mandatory.
Many oil and gas producing states do have an area of
review requirement for obtaining permits for industrial,
.disposal wells. Subsurface, Inc. provided data from
five fields in Texas and one field in Louisiana. Table'
.VIII-16 shows that 32% of the producing wells are
inadequately cemented and 15% of the abandoned wells,
.for which there were records, were improperly plugged.
There were no records for 19% of the abandoned wells.
Because of the location of disposal wells and the
jhighly toxic nature of the disposed fluids, attitudes
toward risk are very different than for hydrocarbon
related injection wells. These estimates are therefore:
'probably higher than if the injection fluids, volume
;and/or pressures were those typical of hydrocarbon
i
related injection wells.
-GS NUMBER
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TABLE VIII-16
PRODUCING AND ABANDONED WELLS NEAR INJECTION WELLS1
Producing Wells
Abandoned Wells
Total
30
26
21
0
1
1
79
Inadequate
Wells
5
20
0
0
0
0
25
Cement
Percent
17%
77
0
0
0
0
32%
Total
162
21
88
8
25
26
330
Inadequate
Wells
g
12
19
3
1
5
49
Plugging
Percent
6%
57
22
38
4
19
15%
No
Wells
29
0
19
2
5
0
62
Records
Percent
18%
0
22
25
20
0
19%
Field
Bill Hill Field
(Jefferson County, Texas)
Clear Lake Field
(Harris County, Texas)
Corpus Christi, Texas
Channel View Field
(Harris County, Texas)
Matagorda County, Texas
Luting, La.
Total
1. Surveys of producing and abandoned wells within 2 1/2 miles of six proposed industrial disposal wells.
Adequacy of cementing or plugging as determined by current state regulations.
Source: Subsurface, Inc., estimates, July 1978.
Arthur P) I \tt\f I
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"-H5 3hฃc;~ TO 3E USED FOR iC,--Viฃ3 CCPY ONLY
i 4. Percent of Wells Requiring Action for Cost j
] j
Analysis i
, I
j ;
iBased on data received from EPA regional offices, ;
; i
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-.state regulatory agencies and major and independent !
i !
joil producers, it was necessary to estimate the percent,
j j
i '
jof producing and abandoned wells that would require
iremedial action on a national level.
a. Wells in Area of Review of New SWD Wells '
; It is estimated that 7.5% of all abandoned wells, that
:penetrate the injection zone of new SWD wells, will not:
be able to demonstrate either adequate cement or the
lack of fluid migration and will require reabandonment..
lit is estimated that 10% of the producing wells in the
area of review of new SWD wells will either have to be
tested or recemented. Of this 10%, 90% will be allowed;
to test for nonmigration and 10% will require recementing
with no testing allowed. Of those 90% that are tested,!
I
jonly 10% will be unable to demonstrate non-migration '
|
lor present compelling evidence (formation characteristics,
etc.) of non-migration. Table VIII-17 shows this
assumption. There are, therefore, approximately 2% of
;all producing wells in the area of review of new SWD
wells that will require recementing.
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TABLE VIII-17
PRODUCING WELLS IN AREA OF REVIEW OF NEW SWD WELLS
REQUIRING TESTING OR RECEMENT1NG
90%
90%
10%
Percent of Wells
Required to Test
or Recement
9.0% of Wells
Test for Non-Migration
8.1% of Wells
Demonstrate Non-
Migration
10%
0.9% of Wei Is
Recement
10%
1.0% of Wells
Recement with No Test
Source: Arthur D. Little, Inc., estimates.
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3 Cl-r c s TC 3E UScD FCR SC^ir-jER CCPY C^L
b. Wells in Area of Review of New ER :
Injection Wells
It is assumed that wells in ER projects will overall be-
25% less likely to need remedial action as part of an
area of review requirement than wells located in SWD !
projects. This assumption is based on the belief that I
operators of ER projects will have performed more
remedial repair work to nearby wells. Enhanced recovery
!
,is usually a unitized operation where the operator has ,
\y , an economic incentive to make sure that the injected
;fluid is not dissipated through leaks through nearby
wells. Therefore, the likelihood of producing and
abandoning wells near new ER injection wells requiring '
remedial action is 25% (75% of the experience in SWD
projects) less than for the same wells nearby SWD wells;.
It is estimated that 5.6% (7.5% x .75) of abandoned
wells penetrating the injection zone cannot be shown
;to have adequate cement and will require replugging.
1
J7.5% (10% x .75) of existing producing wells in the :
area of review will require testing and/or recementing.
Of this 7.5%, ,90% will test for non-migration and 10%
will require recementing without testing. Of those
.tested, 90% will be able to demonstrate non-migration
-AGt .NljMSE
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(or present compelling evidence of non-migration (for-
5
!
jmation characteristics) and 10% will not be able to
demonstrate non-migration and will require recementing
This assumption is shown in Table VIII-18.
F. UNIT COSTS
1. Costs to Review Well Records
In many states, completion and plugging records are
maintained in central files (for example, Texas Rail-
road Commission files of completion and plugging recordls
are kept in Austin, Texas) and not at local district
'offices. Access to these records is not always easy
due to the location of the records and idiosyncracies '.
in filing systems that those unfamiliar to the system
would be unaware of. The centralization of such records
:would require that an operator in search of a record
either travel to locate the record or seek commercial
assistance to search, locate and copy the record. In
.most cases it would be more economical to have a service
j i
jcompany whose staff is familiar with an agency filing
.system locate and copy required well records.
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TABLE VIII-18
PRODUCING WELLS IN AREA OF REVIEW OF NEW ER WELLS
REQUIRING TESTING OR RECEMENTING
90%
90%
7.5%
Percent of Wells
Required to Test
or Recement
6.8% of We I Is
Test for Non-Migration
6.1% of Wells
Demonstrate Non-
Migration
10%
0.7% of Wells
Recement
10%
0.8% of Wells
Recement with No Testing
Source: Arthur D. Little, Inc., estimates.
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iMost operators have most of the well records for wells
j located on their lease (if they are available or exist;
Lease operators have no legal right to obtain from
I
joffset operators (e.g., operators of contiguous leases)
i
I the records of wells on offset leases that may be ,
!
included in an area of review. If producing and
abandoned wells were located on an offset lease, the
operator would have to go to public sources to obtain
well records if the offset operator refused to provide
them.
:It is estimated that on the average it would cost $17
per producing well record and $50 per abandoned well
record to locate and review. It is believed that the
,search for abandoned well records will be more difficult
'and therefore more expensive.
2. Costs to Recement and Test Producing Wells
iThe cost to test existing producing wells for fluid
;migration is estimated to be $2,500 and $30,000 to
1
recement.
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G 3E U3ฃD FOR
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j 3. Costs to Reabandon Plugged Wells \
i ;
jThe costs to reabandon an improperly plugged well ranges
! .
I ,
jfrom an average of $10,000 to $40,000 although there :
s
are occasional excursions up to as much as $500,000 per'
well. The unit cost used in this analysis is $20,000
per well. This figure assumes fairly easy location and
access, little hidden difficulty performing the work,
^and little or no damages paid to surface owners. Tables
;VIII-19 and VIII-20 show cost estimates for well re-
abandonment obtained by Arthur D. Little, Inc.
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TABLE VIII-19
PROCEDURE AND COST TO RE-ENTER IMPROPERLY PLUGGED AND
ABANDONED WELL AND RE-ABANDON
Procedure:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Survey and stake location with best possible data available
Try to locate casing with magnetometer or probes.
Dig out and find casing.
Move in and rig up suitable rig.
Drill out plugs using mud weights as were used on original
Circulate hole clean
Pull out and run in with drill pipe open ended.
Set cement plug (150' to 200') above lowest possible zone
.
drilling.
Set plug below base of fresh water and 100' into surface pipe.
Set plug (25'-50') at top of surface pipe.
Cut off casing and install marker.
Percent of
Cost
1.
2.
3.
4.
5.
6.
Total
Estimate:
Surveying and search S1,500-$1 0,000
Road work and location 5,000- 25,000
Rig Cost 72-1 12 hours @$150/hr. 10,800- 16,800
Rig- move in and out 8,000-15,000
Set plugs 3,200- 5,200
Mud and mud materials 4,000- 8,000
S32,500-$80,000
Total
Low
5
15
33
25
10
12
100
Cost
High
13
31
21
19
6
10
100
Source: Subsurface, Inc., estimates, January 1979.
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TABLE VI11-20
ESTIMATED COSTS FOR TYPICAL WELL
RE-ABANDONMENT OF
IMPROPERLY PLUGGED WELLS
Source Estimated Cost
Subsurface, Inc. $32,500-$80,000
Major Oil Producer
S.E. New Mexico $25,000-$ 100,000
Major Oil Producer average of $10,000-$20,000,
West Texas and up to $80,000
Major Oil Producer
West Texas $15,000-$25,000
Major Oil Producer
California $20,000-$40,000
Major Oil Producer
West Texas $50,000
Major Oil Producer
California $50,000
Sources: Representatives of major oil producing companies and
Subsurface, Inc., as reported to Arthur D. Little, Inc.
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G. COMPLIANCE COSTS
The five-year costs for operators of new SWD wells is
as follows:
Item
Review records
on completion
of producing
wells
Review records
on plugging of
abandoned wells
Remedial action
to abandoned
wells
Test and recement
producing wells:
Test (no fluid
migration)
Recement
Number of
Wells
29, 75!
51,840
3 , 888
2 ,678
565
TOTAL
Unit Cost
($)
$1 7
$50
$20 , 000
$ 2 ,500
$30,000
Total Cost ;
for {
Five Years S
($000) !
$505
$2,592
$77,760
$ 6,695
$16 ,950
$104,502
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HiS $;- ::c7 TO 32 US5D FOR 3C VJTiER COPY 0*;!
'The five-year costs for new ER injection well operators!
i
.is as foHows :
Number of Unit Cost
Item
Wells
!* Review records
i on completion 113,256
of producing
we 11s
a Review records
on completion 200,880
\ of abandoned
we 11s
^ Remedial action
to abandoned 11,250
wells
> Test and recement
producing wells:
' 3 Test (no fluid
migration) 7,645
Recement
1,614
($}
$17
$50
$20,000
$ 2 ,500
$30 ,000
Total Costs
for
Five Years
($000)
$1,925
$10 ,000
$225 ,000
$ 19,112
$ 48 ,420
TOTAL
$304 ,502
,Table VIII-21 provides a detail of the calculation
!of the compliance costs for area of review.
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C5,734
ducing
and
Abandoned
ฃVe
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TABLE VI11-21
COMPLIANCE COSTS FOR AREA OF REVIEW
Source: Arthur D. Little, Inc., estimates.
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29,758 Reviewed
2,678 Test/No Migration
30,000
113,256 Reviewed
7,645 Test/No Migration
1,614 Recement
51,840 Reviewed
3,888 Reabandoned
200,880 Reviewed
11,250 Reabandoned
Grand Total
Unit Cost
$
17
2,500
30,000
17
2,500
30,000
50
20,000
50
20,000
Total Cost
($000)
505
6,695
16,950
1,925
19,113
48,420
2,592
77,760
10,044
225,000
409,004
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THIS ShfcET TO 3E 'JSED FOR SCANNER COPY ONLY
ELEW-.T '73 DPCCuRIER ' 2 MCD! = :-K
SF-iC;v;G DOUBLE
\'AHQi\iS '': INCHES J3OPCERS ,rJDi Z\
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A'HITE CUT OR USE CCRRE
LSE 2 HVPHSNS
v>SE A RED PENCIL OCT ป
SPELL OUT COMPANY NAV
USE RED PENCIL
CHAPTER IX
EXISTING INJECTION WELLS--TESTING AND REMEDIAL ACTION
A. INTRODUCTION
i
This chapter details the non-recurring costs to industry
for testing and, where necessary, taking remedial action
to existing injection wells. An existing injection well,
as defined in 40 CFR Part 122.3, is any injection well j
in operation prior to the effective date of the state
i
UIC program. While state programs will undoubtedly j
i
become effective over a span of many months, for pur- ,
poses of this analysis, existing injection wells are ;
defined as the projected population of injection wells i
as of December 31, 1979.
At a minimum, the proposed regulations require that each
injection well demonstrate "mechanical integrity." This
requires both a test to verify that there are no leaks
in the casing and a review of well records to determine;
the adequacy of cement at the injection zone to prevent!
s
fluid migration. The Figure IX-1 details the critical '
decision path required of each injection well operator. The
analysis in this chapter will determine the costs associated
with each branch of the decision diagram.
PAGE NUMBER
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'JO DOUBLE
'-JS- 1 2 INCHES I'BORDfcRS INDICATED'
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^SCn.MG TAPE
ป
B. ANALYTICAL APPROACH
Using the well population projections and assumptions
Jin Chapter VII, there are about 39,350 existing SWD wel
Is
jand about 100,300 existing ER injection wells to which
^
this analysis will apply. The basic approach to estima,-
i
'ting the cost of compliance has been first, to develop
appropriate well population figures, second, to estimate
incremental unit cost of compliance, and third, to multi-
ply the affected well population by the appropriate unit
cost to produce the total incremental cost of compliance.
C. DATA
1. Well Population Data ;
Information from Chapter IV on the current profile of '
i
injection wells was used to develop estimates of the ,
number of wells subject to remedial action. This infor1
mation is summarized in Table IX-1 for SWD wells and in
Table IX-2 for ER injection wells. These data were de-,
veloped during field interviews and is a composite of
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TABLE IX-1
EXISTING SALT WATER DISPOSAL WELLS WITHOUT CEMENT
BETWEEN THE INJECTION ZONE AND THE FRESH WATER ZONE
Class C, D and E wells do not have cement between the injection zone and the
fresh water zone. 50% of these wells are located in the Illinois Basin or in
Appalachia.
50% of these wells (mostly those in Class C) will be able to present compelling
evidence demonstrating the lack of fluid migration.
Class A B C D E Total1
Number of Wells 19,387 10,919 6,294 8 24 36,632
The remaining 50% will be tested for fluid migration. Experience in the field
indicates that 90% of wells so tested will demonstrate no fluid migration. This
is primarily the result of the formation collapsing in on the casing and forming a
solid bond.
1. Total reflects only 93% of all salt water disposal wells.
Source: Arthur D. Little, Inc., estimates.
-------
TABLE IX-2
EXISTING ENHANCED RECOVERY INJECTION WELLS WITHOUT
CEMENT BETWEEN THE INJECTION ZONE AND THE FRESH WATER ZONE
Class C, D and E wells do not have cement between the injection zone and the
fresh water zone. 70% of these wells are located in the Illinois Basin (28%),
Appalachia (16%) or California (26%).
50% of these wells (mostly those in Class C) will be able to present compelling
evidence demonstrating the lack of fluid migration.
Class
Number of Wells
A
51,479
B
22,712
C
20,434
D
935
E
528
Total1
96,088
~ 23%
The remaining 50% will be tested for fluid migration. Experience in the field
indicates that 90% of wells so tested will demonstrate no fluid migration. This
is primarily the result of the formation collapsing in on the casing and forming
a solid bond.
1. Total reflects only 96% of all enhanced recovery injection wells.
Source: Arthur D. Little, Inc., estimates.
Ar-t-Ki iซ- F^ I it-tie. lt-i/~
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P36RS INDICATED'
3ULLSTS.
ADL.
WHIT- OUT OF
USE 2 HYon-MS
USE A RED PEN
SPELL OUT CCM
USE RED ?ENJC:
actual observations and estimates made by field operators
i
As indicated in the tables, these estimates will be used
to determine the number of injection wells subject to
a fluid migration test.
Since all injection wells require a test for casing leaks
i
jand a review of well records for cementing adequacy, the
j |
only other estimates required are for the number of
wells expected to fail either the leak or fluid migration
I
test. As detailed in Chapter VII, a failure rate of 10%
i
was used for the fluid migration test. This estimate (
was developed from actual field experience as well as
assessments by injection well operators. Failure ;
rates for the leak test vary according to injection well
type and construction.
2. Unit Cost Data
Information on the cost of testing and repairing in-
ijection wells is contained in Tables IX-3 through IX-8..
i
!
The engineering firm, Subsurface, Inc., of Houston, j
I
Texas, supplied many of the cost estimates while others!
were generated from field interviews with industry. All
of the unit costs are in some way dependent on the depth
of the well being tested or repaired, and many are de- ;
E \lU.V.BER
-------
TABLE IX-3
SURFACE MONITORED DOWIMHOLE TESTS TO
DETECT CASING LEAK IN INJECTION WELLS
3,000 Feet 5,000 Feet 7,000 Feet
Spinner survey $1,210 $1,530 $1,850
Temperature survey 1,150 1,450 1,750
Noise log 1,240 1,600 1,950
Source: Subsurface, Inc., estimates.
A rtl-ii ir P> I it-tie. ln<~
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TABLE IX-4
SURFACE MONITORED DOWNHOLE TESTS TO
DETECT MIGRATION OF FLUIDS ALONG THE
EXTERIOR OF AN INJECTION WELL
2,000 Feet 5,000 Feet
Temperature Survey $1,690 $2,170
Noise Log 1,430 2,300
Radioactive Tracer Survey 1,790 2,270
Source: Subsurface, Inc., estimates.
Arthur Pi I i
-------
TABLE IX-5
COST OF SQUEEZE CEMENTING INJECTION WELL
Depth of Interval to be Cement Squeezed
Rig Operation
Materials
Services
Rentals
Miscellaneous
1,500 Feet
$ 3,700
1,700
6,000
3,000
4,500
3,000 Feet
$. 6,500
2,100
7,200
3,400
5,200
5,000 Feet
S 8,000
2,500
9,600
5,000
6,700
Total Cost $18,900 $24,400 $31,800
Source: Subsurface, Inc., estimates.
Arthur DI .ittle Inr
-------
TABLE IX-6
COST OF DRILLING NEW INJECTION WELL -
2,000 FEET
Low Range High Range
Rig Operation $ 48,600 $ 63,200
Materials 74,400 96,700
Services 34,000 44,200
Design and Procurement 27,400 35,600
Contingency 15,600 20,300
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Total $200,000 $260,000
Source: Subsurface, Inc., estimates.
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TABLE IX-7
COST OF DRILLING NEW INJECTION WELL -
5,000 FEET
Low Range High Range
Rig Operation $121,500 $158,000
Materials 186,000 241,800
Services 84,500 110,500
Design and Procurement 68,800 89,000
Contingency 39,200 50,700
Total $500,000 $650,000
Source: Subsurface, Inc., estimates.
Arthur DI ittlelnc
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TABLE IX-8
INDUSTRY ESTIMATES FOR THE COST OF TESTING
AND REMEDIAL ACTION TO INJECTION WELLS AS
REPORTED TO ARTHUR D. LITTLE, INC. IN
FIELD INTERVIEWS
Surface Monitored Downhole Tests $ 500-$ 3,000
Repair Small Leak in Casing $ 8,000-$ 40,000
Isolate Injection Zone (Prevent
Fluid Migration) $11,000-$ 80,000
Drill New Injection Well $70,000-$500,000
Source: Arthur D. Little, Inc.
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
CHANGES.
%G GASHE3.
3ULLETS
AOL.
EDITING
uSc A RED r>E,\C:L DOT ป
SPELL CUT COMPANY >-|Ai'v,=
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Ipendent on the specific geography and geology of the j
jarea. Accordingly, the national average unit costs were
(developed with consideration of the various impacts of j
jkey factors such as geology, geography, depth, and age j
of the well.
For example, while all wells will have to be reviewed for
1 j
jthe adequacy of cement at the injection zone, it was j
! !
;felt that most "newer wells" would not only have adequate
t
j !
irecords, but would also have been adeauately cemented. '
t ~ '.
isince most of these newer wells also tend to be deeper |
'wells, it can be argued that the shallower, older wells?
i '
;will be those most subject to a fluid migration test. i
I i
iThus, the estimated unit cost of $1500 was based on data
] \
'for shallower wells as indicated in Table IX-4. On thei
'other hand, since all wells are required to conduct a [
imechanical integrity test to demonstrate no casing leaks,
;the cost of testing a middle depth well was selected as;
representative. !
i
While a casing leak may occur anywhere between the sur--
face and the injection zone, it is clear that average
depth for repairing a casing leak will be less than that
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USE A RED PENCIL CCT ป
SPELL OUT COMPANY NAV5
USE RED PENCIL
{for sealing off-the injection zone. Thus, the cost for
i
(placing a cement seal at the injection zone was esti-
|
jmated at a greater depth than the average cost for re-
jpairing a casing leak. Finally, the average cost for ]
Abandoning an injection well and drilling a new one was!
I !
'estimated by carefully considering that most of the wells
i
to which this estimate would apply are located in older',
^shallow producing areas, such as Appalachia and the '
i ;
'Illinois Basin. For these areas, field interview data i
i !
iwere used to extend the lower end of the cost range to j
i
'about $70,000, a cost which is not atypical for new wells
.in these areas.
IWhile these costs were not developed as averages, they may
;be considered typical if obtained from a large enough sample
sof affected injection wells. However, they are not intended
[to account for very high cost excursions as a result of'
'particular problems with a single well. Experience in
;California indicates that under such conditions, the ;
'.regulatory agency may allow an exception to a specific ;
AGE DUMBER
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USE -.111 ( NOT c. 1 1 )
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USE A RED PENCIL DOT ซ
SPELL OUT COMPANY NAME
USE RED PENCIL
requirement by requesting that the operator monitor
this particular well more frequently. Therefore, it
may be said that these unit cost estimates include an
element of reasonableness on the part of the operator,
the testing service, and the regulatory agency.
D. ANALYSIS
1. Salt Water Disposal Wells
Figure IX-2 details the cost of testing SWD wells for
casing leaks. SWD wells with tubing and packer will be
allowed to use a pressure test of the annulus as a test
for leaks. This is a relatively simple process which
may not even involve taking the well out of service.
Annular injection wells and wells without tubing and
packer must perform the more complicated testing pro-
cedure which, in most cases, involves shutting down the
well during the test. The total cost of this requirement
for SWD wells is about $28.2 million. \
}
The cost of remedial action to SWD wells failing the j
mechanical integrity test is detailed in Table IX-9. ;
While a typical failure rate for SWD wells has been
t
estimated at about 5%, wells with tubing and packer j
have experienced a significantly reduced failure rate !
?AGE NUMBER
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-------
TABLE IX-9
COST OF REMEDIAL ACTION FOR WELLS FAILING CASING LEAK TEST
EXISTING SALT WATER DISPOSAL WELLS
SWD Wei Is with
Tubing and Packer
Annular Injection Wells
Population
20,965
11,400
Number
Requiring
Failing Test Action
1%
5%
210
570
Unit Cost
($)
$25,000
Cement squeeze
Will elect not to
repair and
cease injection
Total Cost
($000)
$ 5,250
SWD Wells without
Tubing and Packer
6,990
5%
Source: Arthur D. Little, Inc., estimates.
350 $25,000
Cement squeeze
$ 8,750
Grand Total $14,000
A -i.\
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THIS SHEET TO 3E USED FOR SC.^iNcR COPY ONLY
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as a result of the added internal protection. Failure
of the tubing, while certainly not routine, would be
s
detected during normal well monitoring and repaired or j
replaced as required. This action is not a result of ]
j
federal or state regulation, but is standard industry
practice. Most states are phasing out annular injection
wells either when a permit expires or a special problem)
i
i
is detected. For this reason, it has been assumed that!
(operators will not either be allowed to or want to re- '
pair an annular injection well if a leak is detected. j
j
Injection fluids from the annular well will have to be !
l
re-directed. No additional cost has been estimated for!
locating and transporting this injection fluid to a newi
well. Total cost for this remedial action to repair !
leaks in SWD wells has been estimated to be about $14 j
million. !
t
Figure IX-3 details the cost of fluid migration testing]
and required remedial action. Over 90% of existing SWDj
wells will be able to demonstrate, either with adequate)
cement or other compelling evidence, no potential for <
fluid migration. The remaining wells will have to con--
\
duct a fluid migration test. The unit costs in this ;
figure are cumulative ones, that is, they reflect the
PAGE NUMBER
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 PITCH C'-iA.'j-jES WHITE OUT OR USE JCRF
'73 OP COURIER 12MODIFIED LONG DASHES L.SE 2 HYPHENS
GGU8LE 3ULLST31 USE A BED PENCIL DC"7"
r> I'lCHES (3OROERS INDICATED) A^i-. SPELL OUT COV1PANY % A
USE '.lil (NOT A 1 ^ 1 } EDITING. USE RED PENCIL
jcost of all activities along the decision branch. For j
i
t
example, the unit cost of $31,520 on branch four reflects
l
i
j$30,000 for a cement seal, $1500 for a fluid migration j
I ;
jtest, and $20 for a review of well records. Table IX-1,0
I i
summarizes these costs by individual unit cost element |
i |
for existing SWD wells. The total is estimated at $19.9
'million.
JThe total cost to industry for testing and remedial
|
;action to existing SWD wells is $62.1 million; of which
j$34 million is for testing and record review, and $28.1
'million is for remedial action.
I 2. Enhanced Recovery Injection Wells '.
'The analysis for ER injection wells is similar to that i
ifor SWD wells. Figure IX-4 details the cost of testing!
i ;
,all ER wells for casing leaks. With 75% of the wells ;
.having tubing and packer, the total cost of this testing
irequirement is $39.1 million. Estimates for the number;
i l
jof wells failing the test as well as the total cost of j
i ;
iremedial action for those wells is detailed in Table IX,-1 1
.Note that the failure rate for ER injection wells is less
\ ,
jthan that for SWD wells. As explained in Chapter VII, ;
j I
.this is because ER operators generally have a somewhat ;
AGE NUMBER
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TABLE IX-10
SUMMARY: COST OF FLUID MIGRATION TEST AND
APPROPRIATE REMEDIAL ACTION
EXISTING SALT WATER DISPOSAL WELLS
Item No. of Wells Unit Cost Total Cost
($000)
Record Review 39,355 S $20 $ 785
Fluid Migration Test 3.345 $ 1,500 $5,017
Cement Seal 301 $ 30,000 $ 9,030
Abandon and Redrill 34 $150,000 $5,100
Total $19,932
Source: Arthur D. Little, Inc., estimates.
Arthur P) I ittlp Inr
-------
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-------
TABLE IX-11
COST OF REMEDIAL ACTION FOR WELLS FAILING MECHANICAL INTEGRITY TEST
EXISTING ENHANCED RECOVERY INJECTION WELLS
Number
Requiring Unit Cost Total Cost
Population % Failing Test Action ($) ($000)
ER Wells with
Tubing and Packer 75,235 0.75% 565 $25,000 $14,125
Cement squeeze
ER Wells without
Tubing and Packer 25,080 3.75% 940 $25,000 $23,500
Cement squeeze
Grand Total $37,625
Source: Arthur D. Little, Inc., estimates.
I
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Igreater incentive to maintain wells in qood condition. |
I I
! ]
jThus, the likelihood of this proposed regulation creating
I
j ;
i incremental requirements is somewhat less for ER fields!
i i
jthan SWD fields. Based on field observations relating to
' |
the general condition of wells as well as assessments by
field operators and industry personnel, a factor of .75
.has been applied to all casing leak failure rates to recog-
inize this additional incentive. The total cost for repairing
I
Swells with leaks is about $37.6 million. '
i'
S ;
I
I
-Figure IX-5 details the cost of forming a fluid migration
itest and taking appropriate remedial action where nee- :
\ !
iessary. As for SWD wells, all 100,315 ER injection wells
must perform a record review for the adequacy of cement;
'at the injection zone. It has been estimated that about
i J
!88% of these wells will be able to demonstrate adequate'
i
jcement at the injection zone or present compelling evi-;
i
>dence in support of non-migration. The remaining wellsi
;will be tested for fluid migration. Again, the unit
jcosts are cumulative and reflect the total cost for all,
i
|
activity along a particular branch. A summary of the j
icosts by individual cost element is shown in Table IX-12.
i
i
i
I
JThe total cost to industry for testing and remedial
i j
iaction to existing ER injection wells is $144.4 million;,-
A.G5 NUMBER
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TABLE IX-12
SUMMARY: COST OF FLUID MIGRATION TEST AND
APPROPRIATE REMEDIAL ACTION
EXISTING ENHANCED RECOVERY INJECTION WELLS
Item No. of Wells Unit Cost Total Cost
($) ($000)
_ Record Review 100,315 20 $ 2,006
Fluid Migration Test 11,536 $ 1,500 $17,304
B Cement Seal 1,038 30,000 $31,140
Abandon and Redrill 115 $150,000 $17,250
Total $67,700
Source: Arthur D. Little, Inc., estimates.
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"Hi3 SHEET TO 3S USED FOR SCAM^cR GCPY ONLY
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lof which $58.4 million is for testing and record reviewj,
i ' !
(while $86.0 million is for remedial action. i
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L
CHAPTER X 1
I i
I NEW INJECTION WELLS INCREMENTAL COSTS '
i ;
JA. INTRODUCTION ;
i
Chapter X details the incremental costs to industry for:
\
l
new injection wells. These costs are non-recurring in ;
the sense that they occur only once for each well. How!-
ever, since the regulation applicability to new injection
wells extends beyond the five-year analytical time hori-
zon, the costs will also extend beyond the fifth year.
Figure X-1 details the critical decision path required for
each injection well.
In addition to the permitting requirements (discussed
in Chapter XI) and the area of review requirements (dis-
cussed in Chapter VIII), there are specific construction
,criteria detailed for new injection wells. While the
construction requirements actually apply to all injection
iwells, both existing and new, there is a provision which
| I
lexempts existing injection wells and new injection wells
i |
j'located in ex is ting injection fields from complying with
'the full extent of the requirement. This exemption holds
jfor new injection wells in existing injection fields asi
long as there is a state regulatory program in effect
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";CH5 .3OP3SPS -NDICATE
CHANGES ,%<;-, TE OUT OR ',SE CCP.~=C~''.r
ING DASHES. '-SH 2 HYPHENS
BULLETS. L.3E A RED PENCIL DOT 1
ADL. SPELL OUT COMPANY NAME
EDITING 'JSS HED PENCii.
jand being enforced at the time injection is started. j
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iThe result is that all new injection wells constructed I
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jin existing injection fields must comply only with state
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!requirements in force at the time the new program is !
* i
'put into effect. As more fully discussed in Chapter VI!,
]
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;the essence of this requirement is that new injection '
wells in existing injection fields will not be subject
ito any incremental construction requirements. However,'
i ;
jail new injection wells in new injection fields, including
:both converted producing wells and newly drilled injec-;
|tion wells, must comply with the full text of the con-
I
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struction requirements.
For the purposes of this analysis, it has been assumed
that state regulatory agencies would allow conversion
of producing wells to injection wells on a universal
basis. However, where adequate construction and testing
documentation is not available to demonstrate compliance,
the agencies will require a fluid migration test and
appropriate remedial action before issuing a permit.
AGc DUMBER
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THIS 3HEE7 TO 3ฃ USED FOR SCANNER COPY OMLV
SPACING.
MARGINS
i>~,, 'JPAPH ENDING.
3'J^LETS USE A RtD ?tNC L DC' ป
ADL. SPELL OUT COMPANY '.A.'.^
EDITING USE RED =E\C: _
i As a basis of comparison, it might have been assumed ;
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j that operators must present the construction and testing
records specified in the regulations or be denied a
! i
j permit. If this were the case, all type C, D and E >
!
j wells slated for conversion might have to be newly \
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! drilled. The cost for this type of action would be on '
! ;
: the order of $70 million. Since it is probably im-
practicable for state agencies to take this position,
this $70 million estimate has not been included in the'
cost analy sis . ;
B. ANALYTICAL APPROACH
,Using the well population projections and assumptions j
lin Chapter VII, there are expected to be about 1000 newj
i !
ISWD wells and about 4000 new ER injection wells permitted
|each year. The basic approach to estimating the cost ,
;of compliance has been to develop appropriate well popu-
lation figures, to estimate incremental unit cost of ;
.compliance, and to multiply the affected well population
ฐAGE NUMBER
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ELH*.'ฃM"" ! 73 OP CCoRi
3P~C>\'G DO'JBLE
ViPGiNS 1 'i INCHES -30RSEWS ..NDICATECl
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_-*." DACHES USE 2 HYPHENS
;ULL=T"3 i^SE A REO ?E\C!L O0r "ป
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!by the appropriate unit cost to produce the total incre,-
| _ i
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jmental cost of compliance. These are direct costs and,
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as such, do not include any amount for delays in the
permitting or construction process as a result of the
regulation or for management time which has been re-
directed from other projects.
The actual process of performing calculations has been |
:divided into two categories: first, the cost associated
.with testing or record reviews required in conjunction j
i I
,with new injection wells, and second, the cost of taking
any remedial action to bring a new injection well into \
compliance with the regulation. Since it is standard
^industry practice to test new injection wells for mechani-
.cal integrity (no casing leaks), the only incremental
cost is for reporting the results of the mechanical in--
!tegrity test to the appropriate regulatory agency. In
addition, a thorough record review is necessary for con,-
;verted injection wells to determine the adequacy of the1
Iproposed well for conversion to an injection well. Again,
'therefore, the only incremental cost is for reporting
such data to the state agency.
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THIS SHEET TO 3E USED FOR SCUM.MER CCPY QAJLY
'"CM
OR CCURIHR '2 M.
'As noted in the preceding section, it has been assumed j
that state agencies will continue to allow conversion
of producing wells to injection wells even in new in-
jection fields. This assumption is most critical to the
analysis, and any variance in actual practice will have!
1
dramatic influence on the cost of compliance. '
C. DATA
1. Well Population Data
.Information from field interviews was used to compile
a current profile of new injection wells. This profiles
was used to develop estimates of the number of wells :
subject to remedial action. Tables X-1 and X-2 detail :
.respectively the current profile for new SWD wells and
new ER injection wells. Since all Class C, D, or E wells
iwill be required to conduct a fluid migration test, only
a simple calculation is required to determine the esti--
mated number of wells. A failure rate of 10% has been ;
,used in accordance with previous estimates on the like-;
t i
f i
! i
ilihood of wells failing a fluid migration test. Failure
:rates for the casing leak tests are not applicable to
'this analysis since it is standard industry practice to:
itest and repair a well for leaks before putting it into:
servi c e.
3 AGE DUMBER
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TABLE X-1
INJECTION WELL
COMPLETION PROFILE
NEW SALT WATER
Region
Illinois Basin
Appafachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
Total
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TABLE X-2
INJECTION WELL COMPLETION PROFILE BY REGIONS
NEW SECONDARY RECOVERY WELLS1
Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
A
20
10
95
90
90
75
30
% of Wells
B
60
60
5
10
10
15
60
70
in Each
C
20
20
5
30
Class
0 E
5 5
5
10
Number of New
Wells2
495
230
1,197
1,060
45
73
140
592
Total 3,832
1. New wells refers to newly permitted wells which may be newly drilled or simply
converted older wells.
2. Estimated number of new wells to be permitted each year, 1980 through 1984,
by region.
Note: Data in this table accounts for about 96% of the expected number of new
enhanced recovery injection wells to be permitted each year.
Source: Arthur D. Little, Inc., estimates.
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HIS SHEET TO BE USED FOR SCANNER COPY ONLY
1 73 OR CCURIER -2 MODI?! E
-, TJCHE3 iBORCEHS ,MD CATEO
--.'TE GUT CP ^5= C
-3E 2 -'VPHENS
_SE i RE3 PENCIL DO
UT CC'vlPA.T"'
ED PENCIL
2. Unit Cost Data
Information on the cost of testing and repairing injec-
tion wells is contained in Chapter IX, Tables IX-3
through IX-8. Table X-3 contains a summary of unit costs
specifically appropriate to Chapter X.
;D. ANALYSIS
i 1. Salt Water Disposal Wells
i
JFigure X-2 details the critical decision path for esti-i
mating the cost of compliance for new SWD wells. While;
I i
'Figure X-1 makes a distinction between new and existing!
i
{injection fields and, as noted, the requirements are
''somewhat different for these two, it has been impossible
; to estimate what percentage of new injection wells will,
i
;be constructed in new injection fields. It is clear
ithat at the present time a high percentage of oil fieldis
icapable of secondary recovery have already commenced
'operations. However, it is impossible to determine howi
i
many new fields will be considered candidates for secon-
dary recovery in the future. Therefore, following the
interpretation of the proposed regulations as rietaile^
in Chapter VI and in the introduction to Chapter X, the
analysis implies there is no real distinction between ;
new and existing fields. Again, if regulators choose to
make a distinction, the cost implications can be very great
nGE NUMBER X^""5
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TABLE X-3
SUMMARY OF UNIT COSTS FOR NEW INJECTION WELLS
Report Mechanical Integrity Test $ 25
Surface Monitored Downhole Test to
Detect Migration of Fluids 1,500
Cement Squeeze to Isolate Injection Zone 30,000
Source: Subsurface, Inc., and Arthur D. Little, Inc., estimates.
-------
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HIS SHEET TO Be USED FOR SCANNER COPY ONLY
i'; n'IC'-iES .BORDERS .NOICATED!
uSฃ ..\1ฑL { NOT A 1.- 1 )
C-ปA'JGJE3. ,V-^i~E OUT OR 'jSE CC^RH
GDASHES L-Sc 2 HYPHENS
3UL'_ฃ~ฃ 'JSE A R63 =ENC!L DO'" ป
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EDITING USE RED PENCIL
A summary of the incremental costs for new SWD wells isj
\
Ishown in Table X-4. The total annual cost of compliance
j
is expected to be about $250,000; of which $100,000 is !
ifor testing and reporting test results, and $150,000 isj
I ซ
I
for remedial action. The total five-year cost of com-
pliance is estimated at $1.25 million.
2. Enhanced Recovery Injection Wells )
Figure X-3 details the critical decision path for esti-i
mating the incremental costs for new ER injection wells;.
The same assumptions used for calculating the cost of !
compliance for new SWD wells are also used for new ER ;
injection wells. Since the source of wells (either newly
drilled or converted producing) is the same for both SWD
and ER injection wells, the failure rates used are also;
the same. The incremental costs of compliance are sum-'
marized in Table X-5 by individual cost elements. The
total annual cost of compliance is estimated at $1.1 s
million; of which $.4 million is for testing or reporting
t
of test results, and $.7 million is for remedial action!.
The total five-year cost of compliance with this regular
tion is $5.7 million.
E MUMBER
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TABLE X-4
SUMMARY: INCREMENTAL COSTS FOR NEW SALT WATER
DISPOSAL WELLS
Item No. of Wells Unit Cost Total Cost
($) ($000)
Report Mechanical Integrity Test 1,000 $25 $25
Fluid Migration Test 50 $1,500 $75
Cement Seal 5 $30,000 $150
Total 1 year $250
Total 5 year $1,250
Source: Arthur D. Little, Inc., estimates.
134
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TABLE X-5
SUMMARY: INCREMENTAL COSTS FOR NEW ENHANCED RECOVERY WELLS
Item No. of Wells Unit Cost Total Cost
($) ($000)
Report Mechanical Integrity Test 4,000 $25 $100
Fluid Migration Test 230 $1,500 $345
Cement Seal 23 $30,000 $690
Total 1 year $1,135
Total 5 year $5,675
Source: Arthur D. Little, Inc., estimates.
-------
THIS SHEET TO BE USED =OR 5CA,xaMฃR COPY ONLY
173 OR COURIER 12 MOO!
'>':'.NCHES BQRCcHS IND
WHT = OUT OR LS= CCR=>
:-3E 2 HVPHENS
'-.SS A RED PENCIL DCT
SPELL OUT COMPANY \A-^
USE riฃD PENCIL
XI. PERMITTING
JA. INTRODUCTION
i
iThis chapter projects the costs which will be incurred j
1
jby well operators in obtaining permits required under j
j |
jthe proposed UIC program. Permitting costs covered in
Preparation of permit application forms;
i
i j Tabulation of data submitted with the permit
1 application;
Collection of data for the permit application
which has not been previously acquired for
other purposes ;
Preparation of a contingency plan for well
manfunc tions (ง146.250) ;
UMBER
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"HIS SHEET TO 3E USED FOR SCANNER COPY ONLY
3ITSH 3HTT1NG 10 PITCH
cLSiVS^T 173 OR COURIER 12 MODIFIED
SPACING DOUBLE
.V.APGiMS. 1'2 INCHES (BORDERS INDICATED!
3R ^PH = .\OiNG USE A I ฑ I (NOT A 1 i, 1 )
3NG DASHES
3ULLETS.
AOL.
EDITP;G
SPELL OUT COMPANY N
USE -3ED PE.NC1L
Preparation and presentation of the applicant's
case at a public hearing;
Obtaining a plugging bond (-ง146.250), if the
operator does not have such a bond already as
a result of state law and regulation; and
, Laboratory testing of the injection fluid. ;
'Costs which are specifically excluded from this analysis
\
:of permitting costs include:
o Costs associated with the collection and analysis
: of data which the operator would undertake in
!
the normal course of well design and reservoir >
f
i
; engineering; >
Costs of collecting and analyzing data under the
"area of review" requirements discussed in
Chapter VIII; and
Costs to state agencies for processing permit
applications, discussed in Chapter XIII.
3 AGE NUMBER )(l
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'HIS SHEET TO 3E USED FOR SCANNER COPY ONLY
10 PITCH
173 OR COURIER 12 V,O
DOUBLE
vi 'INCHES (BORDERS I
USE -:. 1 j. 1 ( WOT
VH!TH 0-JT CR ',Sc CC^ฐSC
'..SE 2 HYPHENS
L.SE A REO PENCIL 00- 3*
SPELL OUT CO''*? ANY \~V^
USE RED ?E
B. PREPARATION OF THE PERMIT APPLICATION \
Cost estimates for preparation of the permit application
|
are based upon estimates of clerical, technical, and ;
managerial time at the following rates : :
l
* Clerical: $11.50 j
3 Technical (engineering): $27.50
.^Management: $35.00 ;
iThese rates represent the estimated average fully-
\ \
burdened costs of preparing the permit application. ' |
1. Existing Salt Water Disposal Wells
'.These wells are exempted from the requirement to compile I
i : 4
jdata on other wells within the area of review. It is i
i ; I
,estimated that the operator will incur average costs ' I
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\
'of $160 per well for compiling and transcribing: j
' & Ownership and location information; ' 4
! 1
S Engineering data on the well (construction details);
i
0 Anticipated operating data (injection pressure and volume) il
^ Injection zone geological data,-
^Description of underground drinking water sources; and J
it Completing application forms. :
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
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30iJ8Lฃ
T: .riCHES BORDERS INDICATED!
APAGPAPH = \O:\G
CHANGES: (VHIT= CUT OP USE CORRECT! -'iC
LONG DASHES. USE 2 HYPHENS
3ULLSTS. LSE A RED PENCIL DOT ป
ADL SPELL OUT COMPANY \AV =
EDITING. U~E RED PENCIL
2. New Salt Water Disposal Wellsp
i
Data preparation for these wells will include all of the
!
iitems listed above, plus:
j e> Developing a map of all public record wells
within the "area of review";
o Listing in tabular format the plugging and/or
completion data of wells within the "area of
review" which penetrate the injection zone; and
.. Description of proposed action for wells in the
\ "area of review" which are determined to endanger
1 underground drinking water sources.
i :
! i
^ >
j ;
Average costs of preparation of a permit application ,
i !
'for new SWD wells are estimated at $320 per well. ;
' i
3. New Enhanced Recovery Wells
| ,
For these wells, the company must prepare all the itemsj
|of information listed above for new SWD wells. Permits!
i
i
for new ER wells can be sought in groups on a project-
i
jby-project basis. Based on an assumption of three new '
;ER injection wells per permit prepared at an estimated >
cost o~ฃ $800 ~, we e stimat e an average c o"s ฃ 5T $ 2 67 plfr well
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iS ShrET TO BE USED FOR SCANNER COPY ONLY
'PE'.VR'TER SETTING iC'ITCH
EL. 3 MEN"1" 173 OR COL-IE- 'IV.CClF'ED
D 'i f*' h ^ '"^ ; /^ i i ^ i r*
or-ACilsvj CwUa^.=
MARGINS. r;iNCHc3 3CPOE-S INDICATED)
!-^AG-A?H ENDING. US= llj. 1 , -;CT ^ 1 ii i ,
CHANCES: WHITE OLF Of USE COB^ECTiNG TAPE
LONG DASHES US5 2 HYPHENS
3Li_LE~S USE A 3ฃD ฐENCIL "OT ป
A3L. SPELL OUT COMPAfJ f NA.VE
ED't'.NG USE PHD ฐE\C;L
I
C. TESTING THE INJECTION FLUID ;
As required by ง146.25 of the proposed UIC program, th4
1
permit applicant is to provide information on the com-j
position of the injection fluid. Laboratory costs for]
this fluid analysis range from as low as $6 to deter- j
1
!
| mine pH or dissolved oxygen (measures of the fluid's '.
| corrosiveness), to upwards of $800 for a gas chromatog-
j raphy/mass spectrometry review which would provide a
I ;
fingerprint of key organic contaminants. Additionallyj
1 operators would incur overhead charges associated with ,
}
I the handling and record-keeping of fluid test data.
i Cost implications of the fluid analysis requirement are
i difficult to determine because of the ambiguity and
. considerable latitude in interpretation of specific
I
', fluid tests to be accomplished. However, for purposes
j
' of this cost analysis, it is assumed that fluid analy-
sis associated with the permitting process will not be
j substantially different from analysis currently con-
| ducted during reservoir engineering and injection de-
i
i
: sign. Accordingly, it is assumed that new injection
i wells will not incur any incremental costs associated
X
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
f
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,n ,,-~_ ;H."NG53. W'HlTc CUT OH L.S3 CCaQ3C~rl'\G TAP
, .,,, -,-, ,,,-,. -, =R ,~ , -~;ri=r-. _3NG -AS'-'ES. U3E2 HY^hEMS -
' ^ ., t ^ >.. *_< ~ i f' ' - ^ ^' ~ ' - <-'
^,...=T- i;Sr A p?D PENCIL 30T '*
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;D. PREPARATION OF CONTINGENCY PLAN i
; The model for this requirement appears to be the Spill '
- |Prevention Containment and Control Plan required of oil
storage and transfer facilities. The plan would pre-
sumably include emergency notification and command pro-
cedures, and steps to be taken to shut down and repair
; injection operations if a leak is detected. For salt
t
I water disposal operations, temporary storage of brine
;' or shutdown of producing wells would be required. The
; underground injection contingency plan could be part
; of a larger SPCC plan for surface spills in an oil-
production operation.
^v -^ ~ i *_ I O
'>G. USE :. I. :. L *>" _"_*' "" J '--' - **
! with the water analysis requirement. No new incremental
i j
;costs are shown for the water testing requirements for \
iSWD or ER injection wells. However, if the permitting jagency
; i
j requests water analyses which have not been done by opeirators
I !
iof existing wells, the incremental cost may run $100 far
j I
leach well tested. Thus, the costs of permitting shown Jin
(the summary tables might be increased by $3.9 million fior
i,
'water testing at all existing disposal wells. Similar :
i
' increases could occur if operators of new injection welils
s ;
I
were required to perform fluid analyses that were substantially
idifferent from those that are current practice.
-------
HIS SHEET TO 3E USED FOR SCANNER COPY ONLY
One plan could cover all the injection wells in a
unitized operation. Costs of preparing the required
plan are estimated as follows:
One engineer for one week to draw up plan
($27.50/hr x 40 hrs = $1100).
40% of effort attributable to underground
inspection (rather than surface) activity.
Average of 20 wells in each contingency plan.
Cost = $22/well for all disposal and new ER
1 wells.
'E. FINANCIAL RESPONSIBILITY
Many states--California, New Mexico, Ohio, Oklahoma,
i for example now require a well operator to provide a
plugging bond or other evidence of financial surety
before receiving a permit.
Major oil companies should be able to provide evidence,
of financial surety without further insurance. For cost
estimating purposes, it has been assumed that small
operators would need to purchase a plugging bond. Such a
bond may be bought for an individual well or, more
economically, for a group o~f wells. Sa/mple
v /- 7
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"HIS SHEET TO BE USED FOR SCANNER COPY ONLY
plugging bond premiums in New Mexico in February 1979 j
!
suggest an average premium of $100 providing $5000 in I
plugging coverage for a five-year period.
Since data are not available on the number of wells
currently covered by financial guarantees, it has
been estimated that plugging bonds (@ $100/well)
will be required as follows:
' - 50% of existing disposal wells; and i
' - 33% of new injection wells.
F. PUBLIC HEARINGS
Preparation of an applicant's case by staff can cost
$3000 (2-1/2 weeks @ $27.50 per hour). Few existing
jwells will trigger a hearing with their permit applica-
j !
; tionthe existence of such wells is now accepted by
' neighboring landowners and lease holders. New wells are
more likely to generate controversy and result in a
public hearing. We, therefore, estimate that the $3,000
hearing costs will be incurred by:
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
/VHI . c OUT DP USE CORRECT NG TAPE
'^3= 2 HYPHENS
oSH A <3ฃD PENCIL CO"1" 9
S?ฃL_ DOT CCMPAfj^ ,\ซ.\1E
- 1% of existing SWD wells; and |
i
- 10% of new injection applications '
(3 wells per ER application, 1 well per 1
i
I
SWD application) .
!
i
In many states, oil companies will be required to hire ,
i ;
I local counsel to present their case. At a cost of
!
j $60/hr or more, an additional expense of $1,920 would
i
1
i be incurred for 4 days of hearings. If we add trans-
i
i portation costs of $500 for technical witness, the .
rounded cost of a public hearing might rise to $5,500.
i This could increase the totals shown in the cost summary
, by $11.3 million .
; G. COST SUMMARY
Incremental costs of permitting over the first five
years of the proposed UIC program are estimated at
$22.1 million. Additional efforts discussed above (hear-
;
j ings, water testing) might raise this total to $33.4 ;
I
million. Table XI-1 presents the detail of the calcu-
lations of unit costs. Using these unit cost estimates
and assuming 20% of the existing wells which will re-
quire issuance of new permits are processed in each of
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
1 ': >,NCHH3 'BORDERS INDICATED1'
USE .-l.il ( \CT i 1 _ * ;
'the first five years, permitting cost estimates presenti-
j |
ied in Table XI-2 were developed for each of the years
i
!in the five-year cost analysis.
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CHANGES WHITS OUT OR USE CORRECTING
?VG DASHES USE 2 HYPHENS
3ULLETS USE A RED PENCIL DOT ซ
ADL. SPELL OUT COMPANY NAME
EDITING USE RED PENCIL
XII. MONITORING AND REPORTING COSTS
A. INTRODUCTION
JThis chapter presents the analysis of the oil industry
compliance costs resulting from UIC program requirement^
for the collection and reporting of monitoring data. 1
The cost analysis has been divided into two parts: ;
(1) monitoring, which includes the costs of making and {
!
recording the required observations of injection well
i
data; and (2) r_ep_Qrj:ijKi_, which includes the costs j
!
associated with completing and forwarding the required reports
to the state agency or agencies responsible for adminis'tering
the UIC program. In both cases, compliance costs are '.
the incremental or additional costs above and beyond
!
industry practice as described in Chapter V.
'AGE NUMBER X\ \
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"HIS SHEET TO 3E USED FOR SCANNER COPY OMLY
1730HCOuRIEr*12 MODIFIED
DOUBLE
''2 INCHES 'BORDERS INDICATED)
USE \ i ^ i ( \OT j, 1 j. 1 }
;VHiT= OUT OR USS CQRP.EC
USE 2 HYPHENS
USE AHS3PENCIL GOT *
SP6LL OUT COMPANY NAME
JSc RED PENCiL
B. MONITORING COSTS ASSOCIATED WITH SALT WATER
DISPOSAL WELLS
This section describes the approach and presents the
findings of the monitoring cost analysis for SWD wells.
Cost estimates for SWD well monitoring were developed in
four steps: i
Estimating the number of SED wells not already
in compliance with the proposed monitoring
requirements ,
$
y Developing a national average full cost of
performing the required monitoring,
^ Adjusting the full cost estimate to an ;
incremental unit cost, and !
, Multiplying the unit cost times the number of
wells affected for each. j
|
i
1 . Determination of the Number of Wells
^
i
! Requiring Additional Monitoring ;
i
JField interview data established that most SWD well
mon
Injection pressure and vo-.lume
at intervals equal to or more frequent than those prescribed
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2=T~~I,\G 1C 3I7CH
^E\ia\T 173 OR COURIER '2 MODIFIED
SPACING DOUBLE
.WGIMS V; INCHES I3ORCERS INDICATED!
ENDING USE 1 1 A i . NOT A 1 - 1 )
CHANGES,
NG DASHES
BULLETS
AOL.
EDITING
,','HITE C'J~ OB ,SECC
USE 2 HVpup-j3
USE A 3 = 0 PSr
-------
TABLE Xll-1
REQUIREMENTS FOR ADDITIONAL MONITORING OF
SALT WATER DISPOSAL WELLS
% of Wells Without Regional
Weekly Monitoring2 of Regional Component
Geographic Region1 Volume and Pressure Weight3 (%)
Illinois Basin 5% .187 0.9
Appalachia 20 .158 3.2
Mid Continent 5 .146 0.7
Permian Basin 5 .156 0.8
Gulf Coast 5 .189 0.9
East Texas 5 .144 0.7
Rocky Mountain 10 .004 0.0
California 15 .015 0.2
Weighted National Average 7.4%
1. The eight regions included in the field interviews account for 93% of ail SWD wells.
2. Reading a guage and logging the results in an internal record-keeping system.
3. Regional weights are the total SWD wells in the region divided by the total SWD wells in the eight
regions.
Source: Arthur D. Little, Inc., estimates.
1
Arthur D Little. Inc
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TABLE XII-2
INCREMENTAL MONITORING PROJECTIONS FOR
SALT WATER DISPOSAL WELLS
Yearl Year 2 Year 3 Year 4 Year 5
Total SWD Wells 40,240 41,150 42,075 43,020 43,990
ซ| % Adjustment 7.4% 7.4% 7.4% 7.4% 7.4%
#of Wells Requiring Additional Funding 2,978 3,045 3,144 3,183 3,255
Source: Arthur D. Little, Inc., estimates.
Arthur Dl irrlpl
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10 3J-CH
!73 DP COURIER 12 MODIFIED
DOUBLE
1 i'.NICHES (BORDERS INDICATED)
USE i 1 j, 1 (\iCT A 1 i " )
USE A RED PENCIL GOT *ป
SPELL OUT COMPANY ,\.-v,,=
J3E RED PENCIL
2. Development of a Unit Cost j
i
:Unit costs for the required monitoring of SWD wells werb
I i
ideveloped by first estimating the full costs of monitor}-
jing and then adjusting for monitoring activities that
i
jare already typically accomplished.
; a. Calculation of an Average Full Cost
I An estimate of the average cost to perform the required;
monitoring was developed by using the following formulas:
j Average Cost =NxTxWxB ]
iwhere :
'. N = number of monitoring visits per year required
in order to comply;
T = time for a monitoring visit;
W = average hourly wage; and >
\ B = burden rate to adjust for overhead.
,A discussion of each of the elements used to arrive at
(an average of the full costs of monitoring injection
'pressure and volume for SWD wells follows:
i
i
; (1) Number of Required Visits. The
'proposed UIC program specified at least weekly monitoring
of. in j ec tion pre s sure and volume for all SWD we 11s . '
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
;o PITCH
173 OR COURIER 12 MODIFIED
OOL'BLE
V: INCHES (BORDERS INDICATED!
USE Alii ( MOT A 1 .1 1 )
3 OASHGS
3ULLHT3
-DL
EDITING
WHITE OUT OR USE ;CRP3<
USE 2 HYPHENS
USE A 3ED PENCIL DC'' 4
SPELL OUT COMPANY NAV =
USE RED PENCIL
Accordingly, 52 is the value of N that is utilized in
calculating the average annual cost to monitor an SWD
we 11.
(2) Time Expended per Visit. Field
interview data established that there is considerable
variation in the total elapsed time required for a !
monitoring visit. Generally, the time actually spent
in attaching or adjusting a guage, taking a reading and!
1
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!
jrecording it is quite small compared with the transporta-
i i
jtion time between injection wells. Time spent taking :
i i
and recording the required monitoring data was typically
.reported as one to two minutes, while transportation time
I i
^ould range anywhere from less than a minute to more
jthan a half hour. Based on the field data, 8.5 minutes;
i
[of 0.14 of an hour was allotted for total time required!
ifor a monitoring visit. The more than a tenth of an
hour included in this amount for transportation was felt
|to be reasonable, considering that well visits tended i
j i
jto be conducted in a sequence that took into account '
I
their geographic location and the weekly frequency require-
ment would, in many cases, permit combination of the
|
i
.monitoring visit with other routine required visits to
i
'the wel 1 site .
PAGE .NUMBER
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10 PITCH
;?3 3R COURIER 12 MODIFIED
DOUBLE
',"2 INCHES (BORDERS INDICATED!
USE :. 1 i I ( NOT .1 "U 1 )
,VHiTE OUT OR '_Sฃ CCRPSC
3U_L=T3.
"*. 0 L.
SD'T'MG
uss A RED PENCIL COT
SPELL OUT COMPANY \
USE RED PENCIL
(3) Average Hourly Wage. Based on fiel'd
i
interview data, an estimate of $8.20 per hour was '
i
developed as a national average wage of field personnel!
i
I
involved in the collection of monitoring data. As shown
in Table XII-3, the national average wage was weighted ฃ0
i
reflect the geographic distribution of injection wells.i
(4) Assumed Burden Rate. In order to
include appropriate overhead costs (such as employee
fringe benefits, supervision, transportation, etc.), I
an adjustment to the average national wage was required!.
i
iFor purposes of this analysis, it was assumed that the
relevant portion of overhead to be included in the cost:
;analysis was equal to the average wage. Accordingly,
i
;a 100% overhead rate (or a factor of 2) was utilized to
iadjust average wage to an estimated fully-burdened hourly
wage .
(5) ^Avejrage Cost Calculation (full cost
basis). Utilizing the formula and inputs described
above, the average cost of monitoring SWD wells was
calculated to be $119.39 per well per yeara This figure
^represents the annual full cost of monitoring an SWD
i
wg 1 1 , ________ .
PAGE NUMBER Xll"'
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TABLE XII-3
CALCULATION OF NATIONAL AVERAGE HOURLY WAGE
COLLECTION OF MONITORING DATA
Region
Illinois Basin
Appalachia
Mid-Continent
Permean Basin
Gulf Coast
East Texas
Rocky Mountain
California
Average Wage Weight1
National Average
Component
$ 7.50
7.00
8.25
8.00
9.00
9.00
8.25
9.50
..145
.087
.267
.244
.060
.054
.028
.116
Weighted National Average $ 8.20
1. Regional weights are the total injection wells in the region divided
by the total injection wells in the eight regions.
Source: Arthur D. Little, Inc., estimates.
775
Arthur DI ittle li
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10 PITCH
173 OR COURIER 12 MODIFIED
DCUBLH
1"i INCHES ''BORDERS INDICATED)
USE L1 l 1 ( NOT d 1 A 1 )
WHITE OUT OR USE CORRECT1-;;
USE 2 HYPHENS
USE A REC PENCIL DOT ป
SPELL OUT COMPANY NAME
USE RSD PENCIL
b. Adjustment to Derive an Incremental
Unit Cost
An adjustment to the average cost calculation was required
to derive a unit cost that could be applied to the pro-
jections of SWD wells requiring additional monitoring.
Specifically, the average annual cost of $119.39 must
be scaled down to reflect only incremental rather than
full costs. This was necessary because many of the SWD
wells not already complying with the proposed monitoring
requirements were already accomplishing some monitoring,
though at intervals less frequent than described in the
proposed UIC program.
This scaling of the full-cost estimate is accomplished
by estimating the average number of additional monitor-
ing visits required as a percentage of the total number
of required monitoring visits. This factor can then be
applied to the average full cost to provide an average
incremental monitoring cost for wells not already in
compliance.
Based on field data, it was estimated that approximately
75% of those SWD wells not already in compliance with the
proposed regulations were monitored at least monthly and
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10 PITCH
173 OR COURIER 1 2 MODIFIED
DOUBLE
vi INCHES sBQRDbriS INDICATED)
USE .i 1 i. 1 { NOT A 1 _\ 1 }
JrtAMGES. WHITE OUT OR USE CORRECTING TAf
.ONG CASHES: JSE2HVPHฃ\S
3U'_LฃTS. USE A R6D PENCIL DOT ซ
AOL. SPELL OUT COMPANY NA-\<< =
E2IT1NG USE =ปED PENCIL
{that only 25% were not routinely monitored in a manner
consistent with the proposed regulations. In other
(words, 75% of those SWD wells not in compliance would
{require, at most, 40 additional visits per year, while
the remaining 25% were assumed to require the entire 52
visits. These were weighted to arrive at an incrementap.
j
required frequency of 43 monitoring visits per year, orj
about 83% of the full requirement for those SWD wells not.
already in compliance. Adjusting the average full cost!
by 83% provides an estimated incremental cost of $98.73':.
j
i
This figure reflects an estimate of the average annual j
incremental cost per well for those SWD wells not already
in compliance. Table XII-4 provides a calculation detail
for the unit costs associated with monitoring of SWD
l
we 11 s . '
3. Calculation of Incremental Monitoring :
Costs :
Incremental costs for monitoring SWD wells were calculated
by multiplying the unit cost times the estimated number!
of wells requiring additional monitoring under the pro-'
posed UIC program. This calculation yielded an estimate
of about $1.6 million in additional cost to the oil andi
gas industry over the first five years of the UIC program,
PAGE DUMBER
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TABLE XII-4
UNIT COST CALCULATION DETAIL FOR
SALT WATER DISPOSAL WELL MONITORING
1) Average Cost of SWD Monitoring (Full Costs)
= NxTxWxB
Where: N = number of monitoring visits per year required in
order to comply
T = time for a monitoring visit
W = average hourly wage
B = burden rate to adjust for overhead
= 52 visits/year x .14 hour/visit x S8.20/hour x 2
= $119.39 per well per year
2) Adjustment to Incremental Basis
Incremental cost = Full Cost x F/N
Where: F = number of additional monitoring visits per year required
= (.75x40) + (.25x52)
= 43
Incremental cost = $119.39 x 43/52
= $98.73
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10 PITCH
1 73 OR COURIER 12 MODIFIED
DOUBLE
Vi INCHES (3ORDEHS INDICATED)
USE >\ 1,11 ฃ MOT A 1 A 1 )
CHAMGES,
U OASHtzS.
3ULLETS.
ACL.
EDITING.
WHITE OUT OR uSS
USE 2 HYPHENS
USE A RED PENCIL C
SPELL OUT CCMPAN
USE RED PENCIL
in order to monitor SWD wells. Table XII-5 presents
the incremental costs on a year-by-year basis.
JC. MONITORING COSTS ASSOCIATED WITH ENHANCED
RECOVERY INJECTION WELLS
This section presents the findings of the monitoring
cost analysis for ER injection wells. Except as noted,..
the approach is similar to that used for SWD wells. ;
1. Determination of the Number of Wells j
Requiring Additional Monitoring
As with SWD wells, field interview data established that
the vast majority of operators or ER injection wells
already monitor injection pressure and volume at intervals
equal to or more frequent than those prescribed by the ',
proposed UIC program. This was particularly true with ,
ER injection wells both because the proposed requirements
call for monthly rather than weekly monitoring, and the,
nature of ER injection projects is such that the n,onitorincT of
operating data is routinely performed. j
Based on the field data presented in Chapter V, it is i
estimated that 3.8% of the ER injection wells will :
require additional monitoring in order to comply with
PAGE NUMBER
XII-1
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TABLE XII-5
FIVE-YEAR COSTS
SALT WATER DISPOSAL WELL MONITORING
($000)
Unit Cost Total
($) Year! Year 2 Year 3 Year 4 Year 5 5-Year
(#of Wells) (2,978) (3,045) (3,114) (3,183) (3,255)
Monitor Pressure
and Volume $98.73 $294 $301 $307 $314 $321 $1,537
Source: Arthur D. Little, Inc., estimates.
Arthur D Little, Inc
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10 ?!TCh
173 OR COURIER 12 MODIFIED
DOUBLE
1'i INCHES iBORDSRS .NDICATED)
U'Se ll :.! ( MOT j, 1 A. 1 )
.'.HiTE OUT CH OSS CCR
USE 2 HYPHENS
U3ฃ A RED PEMCi L DOT
SPELL OUT COMPANY \
USE RED PENCIL
I
the proposed monitoring requirements. Table XII-6 1
j
provides the details of this calculation.
As previously discussed, the eight regions contacted 'in
the field interview program comprise 96% of all ER i
{injection wells. Assuming that the 4% of ER wells which
are not included in the field interview regions are not:
significantly different, the weighted average of 3.8%
calculated from the field interview data can be used with
the well population projections developed in Chapter V
to develop an estimate of the total number of ER injec-
tion wells that would incur additional monitoring costs
arising from the proposed UIC program. This calculation
results in an estimate of 3812 ER injection wells in
1979 that will require additional monitoring. Table XII-7
presents the five-year projections of the number of ER '
injection wells requiring additional monitoring during
the first five years of the UIC program. :
2. Development of a Unit Cost '
Unit costs for the required monitoring of ER wells were
developed by first estimating the full costs of monitor-
ing and then adjusting for monitoring activities that are
already typically accomplished.
PAGE NUMBER Yl )-* /
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TABLE XI1-6
REQUIREMENTS FOR ADDITIONAL MONITORING OF
ENHANCED RECOVERY INJECTION WELLS
% of Wells Without Regional
Monthly Monitoring of Regional Component
Geographic Region1 Volume and Pressure Weight2 (%)
Illinois Basin 2% .129 0.3
Appalachia 2 .060 0.1
Mid Continent 5 ,312 1.6
Permian Basin 2 .277 0.6
Gulf Coast 2 .011 0.0
East Texas 2 .019 0.0
Rocky Mountain 10 .037 0.4
California 5 .155 0.8
Weighted National Average 3.8%
1. The eight regions included in the field interviews account for 96% of all ER injection wells.
2. Reading a guage and logging the results in an internal record-keeping system.
3. Regional weights are the total ER injection wells in the region divided by the total ER injection wells
in the eight regions.
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TABLE XI1-7
INCREMENTAL MONITORING PROJECTIONS
ENHANCED RECOVERY INJECTION WELLS
Year 1 Year 2 Year 3 Year 4 Year 5
Total ER Injection Wells 103,830 107,460 111,225 115,115 119,145
% Adjustment 3.8% 3.8% 3.8% 3.8% 3.8%
#of Wells Requiring Additional Monitoring 3,496 4,083 4,227 4,374 4,528
Source: Arthur D. Little, Inc., estimates.
Arthur H I ittlpl
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HIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 r-17';1-
1 73 OP CC'jRIE1' ' 2 MODI = ':E3
SCvJSLE
1 ; :NCHE3 i3OR3tRS INDICATED)
WHI73 CUT OR IjSS C
USE 2 HYPHENS
OScA RED PENCIL DOT %
SPELL GUT COMPANY NAME
'JSE ^ED PENCIL
I
a. Calculation of an Average Full Cost
An estimate of the average cost to perform the required
monitoring was developed by using the same equation
presented for analysis of SWD monitoring costs:
Average Cost =NxTxWxB i
whe re : !
1
N = number of monitoring visits per year required i
i
in order to comply; i
i
T = time for a monitoring visit; i
W = average hourly wage ,- and !
i
B = burden rate to adjust for overhead. ;
A discussion of each of these elements follows. ;
; ( 1 ) Number of Required Visits. The pro*-
posed UIC program specifies monthly or more frequent :
monitoring of injection pressure and volume for all ER i
tinjection wells. Accordingly, the minimum requirement :
| I
jof 12 visits per year is used in calculating the full !
'cost estimate.
( 2 )
Expended per Visit. Field inter-
views confirmed that time expenditures for monitoring
of an ER injection well are similar to those discussed for
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"HIS SHEET TO 3E USED FOR SCA,\NฃR COPY ONLY
' = 'J 3ETTI\G 10 ?!TOH
ฃLE"'.;E";^ 173 OR COURIER '2 MODIFIED
MARGINS, ! i INCHES BORDERS INDICATED)
ARM E\Dli\)G. USE '.1^.1 { NO"" .1 1 * )
CHANGES, WH!7~ OUT Qq USE GCRRฃC~'"j
\G DASHES USE 2 HVPHENS
3Li__=TS USE A RED PENCIL DOT 4
AOL. SPELL OUT COMPANY NAME
ECiTING USE ^ED PENCIL
JSWD wells. A total of 8.5 minutes or 0.14 hour was
allotted for a monitoring visit.
(3) Average^Hourly Wage. As previously
discussed, the national average hourly wage for personnel
assigned to injection well monitoring activities was
estimated to be $8.20 per hour. -,
\
\
\
(4) Assumed Burden Rate. A 200% burden!
rate was assumed in order to allow for the relevant j
i
portion of overhead to be included in the cost analysis.
Accordingly, a factor of 2 was utilized to adjust the ;
average wage to an estimated fully burdened hourly wage!
(5) Average Cost Calculation (full costj
ba^sis) . Utilizing the formula and inputs described
i
above, the average annual cost of monitoring the injec-
tion pressure and volume of ER injection wells was cal-;
culated to be $27.55 per well. This estimate represents
the average annual full cost of monitoring an ER injec-i
tion we 11.
?iGฃ \LMBER
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
10 PITCH
1 ?3 OR COURIER 12 MO^I = !=D
DOUBLE
V'z INCHES iSGRDEPS INDICATED)
USE :> 1 ^ 1 ', r'-iOT i 1 ;. i
CHANGES'
_0\G DASHES
BULLETS
AOL.
EDITING
WHITE OUT OR USE CCF
USE 2 HVRHENS
USE A RED PENCIL QC~
SPELL OUT COMPANY Xi
USE RED PENCIL
b. Incremental Unit Costs
>,
jUnlike SWD wells where full costs were scaled down to 1
an incremental basis, no adjustment was made to the !
i
full-cost estimate for ER injection wells. Based on i
field interviews, it is felt that those extremely few j
jER injection wells that were not already accomplishing '
I '<
jthe proposed monitoring requirements are apt to incur
most, if not all, of the full costs of monitoring.
Accordingly, the full cost of $27.55 per well per year
!has been utilized as the unit cost for those ER injection
1 !
i
jwells not currently in compliance with the proposed ;
irequirements for monitoring injection pressure and
i
,vo lume . ,
3. Calculation of Incremental Monitoring Costs
Incremental costs for monitoring of ER injection wells were
calculated by multiplying the unit cost times the estimated
number of wells requiring additional monitoring under the
proposed UIC program. This calculation yielded an '
estimated $583,000 in additional cost to the oil and gas
industry over the first five years of the UIC program.
Table XII-8 breaks out the incremental costs of ER injec-
tion well monitoring on a year-by-year basis.
E NUMBER
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TABLE XII-8
FIVE-YEAR COSTS
ENHANCED RECOVERY INJECTION WELL MONITORING
($000)
Unit Cost Total
($) Year 1 Year 2 Year 3 Year 4 Year 5 5-Year
(#of Wells) (3,946) (4,083) (4,227) (4,374) (4,528)
Monitor Pressure
and Volume $27.55 $109 $112 $116 $121 $125 $583
Source: Arthur D. Little, Inc., estimates.
-------
'HIS SHEET TO BE USED FOR SCANNER COPY ONLY
ARGIN'S. ' * INCHES'BORDERS INDICATED!
CHANGES. wrCT-cuTCR jsฃc??
!_0\G DASHES. '~3S 2 HY?<-ENS
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AOL. SPELL GU
EDITING USE BE
ID. MONITORING COST SUMMARY |
1
JTotal incremental costs of the proposed monitoring require-
ments for Subpart D, oil and gas production related
injection wells, is estimated at $2.1 million over the j
first five years of the UIC program. Although SWD wells
t
'comprise less than 30% of all oil- and gas-related injec-
tion wells, they account for more than 70% of the incre-
mental costs of the proposed monitoring requirements.
I
This disproportion is due to two factors. First, more
stringent frequency requirements have been proposed forj
5
SWD well monitoring than for ER operations. Second, ;
i
somewhat lower levels of monitoring are currently practices
for SWD wells than for ER operations. Table XII-9 pro-i
vides the yearly totals for SWD and ER monitoring costs.
E. REPORTING
Included in the analysis of reporting costs are those
i
costs associated with the preparation, handling, and
submission of the required monitoring reports to the i
state agency or agencies responsible for administration,
of the UIC program.
PAGE NUMBER X\V
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---JGES. -,VMT= OUT OR USE CORRECTING TAP =
G "JOSHES, '-SE 2 HYPHENS -- I
3LL'_3T3 USE A RED PENCIL DOT * I
AOL. SPELL OUT COMPANY NAME '
~3i"',NG USE RED PENCIL
1. Reporting Requirements '
\
Under the proposed UIC program, operators of injection j
wells are required, at a minimum, to make annual reports
i
to the state director summarizing the results of the i
! i
(required monitoring and situational reports pertaining j
$
to violations and certain malfunctions and compliance '
schedules. Each state director shall establish the form,
manner, and content of reporting and may establish more
stringent reporting frequency requirements.
It has been assumed that UIC reporting will be compatible
with existing reports. That is, current report forms ',
and procedures will be modified to include all required;
UIC data so that duplicate reporting would not be required.
jThis assumption enables exclusion of the costs associated
Iwith information that is currently reported.
'Secondly, it was assumed for purposes of the cost analysis,
jthat directors would require the minimum; that is, annual
'reporting of summary data. The rationale for this
assumption is that requirements desired above the minimum
i
'.are at the discretion of the directors of the various
state programs and not a "requirement" of the proposed
TJIC p TO err am . ,
GS DUMBER V\\-
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"HIS SHEET TO BE USED FOR SCANNER COPY ONLY
10 P!TC^
173 3P COURIER 12 MODIFIED
DOUBLE
1"i 'NCHtS .'BORDERS INDICATED!
f~~ H A >*'* G *" 5 ', V *" i T ~ ^' T ^ ^ : *- f~ *"*
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EDITING, USE RED PENCIL
'A?
jLastly, based on current practice, it has been assumed j
l
jthat UIC reports will often contain data for several
i j
Swells. For purposes of this analysis, an average of three
,SWD wells or ten ER injection wells has been assumed.
r
1 2. Analysis of Reporting Tasks ';
]
:A sequence of key tasks that typically would be accomplished
Jin order to meet the proposed reporting requirements was
developed. This typical reporting task sequence includes
i
the following eleven steps: j
i
& Fill out identifying demographic information j
(operator's name, location, well identification
numbers, date of report, etc.) on report form!.
i
Retrieve and transcribe summary surface injec^
tion pressures as required on to report form
from log. :
I
j
i
_, Transcribe water analyses conducted during the
reporting period.
i
w Calculate total and transcribe volumes of '
i n o fl* p d f r\r 'M-io
rj p
g-rior|
!AGE MUM
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THIS SHEET TO BE USED FOR SCANNER CCPY ONLY
10 ?>TCH
173 OR COuRiER 12 MODIFIED
DOUBLE
1-2 INCHES ;aOPDERS INDICATED)
USH ,\ 1 A 1 ( .NOT ,1 1 A " )
A'-IT= CUT OP .JSS CC
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USE A RED PENCIL. D0
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USE =*ED PE\CiL
, Convert injection well test data for tests
conducted during the reporting period into
required summary format.
,_ Transcribe injection well test data.
Forward with transmittal letter/memo to
Operator's Office.
Review report for accuracy and completeness
(field and district levels).
^ District Manager/Division Headquarters sign
form.
Forward to state agency.
j Minimal internal dissemination and filing.
Each of these steps requires effort or activity on the
;part of an injection well operator. Some of the steps
are primarily clerical, others technical, and yet others
managerial in nature. Also, distinctions can be made ;
to whether the effort (and therefore the cost) associated
13AGE NUMBER X\\'
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3
TH!S SHEET TO BE USED FOP SCANNER COPY ONLY
10 PITCH
173 OR COURIER 12 MOClF'ED
CCUBL3
r< INCHES (BORDERS INDICATED)
USE :> 1
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jwith a particular task is essentially variable (dependent
on the number of wells involved in a report) or fixed
(little or no difference in costs as the number of wells
jin a single report). Table XII-10 presents a profile
of the characteristics of the reporting tasks. i
i
i 3. Reporting Practices
i
As described in Chapter V, profiles of current reporting
practices were developed for both SWD and ER injection
I
wells based on the various state requirements now in :
force. Categorization schemes were developed and well !
populations apportioned to one of five levels of required
reporting. Based on these profiles, costs can be
estimated and weighted to provide a national average
"unit cost."
4. Development of a "Unit Cost"
^Estimates of the time requirements and associated
hourly costs were prepared for each of the eleven tasks
These were then considered with the required frequency
in order to develop estimates of the "per well" and
"per report" costs. Table XII-11 presents this
analys is.
GE NUMBER
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TABLE XI1-10
Task
Fill out identifying demographic information
(operator's name, location, well #'s, date of
report, etc.) on report form.
Retrieve and transcribe summary surface injection
pressures as required on to report form from log.
Transcribe water analysis conducted during the
reporting period.
Calculate total and transcribe volumes of fluid
injected for the reporting period.
Convert injection well test data for tests conducted
during the reporting period into required summary
format.
Transcribe injection well test data.
Forward with transmittal letter/memo to Operator's
Office.
Review report for accuracy and completeness
(field and district levels).
District Manager/Division Headquarters sign form
Forward to state agency.
Minimal internal dissemination and filing
0
PORTING TASKS
Basis of
Variable Cost Skill Level
Report Clerical
Well Clerical
Well Clerical
Well Clerical
Well Technical
Weil Clerical
Report Clerical
Report Clerical/Technical
Report Managerial
Report Clerical
Report Clerical
1
1
1
1
1
1
1
1
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1
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1
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,
Next, using the assumption of either three SWD wells or!
I
10 ER injection wells per report and the category weighjts,
i
unit costs were prepared for two types of injection wells.
t
i
i
Unit costs of $6.16 for SWD wells and $1.08 for ER injeic-
jtion wells were arrived at. These costs represent the
^estimated average costs per well of the additional
j
jreporting required by the proposed UIC program. ;
Unit costs for ER injection well reporting is substantially
i
ilower than those for SWD wells for two reasons: First,;
,a considerably higher concentration of ER injection wells
(82%) than SWD wells (38%) are already making reports
similar to those that will be required under the proposed
i
,UIC program. Second, ER wells (10 wells per report)
are expected to take better advantage of the limited
opportunities for economies of scale in reporting than .
'are SWD wells (3 wells per report) .
i
!
I
I
Table XII-12 presents the results of this analysis,
while Figure XII-1 provides an overview of the components
that contribute to the two unit costs.
PAGE NUMBER
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TABLE XI1-12
CALCULATION DETAIL OF WEIGHTED AVERAGE ANNUAL INCREMENTAL COSTS
Category
A
B,C,D,E
Category Costs
Per Well Per Report
$4.32 $16.83
NNIC NNIC
Category
A
B.C.D.E
Category Costs .
Per Well Per Report
$4.32 $16.83
NNIC
NNIC
NNIC = No New Incremental Cost.
Source: Arthur D. Little, Inc., estimates.
Enhanced Recovery
Category Unit Cost Category
(10 wells/report) Weight
$6.00 .18
NNIC .82
Salt Water Disposal
Category Unit Cost Category
(3 wells/report) Weight
$9.93 .62
NNIC .38
Category Weighted
Cost Component
$1.08
0
Category Weighted
Cost Component
$6.16
0
Arthur P) I irtlp Ir
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THiS SHEET TO 3ฃ USED FOR 3CANNS3 COPY ONLY
173 OR COURIER 12 MODIFIED
DOUBLE
r-. INCHES !BORDERS INDICATED)
USE l i i I ( NOT .i 1 .1 1 )
WHITE OUT OR USE COPR5C
USE 2 HYPHENS
USE A RED PENCIL DOT ป
SPELL OUT COMPANY .-JAMS
USE RED PENCIL
I
5. Reporting Cost Calculation
i
'Overall incremental reporting costs were developed for '
i 1
jboth types of injection wells by multiplying the unit i
; I
jcosts by the projected well populations. Over the first
f t
five years of the proposed UIC program, incremental i
{reporting costs for SWD wells are estimated at $ 1.3 :
i
million and $600,000 for ER injection wells. Table
XII-13 presents a yearly breakout of estimated incremental
reporting costs during the intial five-year period of :
i
the UIC program. i
3 AGE \UMBER
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THIS SHEET TO SE USED FOR SCANNER COPY ONLY
10 PITCH
173 OR CCURiER !2 MODIFIED
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USE l 1 i I ^ '-JOT " ' '
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USE 2 HYPHENS
USE A RED PENCIL COT *
SPELL OUT COMPANY NAME
USE RED PENCIL
XIII. COST TO STATE AGENCIES
A. INTRODUCTION
To estimate the cost of implementing the proposed UIC
jprogram, Arthur D. Little, Inc., has estimated the totdl
effort that will be required in each producing state td
i
effectively enforce the regulations. By subtracting j
5
;
from this total the amount currently spent on similar I
i
existing programs by the producing states, the analysis
j
details the incremental resources necessary to implement
j
i
the full regulatory program. j
The steps in determining the effort required for the |
proposed UIC program are as follows: \
1. Determine the functions that must be per-
formed in a UIC program.
2. Develop a formula to show the relationship
between each of these operating functions
and the number of wells to be regulated.
This formula enables an analyst to cal-
culate the total effort needed to operate
a UIC program in a given state.
PAGE NUMBER /\
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THIS SHEET TO BE USED FOP SCANNER COPY ONLY
iVni i = C'^T OP OSS CC
:j,3ฃ 2 HVPHENS
USE A RED PENCIL DOT
SPSLw OUT COMPANY .\
USE SED PENCIL
3. Estimate the effort it will take to perform
each function in regulating an underground
injection well. As few state programs
currently operate at the level that will
be required under the federal regulatory
program, the time to be spent in each
function has been estimated. The appro-
priateness of these assumptions has been
checked against data acquired by the survey
of existing state programs. Experience in
other regulatory programs has also been used
as a reference.
4. Calculate the amount of effort required in
each state. Using the formula, data on
injection wells in each producing state, and
estimates of the effort required for
each regulatory function, the total effort
required by a UIC program in each state has
been calculated. These figures (expressed
!
in person-years) are then multiplied by estimated
costs for salary and overhead. The result is
an estimate of the annual operating budget
required by each state UIC program.
5. Compare the estimated state budgets with '
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'HIS SHEET 1C BE USED FOR 3CAMNER COPY ONLY
BORDERS INDICATED!
i ( NOT A Ki 1 i
WHITE OUT OR USE CORRECT
USE A REDPENCIU DOT *
SPELL OUT COMPANY NAM
USE RHD PENCIL
existing budgets. From this comparison, the
states that will require the largest program
increases have been identified. The total
amount of additional resources necessary to
implement the full UIC program is also estimated
6. Add one-time costs associated with bringing aj
state program into compliance with the new ;
federal requirement. 1
i
B. FUNCTIONS TO BE PERFORMED IN A UIC PROGRAM i
1
Seven explicit functions can be identified in a program
to regulate underground injection wells: permitting of
j
existing disposal wells; permitting of all new wells
(SWD and ER); on-site inspection; enforcement of regula-
tions; review of complaints; record keeping (logging, i
filing, and review of required reports) ; and general
overhead. The factors governing each of these functions
are discussed below. ;
1 . Permitting of Existing Wells
' !
i The number of permits to be issued each year depends
i
i '
' on the time allowed to issue permits and the number of ,
)
|existing wells. EPA has chosen to permit existing !
!disposal wells (not existing ER injection wells) over
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\ .fiCHES (BORDERS :NDICATEQ;
/.'HIT5 OUT CP USE CCi3P
USE2 HVPHENS
USE A RED PENG! L DC"
SPELL OUT COMPANY "KV
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a five-year plan period. The effort required to permit!
each well will depend, in part, on the number of wells !
i
that are included on each permit; if several wells in >
I
the same field are included on a single permit, the I
i
effort required for each individual well will be reduced.
!
l
In considering the permit, state officials will be
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THIS 3HEHT TO 3c JSE3 FOR SCAMPER CCPY ONLY
'0 ?!TCH OA,'4G=5. (VHIT- CUT OR USE CORRECT
173 3R COURIER ' 2 MOOi = ! ED LO*JG DASHES USE 2 HYPHENS
DOUBLE ' 3ULLETS: USE A RED PENCIL DOT *
Ti INCHES (BORDERS INDICATED1 AOL. SPELL OUT COMPANY NAM;
"-.0. !J3E il^.1 ( ,NCT ji1.il, EDiTiNG USE RED PENCIL
This operation is basically the same as the granting ofi
; |
i
permits for existing wells. The same factors determine;
!
I the effort expended per well. Permits will be required
1
of all new injection wells, both SWD and ER injection
iwells.
i 3. On-Site Inspection
iThe effort devoted to on-site inspection will depend i
|
I greatly on certain policy choices. The percentage of
i
''wells to be inspected each year can be set at a variety
i i
<
!
iof levels. ;
^ i
,For every well that is inspected, the effort required
'will depend on such variables as:
i
| the density of the well population,
: v- the distance between fields,
, o the detail to which seIf-monitoring
; records are reviewed,
0 whether the inspector attempts to observe ;
! actual tests at the subject well, and
', o whether the inspector attempts to obtain
I independent samples for testing.
.Because all UIC wells are subject to regulatory require
O ^ "* ~ \; i ^ * Q r* o
-AVJ C -\O'Vib CM
-------
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.'/(IT; OUT 0ฐ USE C'
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ments, whether or not they must have a permit, the
amount of inspection activity will depend on the total
population of UIC wells in the state.
j 4. Enforcement
i
I
jEach time an inspected well is found to violate UIC
i
regulations or the conditions of its permit, the state
agency will be required to follow through with adminis
i
jtrative and legal action against the violator. The
'effort devoted to each action will depend on:
j ซ the quality of records kept by inspectors,
i
procedures for adjudication of regulatory j
i i
violations in the state agency, and ;
! - quality and quantity of legal assistance
i available to the state agency.
i
Most states report considerable effort in field surveillance,
;but the data in Chapter V suggest a wide variation in the
!expenditure per well for state inspections. An increase in
'enforcement efforts will be necessary, although states may
achieve some savings by combining inspection of underground
i I
I injection with reviews of production and surface disposal
;which are currently more frequent.
!
| 5. Complaints
j
:State agencies are likely to receive citizen complaints
I about illegally operated wells or contamination of :
jdrinking water wells. Investigation of these complaints
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THIS 3HEET TO SE u,SSD =OR SCANNER COPY ONLY
fll^ER SETTING 10 PITCH CHA.'JGHS' ,','HiTE OUT OR USE CCftHEC"
ELEMENT ' "3 OP COLRfEP 12 MCJI'tEQ .-^.NG DASHES USE 2 HYPHENS
SPACING DOUBLE BULLETS USE A RED PENCIL DOT *
VARGi'-iS. T3 ,,MCHES iBORDERS !NDICA"Di Aฐ'~ SPELL OUT COMPANY NAME
3 V.3-3RAPH ฃ\D*\G. USE.il.il (NiCT .I'll', ECiTiNG USE RED PEiMCiL
I by the staff regulating underground injection will j
! I
jrequire additional effort. The time necessary to examine
i
each complaint will depend on: j
i
I
e travel time from state offices to the j
1
site of the complaint, and j
o the thoroughness with which the complaint
is investigated (e.g., Are samples taken?
Are nearby wells inspected?) . j
J
6. Report Review and Data Processing '.
The volume of reports received by some state agencies
will increase under the federal UIC program. While
some states do require monthly reports from permitted
i
wells, many states, including Texas and Louisiana, requdre
i
ireports only once per year or on request. Federal
.requirements for annual reporting by well operators wild
.probably result in some changes in state procedures.
|The cost of report processing will depend on: \
I j
' i
o whether professional staff review incoming
; reports, and
; v- the efficiency of the filing or data ;
' processing system used to keep track of
the submitted reports.
PAGE NUMBER
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i 7 . Overhead
!
t
j Even the smallest producing state will require some
|
j resources to set UIC policy and establish basic maps
j
t and administrative procedures. Semi-annual reports
I
to the federal government will be required of the
designated states running the UIC program. As the
1
number of wells to be regulated grows, the burdens
imposed on the central staff by these tasks will increase,
but not in direct proportion to the number of wells
regulated.
C. DETERMINATION OF RESOURCE REQUIREMENTS
The staffing requirement for operating a state UIC
program can be summarized in the following equation:
1 .
2.
3.
4.
5.
6 .
2 Permijts for Existing^ We lljs.
7 .
M = O + ND"~P + Nn-P + NT-m-M + NT-m-i'E + NTcC + NTR'f
M is the total required staffing for the state
s
program.
1. Overhead. O represents overhead functions
required by any state programs.
-P represents;
AG5 DUMBER
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THIS SHEET TO BE USED FOR SCANNER COPY ONLY
1 "3 DP> CCURIHR 12 MODIFIED
;O^BLE
1 ; INCHES (BORDERS INDICATED)
'.VHiTE CUT OR fSE CGRR
USE 2 HYPHENS
USE A RED PENCIL OCT
SPELL OUT COMPANY '!A.'"
USE RED PENCIL
the manpower required to issue permits for existing
wells. N_ is the number of existing SWD wells in
i
the state. F is the time period over which the
permit is issued. P is the average number of man-j
hours required to issue a permit.
j
3. Permits for New Wells. N -P represents the i
staffing required to permit new wells each year. i
N is the number of new wells (SWD and ER) for
n ;
which permits are sought. Again, P is the average!
t
number of man-hours required to issue a permit. <
4. On-Site Inspection. N -m'M represents the ;
personnel requirements to monitor compliance with
operating regulations through on-site inspection.
N is the total number of underground injection
wells (SWD and ER) operating in the state. m is
the percentage of wells to be monitored each year.,
M- is the average number of man-hours required for:
a monitoring inspection.
5. Enforcement. N m * i E represents the additionial
personnel requirements for enforcement actions on non-
complying wells. As before, N is the total numbeir
of all injection wells in the state, and m is the '
percentage of wells monitored. i is the percentage
of wells monitored that are foundto be operating ,
IF NUMBER
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THIS SHEET TC 35 t'ScD rQR SCANNER COPY OMLY
VHiTE CUT OR 'JSE CCRPEl
* -? 7R COURIER 12 YIQOI = '=C i-I^G DASHES -^Sc 2 HYPHENS
5Lc -3UL.'_ETC USE A RED PฃMC!L D0~ ป
' '; .TJCHES iBOROcHS INDICATED' AOL. SPELL O'JT COMPANY \A*i;
USE =?ED PENCIL
) in violation of regulations. E is the number of
I
staff-hours required to take further action to enforce
1
j the regulatory requirement.
i
I 6. Complaints. N -c-C represents the effort
j required to investigate complaints of groundwater
I
i pollution or illegal well operation. N is the
total number of wells in the state; c is the
I frequency of complaints; and C is the time required
j ;
' to investigate one complaint.
'] 1. Report Review and Data Processing. N is the :
j number of UIC wells in the state. R is the time
t
I ;
i it takes to review, process, and record a single
\
report. f is the frequency of reports to the state
' agency by the permitteeonce per year under the
' proposed regulations.
Once the personnel requirements of the state oroaram are
idetermined from these relationships, the cost of the
', program is determined by multiplying the total number
of staff-years of effort by the average cost cer staff-year
1 (including salary, fringe benefits, and overhead expenses) .
i
i
i
!D. ESTIMATED COST OF STATE UIC PROGRAMS :
'With sufficient time and resources, it would be possible
UMBER
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10 PITCH
173 OR COURIER '2 MCDI = I=Q
DOUBLH
ARGINS. T2 INCHES (BORDERS INDICATES!
=.\DI-;G. usE^l^l ;NOT -i-n
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"HSS SHEET TO BE USED FOR SCANNER COPY ONLY
10 ?;7CH
173 OP COURIER 12 MCDIF'-D
DOUBLE
1'i INCHES (BORDERS INDICATED)
USE 11:. 1 ' NOT ,11 _\ : i
CHANGES' WHITE CUT CR USE CCFRSC'
3MG DASHES: USE 2 HYPHENS
3U LISTS. USE A RED PENCIL QCT ป
ADL SPELL OUT COMPANY NAVE
EDIT'NG USE RED PENCIL
Column 1
i
Number
j
1. Overhead. A minimum of one position is assumed 1
__ ;
for office management in each state program. A i
!
maximum staff of four is assumed for policy ;
|
setting and overall management in the largest :
state, Texas. States with less than 2000 wells
are assumed to have one overhead position, with ;
additional positions added as the number of wellis
\
increases, until a maximum of four is reached at
47,000 wells. !
2. Permitting. Permits for existing SWD wells will
be issued over a five-year period; thus, one-fifth
of existing wells are reviewed each year (= 0-20).
F ,
i
The effort required to issue a permit is based an
experience in the water pollution program. Infor-
mation for the NPDES system indicates that three!
staff-days will be required for routine permit
!
issuance. About 10% of all permits will raise |
major issues and will require 19 staff-days for
permitting. Thus, by analogy to the NPDES system,
it is assumed that the average nermit will require
five staff-days to process. This assumption produces
ฐAGENUMBER
-------
THIS SHฃ=7 TO 3E USED FOR SCA.NMER COPY ONLY
1 j J1~CH
173 OR CCL.3IER '.2 MOOIFiED
DOUBLE
"2 ifjCHES aOBOtFtS INDICATED!
^SS .ll^I ( ,\'0~ J, 1 .1 1 }
lUT OP L.SE CORRECT!-JG
'vSc 2 HYPHENS
JSE A RED PENCIL DOT *
SPELL OUT COMPANY ^JAMS
use ,=>ED PENCIL
a cost for permit processing of approximately i
I
$600, very similar to the per permit costs reported
i
!
in Texas and California. j
It is likely that each permit for existing wellg
|
will cover more than one well. The effort has '
been calculated using an assumption that one
permit application will cover three wells. This
indicates an average of 1.67 staff-days per well
for permit review. Existing disposal wells in
i
common ownership and in the same geographic '
area will likely be submitted together for
permitting and review, and some determinations
will be based on information already in state
files. The cost for permit review on existing j
disposal wells will be $197.
New Wells. New wells seeking permits each year .
are estimated at 4% of the population of existing
j
wells in the state at the end of 1976. This i
number of new wells is multiplied by the same
number of staff-days per permit as used for existing
!
wells. We assume that an average of three wellg
will be included on each permit because new ER :
PAGE NUMBER
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THIS SHEET TO 3E USED FOR SCANNER COPY ONLY
10 =!"CH
1^3 OR COURIER 12 MODIFIED
DOUBLE
''2 iNChES iBORDERS i.NDiCATEDl
USE ,:> 1 i I ( >,OT ,i 1 ^ 1 j
v'.'HiTH OUT OP USE CC
USE2 HYPHENS
uSE A PE3 PENCIL 001
SPELL OUT COMPANY '
USE RED ?ENC;L
injection wells will be submitted for review
on a project basis, with several wells in a
group application.
Surveillance and Inspection, This report assumes
one day for each well inspected, with 5% of
wells surveyed each year on a random basis (m = .0,
This term is very sensitive to the desired inspec-
tion frequency (as is the final result) . Inspec.-
i
tion of 10% of the wells each year doubles the j
!
i
manpower in this column. ;
i
Enforcement. One well in every 10 is expected to
show violations requiring action (i = O.10). The
mean time for each enforcement action (E) is i
\
estimated at four weeks (20 staff-days). ;
05)
_Complaints . Data were insufficient to calculates
complaint incidence, c. Where the number of
complaints received in the prior year was reported
by the state agency, this number is multiplied by an
estimate of one staff-day to investigate each complaint
(C = 1 ) . !
Report Review and Data Processing. N is the
AGE DUMBER
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THIS SHEET TO 3ฃ USED FOR SCANNER COPY ONLY
' " OP COURIER *2 MOOIe!SD L3NG DASHES. -SE 2 HYPHENS
DO-.3LE ^1-i.LSTS. U'SS A RED 3ฃ.\CIL OCT '1
r, INCHES :BORD?RS INDICATED' AOL. SPELL OUT CCVIPANY NAVE
USc :, 111 ( NOT j, 1 i i ) ฃ~!7::
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8
1
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THIS SHEET TO 3E USED FOR SCANNER CCPY ONLY
1 '2 INCHES .3CRDERS INDICATED!
USE :. 1 =1 I ; MOT A 1 j. 1 )
V-'.'TS CUT OR USE CCRR
USE2HVPHENS
USE A RED PENCIL DOT
SPELL GUT COMPANY NAV
USE RED PENCIL
9. Total Cost. Person-years are multiplied by $26,000
;
The average cost per staff-year in the NPDES permit
I
system is estimated at $22,500. This number
includes salary and fringe benefits and is based
I
t
on an estimated 70/30 split between professional!
and clerical time. Another 15% is added here far
overhead items including costs for rent, light,
telephone, and duplicating and other similar
direct expenses. These are the only amounts that
would have to be appropriated to start or expand
a program. (Higher overhead charges might be
imposed on a federal grant program, depending on
the sophistication of the state accounting systesm.)
The total cost per staff-year used here is $25,875
rounded to $26,000. This column gives the resource
requirements for a complete state UIC program. :
10. Current State Co s^ts were compiled from the survey
of state agencies. The estimated percentage of
1
effort for permitting and surveillance of injection
wells was multiplied by the state agency budget.,
These figures are sensitive to subjective estimates
by state officials on the relative distribution 'of
agency activities. State agency budgets are
?-AG= VJUMBER X "< -
-------
THIS SHEET TO BE USED FO.R SCAMPER COPY OMLY
10 ^ i 7 C H
1 73 OR COURIER 12 ป1CD!ri=D
DO'^eLc
I'.- INCHES ,'SORDERS !r-iO!CAT = C',
USE -1 I J. 1 ( NOT A. 1 .>, 1 }
.VH;Tฑ ou~ C" USE C
'-Sc 2 HYpnSMS
>JiE A RED PENCIL CO
SPELL OUT CCWANY
jSฃ RED PENCIL
shown in Chapter V
11. Difference. This column shows the difference \
between the estimated amount required using the^e
i
1
!
assumptions (Col. 9) and the amount currently
spent on UIC (Col. 10). This is the incremental]
annual cost, in current dollars, of implementing
i
the UIC program. j
|Based upon this analysis, few states appear to be j
t ซ
': spending enough money to meet the needs of a full federal
IUIC program. Only Louisiana, Alabama, and West Virginia
i
appear to be spending more than is required.
i Several states would be required to spend considerable ,
!
; sums to implement a full UIC program. Texas, Oklahoma,,
-Kansas, Illinois, and Kentucky will be required to
make the largest increases.
!Incremental annual expenditures for the UIC program
t
i
iin 25 target states will run from $2,651,000 to
: $2,976,000.
DUMBER
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THIS SHEET TO 3ฃ USED FOR SCANNER COPY ONLY
1^3 OR COURIER !2MCDIci=O
DOUBLE
i '2 i.NCHES (3ORCERS !MD!GAT~
USE --l.il ( MOT Ji 1 i 1 )
G DASHES.
BULLETS.
AOL
ED!T;,NG
v/HITE OUT OR USE CORREC
ijฃE 2 HYPHENS --
USE A RED PENCIL DOT H
SPELL OUT COMPANY NAME
USE RED PENCIL
All preceeding estimates focus on annual operating cost's which
i
I
can be expected in the first five years of a federal UTJC
program. (Costs are in constant dollars with a 2.5% nat
{increase in the total number of injection wells operating
I i
leach year.) it should also be noted that a state mav refuse
'to seek certification under the new federal UIC prograirt,
in which case the EPA will be required to administer
a federal UIC program which will have a cost equal to
the amount shown for that state in Table XIII-1. This
cost will be entirely over and above current state
expenditures. ;
E. START-UP COSTS ;
States will encounter special one-time costs as they
seek federal approval under the new UIC program. These
distinct start-up costs can be defined for:
a drafting and approval of the state UIC plan
and implementing regulations;
c development, or modification, of a computerizesd
i
data processing system in states with a large
volume of permitted wells, and
o designation of underground sources of drinking!
water, as described in the proposed regulation;
PAGE \ljMSER
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THIS SHEcT TO 3E USED FOR SCANNER COPY ONLY
;c PITCH
1 73 OR COURIER 12 %'COI-i=3
DOUBLE
Vi INCHES 'BORDERS INDICATED)
USE >_ 1 i i ; \o~
WHITE O'J~ OP 'JSฃ CC
USE 2 HYPHENS
USE A RED PENCI^ CC
SPELL OUT COMPAN"
USE RED PENCIL
40 CFR 146.04; the state must protect aquifers
with better than 10,000 ppm of total dissolved
solids except for certain identified exceptions
]Preparation of the plan and implementing regulations i
{ i
will probably require the services of a lawyer, half :
i
jtime for one year. In the largest state, the equivalent
of one staff-year may be required to draft new Drogram .
documents. One year of a junior lawyer's time is
estimated to cost $26,000.
!Costs for starting up the reporting and data processing;
(
'system have been taken from a report by Arthur Young &
; 2
(Co. to EPA. A simple manual report filing system in
ia state with 1000 wells is expected to cost $8,700 to
;start including the addition of new data. For a large
state (35,000 wells), Arthur Young & Co. estimates the .
.start-up costs of three alternative computer systems
!at $448,000 to $458,000. Much of these costs is ;
i !
i i
i
.associated with the loading of data on a federally
i
.designed system. In some cases, large states may choose
-to modify existing data processing systems to produce
ifederally required reports. We have used the Arthur
Young & Co. estimate to derive a figure of $12.80 per
2. Arthur Young and Co. , op.cit.
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THIS SHEET TO 3c USED FOR SCANNER COPY ONLY
10 PITCH
173 CR CCuR'.EP ' 2 VCOI F' ED
DOUBLE
r; INCHES .3ORCERS .NDICATEC)
OSS .. l.ll NO- A 1 ' ' )
C3 DASHES.
3ULLETS.
ECIT;NG,
A'HITH OUT CP 'JS3
;LMBER X
-------
THiS SHEET TO 3E USED FOR SCAMNER COPY ONLY
H = 5 .30RDERS INDICATED"
;
jldentification and designation of these areas will not
I
be a simple process. Well operators will seek to have
i
;deep aquifers not currently used or protected exempted
'from protection under the new regulations. The exact
jextent of these deep aquifers not currently used as
i
^drinking water sources (particularly those over 3000
ppm of total dissolved solids) may not be known. Addi-
^tional information may be necessary to determine the
I
boundaries of exempted aquifers.
As a point of reference, AppendixF contains the esti-"
mates made of the costs of fully mapping all protected;
aquifers. As a crude estimate of the costs associated
' only with the designation of exceptions under Section ,
146.04, we have taken 10% of this cost. This work '
' would be split over two years and add $2,174,000 to
! total cos ts.
A summary of start-up costs is shown in Table XIII-2. ,
Costs in the first year of program implementation are -
!
i
! $3,159,000. In the second year, when disputes over
|
'' exempted aquifers are still in progress, the cost of
!
I
! hydrologic work will add another $1,087,000 for a total
! two-year start-up cost of $4,246,000.
?
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-------
THIS SHEET 70 BE USED FOR SCANNER CCPY ONLY
. p ~? ~ ;'
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0T
jF. SUMMARY
J
^
,A summary of total and incremental costs for state
agencies is shown in Table XIII-3. Over five years,
total state expenditures for UIC in the oil and gas
industry are estimated at $39,042,000. Incremental cosฃs
associated with adoption of the new federal UIC program;
are estimated at $ 1 8,032--$4,246,000 for start-up costs:
!
and $14,056,000 for additional operating costs. The '
i
highest additional expenditure will occur in the first I
i
year--$5,811,000 in 1977 dollars. i
-------
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t-_ , rป r -
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PARAGRAPH E\:-:\C-
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ADL: Sf ELL CUT -
EDITING USE FED ฃฃ
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CHAPTER XIV
SUMMARY OF COSTS TO OIL AND GAS PRODUCERS '
!
i
The incremental costs to oil and gas producers result- j
ing from the proposed UIC program have been presented
in Chapters VIII through XII. In order to facilitate
examination and review of these cost estimates, a cost
summary has been prepared. Table XIV-1 presents a
i
[line-item summary of those incremental costs that will !
i
|be incurred by oil and gas producers during the first
five years of the proposed UIC program. The costs
have been broken out into two major categories (non-
-recurring costs and recurring costs) and are grouped
according to type of injection well.
PAGE NUMBER
(in red1
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APPENDIX A
ARTHUR D. LITTLE, INC./INTERSTATE OIL COMPACT COMMISSION
SURVEY OF STATE AGENCIES
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Arthur D Little.
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APPENDIX B
EPA REGIONAL OFFICE SURVEY
INJECTION WELL POPULATION
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DEFINING THE POPULATION OF WELLS
1. On a total state basis, what was the population of wells as of December 31, 1976?
a. oil production wells
b. gas production wells
c. natural gas storage wells
d. oil and gas related injection wells
e. abandoned wells for which the state has data on location, completion, and
f. abandoned wells for which state only has location and depth data
g. estimated number of abandoned wells for which state has no data
2. On a total state basis, how many wells are currently used for subsurface injection
water associated with oil and gas production?
a. annular injection at an oil or gas production well
b. injection at a formation water disposal well
c. injection of formation water for secondary recovery or water flooding
plugging
of formation
3. On a percentage basis, what is the approximate division of the injections into well depth categories?
Well Depth Disposal Secondary Recovery
0 - 1 ,000 feet
1,000 -3,000 feet
3,000 - 6,000 feet
over 6,000 feet
Total 1 00% 1 00%
4. In order to establish some broad completion technology categories, approximate
wells divided by years in which they were completed.
Producing Secondary
Oil and Disposal Recovery
Gas Wells Wells Wells
Prior to 1 940
1940- 1950
1951 - 1960
1961 -1970
After 1971
Total
Annular
100%
the number of
Currently
Abandoned
Wells
Arthur D Little. Ii
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DEFINING THE POPULATION OF WELLS (continued)
5. In 1976, how many permits were issued?
a. oil and gas production wells
b. annular injection at production wells
c. disposal wells
d. secondary recovery wells
e. gas storage wells
f. well abandonments
6. If there is a requirement that ground water of 3,000 IDS or 10,000 TDS be protected by surface
casing through the zone with cementing below the zone, approximately what percentage of wells
would not currently comply with the requirement?
Producing Secondary Abandoned Wells Abandoned Wells
Oil and Disposal Recovery Recorded by Not Recorded
Gas Wells Wells Wells by the State by the State
3,000 TDS
10,000 TDS
7, For each state, approximately how many producing or abandoned wells will be in total within a
one-half mile radius of a disposal or secondary recovery injection well?
8. A proposed definition of the "zone of endangering influence" around an injection well within which
other wells would have to be checked for adequate completion and plugging is "the lateral distance
from an injection well or injection well pattern, in which the pressure change resulting.from the
injection operation would cause a rise of injection fluid, formation fluid, or a combination
thereof, to a height sufficient to intersect underground drinking water sources."
On a state-by-state basis, what on average is the implied size of such a zone?
9. Approximately what total volume of fluid is being injected each year associated with oil and
gas production?
Disposal Secondary Recovery Annular Injection
Volume/Year
10. On a state basis, of those producing and abandoned wells for which the state will at least have
location and depth data in the files, what is the approximate percentage breakdown of their ex-
isting completion and plugging program?
Arthur D Little, Ir
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ABANDONED WELLS
a. Abandoned wells plugged below the fresh water zone and with surface
casting through the fresh water zone cemented below the zone.
b. Abandoned wells plugged below the fresh water zone, with the surface
casing through the fresh water zone but without cementing below the zone.
c. Abandoned wells plugged below the fresh water zone, but without surface
casing.
d. Abandoned wells not plugged below the fresh water zone and without
surface casing.
Total
PRODUCING WELLS
a. Producing wells cemented to prevent fluid migration out of the produc-
tion zone and with surface casing through the fresh water zone cemented
below the zone.
b. Producing wells cemented at the production zone, with surface casing
through the fresh water zone but without cementing below the zone.
c. Producing wells without surface casing.
Total
11. For the injection operations themselves, give an approximate breakdown of existing
and practices.
Secondary
Disposal Wells Recovery Wells
a. Wells with casing and cementing which
prevent the migration of fluids out of
the injection zone and a packer set im-
mediately above the zone.
b. Wells with casing and cementing at the
injection zone but without a packer
at the zone.
c. Wells without casing and cementing or
a packer at the injection zone.
Total 100% 100%
Return to: Richard Williams
Arthur D. Little, Inc.
35 Acorn Park
Cambridge, Massachusetts 02140
100%
100%
technology
Annular
Injection
100%
A.I
Arthur D Little, Ii
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APPENDIX C
FIELD INTERVIEW GUIDE
ArtKnr n I it-tip Inr
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Date:
Interviewer:
INJECTION WELL - FIELD MONITORING PROCEDURES
Classification:
SR: Unitized:
Non-Uniti:
SWD: Contract:
In-House:
PART1
Operator: (Name)
Large Operator:
zed* Small Op^ra*nr-
Small Operator:
Urban:
Rural'
i lrh-irv
Rural:
Dense:
ซ? ปซป
Sparse:
(Address)
Owner: (If Different) ( Name)
(Address)
Field:
Size of Operation:
Ground Water Characteristics:
Depth:_
Quality:
Name:
Name:
Name:
Name:
Name:
; Water Supply: Yes
Interviewed:
Title:
Title:
Title:
Title:
Title:
No
Tel:
Tel:
Tel:
Tel:
Tel:
A_*U.... Pv I ;ซ.ซ.! I,
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PART 2
WELL SPECIFIC INFORMATION
Age of Well: (year drilled)
Depth:
Injection Pressure: Volume:
Construction Details:
Surface Casing Feet
Cemented from Feet to Feet
Fresh Water Protected to (Depth or IDS)
Tubing and Packer:
Annular Injection:
Other:
Arthur Dl ittleln
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PART 3 (continued)
WHO COLLECTS MONITORING DATA?
Job Title (Training):
Employed by:
Hourly Wage:
Other Responsibilities at Work:
Supervised by (Title):
Does This Person Deal with State Inspectors:
COLLECTION PROCESS
1. Assignment Policies
Frequency of all visits to this well:
Who Assigns:
Regular schedule/discretionary?
On which visits are readings taken:
Frequency: % Total Visits:
2. Travel
Method of transport:
Time between stops (wells):
Duration of visits:
Upsets in schedule (cause/frequency):
Number of wells visited in typical day:
Production: SWD: SR:
Arthur n 1 it-tip Inr
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PART 3 (continued)
Differences in monitoring visits for different types of wells: (Discuss company policy
and actual practice)
3. Reading Pressure (at this well):
Is gauge on well? Yes: No: Type:
If gauge is not on well, how is pressure read?
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[If you need more space, it is provided at the top of next page.]
Volume: Yes: No:
(If not read at wellhead, indicate where read:
Refuel Pumps:
Source of gauge: Type:
Set-up time:
Readings taken:
Injection Pressure: Yes: No:
Annulus Pressure: Yes: No:
Time for readings (includes set-up and takedown):
Total time spent at well:
Reasons for reading:
Other activities while at well:
% of Visits % of Time in
Activity This Occurs Average Visit
Machinery Maintenance:
Collect Crude:
-------
PART 3 (continued)
% of Visits % of Time in
Activity This Occurs Average Visit
LOGGING READINGS
Are readings logged each time they are read? Yes: No:
If not, how frequently are readings logged?
Where is log book kept? ___
Are readings entered directly in log? Yes: No:
Other means of primary data recording:
How many wells per log book?
FIELD INFORMATION CYCLE
Chain of data recording (start with well and indicate each level to which data is transferred):
1.
2.
3.
4,
5.
6.
Number of primary records (logs or other):
per weU
per field
I irrip Ir
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PART 3 (continued)
Frequency of data consolidation:
Pressure Volume
Weekly:
Monthly:
Other:
Who transcribes and consolidates pressure data?
Weekly:
Monthly:
Other:
Ultimate disposal of raw data collected in field:
Review of consolidate data:
Title Level of Consolidation Frequency
1.
2.
3.
4.
J| Use (*) to denote last level prior to reporting to state.
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PARTS
GENERAL OBSERVATIONS
How do monitoring operations in this field compare with other company operations?
What effect does state regulatory policy have on well monitoring?
Does State make random inspection of wells?
Type: (SWD/SR) Frequency:
Actions of State inspector:
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PART?
OBTAINING A STATE PERMIT?
What does the operator do?
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_ What special precautions do you take with high-risk wells? (Specify)
Construction:
B Monitoring:
I
What area is reviewed to determine affected wells?
What records reviewed:
Own corporate records
Other corporation records
State records
Tobin or other maps
What criteria are used to determine if a well requires action? (Specify)
Test results
Casing and commenting data
Report and map data
State requirements
Company requirements
What action is taken?
Cement above and below injection zone
Plugging
Special monitoring, etc.
Can you identify a high-risk well (one that is likely to leak or provide a conduit for fluid migration)?
What are the key identifiers of high-risk wells?
Arthur Pi I itflp In
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APPENDIX D
RELATIONSHIP OF HAZARDOUS WASTE REGULATIONS TO
UNDERGROUND INJECTION CONTROL PROGRAM
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APPENDIX D IN PREPARATION
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APPENDIX E
PRODUCTION WELL COVERAGE MODEL
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I. INTRODUCTION
The purpose of the well covering model is to estimate the fraction of production wells
covered for alternative radii of review. The model produces an estimate on the basis of
analysis of 77 sample well fields in the United States. The model is based upon a number of
assumptions which we believe are reasonable. In addition, the results of the model are
relatively robust to variation between the assumed conditions and the real-world conditions.
A detailed description of the model is presented below.
II. MODEL DESCRIPTION
The model is a probability model in the sense that it calculates an estimated probability
of coverage for any production well within a certain portion of the well field. The model is
based upon the assumption that the new injection wells will be placed in a relatively uniform
grid pattern over the well field. In addition, it is assumed that the new injection wells will be
placed within the sample well fields in proportion to the number of injection wells already
drilled within the well field.* The result of the two above assumptions is the depiction of the
sample well fields as shown in Figure 1.
D is the average inter-injection well spacing, if the well field is fully drilled with new
injection wells. In the initial years only a fraction of these new injection wells will be in place.
We assume that within the remaining possible new injection well positions, a new injection
well is positioned randomly. Notice that surrounding each injection well (denoted by an "x")
there is a near zone area where we do not expect to find any existing production wells. Exist-
ing production wells are assumed to be located randomly within the remaining well field area
(the "swiss cheese" topographical area). If the well field has a number of new injection wells
drilled in it, then the percentage of producing wells covered is essentially the ratio of the
producing well area covered by the injection wells to the total producing well area.
For the purposes of model development we do not have to look at the entire area
indicated in Figure 1, but only at one representative square whose four corners are new
injection well sites. By taking a probability approach, we can develop statistics which
represent coverage percentage estimates for the entire field. Further, by averaging these
estimates for each of the 77 sample well fields, we can produce an estimate of the percentage
of total well fields in the U.S. which would be covered within a given radius of review of new
injection wells.
"This assumption was made because no information was available on the condition of each of the 77 sample
well fields. Given information on the ability to develop the sample fields, it would be possible to more selec-
tively allocate new injection wells to the sample well fields.
ArtKnr
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FIGURE E-1 IDEALIZED NEW INJECTION WELL GRID PATTERN
Arthur D Little, Inc
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The statistics developed for the "average" square apply because the average number of
wells covered in the entire well field can be estimated by adding up the average number of
well fields covered for all the squares in the entire well field. Figure 2 depicts the average
square. D is the average inter-injection well spacing.
D
FIGURE E-2: AVERAGE WITHIN NEW INJECTION WELL SQUARE
Given there are M injection wells drilled in a well field containing N when fully drilled,
the probability that each corner of the square is drilled can be calculated. In fact, taking into
account symmetries there are six possible combinations of well drillings that could occur for
the "average square."
Configurations
I No covered nodes 1 Symmetric configuration
Probability
PT = 1 --
1 \ N
II One covered node 4 Symmetric configurations
'M1
M
P,, = 4 1-
N,
N
M;
III Two adjacent nodes - 4 Symmetric configurations Ptn = 3( ) (1
1 v N / \ N
/
MN
IV Two diagonal nodes - 2 Symmetric configurations PIV = 2( I [1
lv ' N / V N
M
V Three corners covered - 4 Symmetric configurations Pv = 4[j [1
N
N
VI Four corners covered - 1 Symmetric configuration PVI = I
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For each one of these six possible injection well configurations the percentage of the
"average square" which is covered by new injection well areas of review is a function of the
relationship between the radius of review r and the average inter-injection well spacing, D.
The fraction of the production wells covered in the "average square" is equal to the percent
of "average square" area covered under the assumption of uniformly random placement of
production wells in the "average area."
Radius Groups
D
Case 1: 0 < r <
2
% Area covered = 0
AZONE
II
% Area covered =
D2 - AZONE
III
fir
9
AZONE
% Area covered =
D2 - AZONE
IV
% Area covered =
rrr"
~2
AZONE
% Area covered =
VI
% Area covered =
D2 - AZONE
3 3
4?rr2 4 AZONE
D2 - AZONE
rr2 - AZONE
D2 - AZONE
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D D
Case 2: < r <
2 VT
D
> Area covered = 0
AZONE
II
i Area covered =
D2 - AZONE
III
D2-B-C-2A-
AZONE
% Area covered =
D2 - AZONE
m2 AZONE
C-
2 2
D2 - AZONE
IV
D2-2A-B-
AZONE
% Area covered =
D2 - AZONE
TTT"
"T
AZONE
D2 - AZONE
D2-A-B-
3AZONE
% Area covered =
D2 - AZONE
3?rr2 3 AZONE
2C
2 4
D2 - AZONE
VI % Area covered =
D2-B-AZONE = 7rr24C-AZONE
D2 AZONE D2 AZONE
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D
Case 3: < r < D
2
D
% Area covered = 0
II % Area covered =
m"
4
AZONE
III % Area covered =
D2 - AZONE
AZONE Trr2 AZONE
D2-2E-F- -C
222
D2 - AZONE D2 - AZONE
D2-2E-
AZONE
IV % Area covered =
D2 - AZONE
D2-E-
3AZONE
V % Area covered =
D2 - AZONE
VI % Area covered = 1
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Where:
Area C = 2r
sin
-i
-1
2rJ
D2 -D V2r2-D2
Area E = - 2rtan
D -v/lr'-D2"1
~2
D
L~2~
2 J
D = .1894
= average inter-injection (in miles) well distance
A = Area for each of the 77 sample well fields in 106 sq. ft.
NJN j = Existing number of injection wells in each of the 77 sample well fields.
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APPENDIX F
ESTIMATED COST OF FULLY DESCRIBING AND DESIGNATING THE
UNDERGROUND SOURCES OF DRINKING WATER
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The principal objective of the proposed EPA regulations for underground injection
wells is the protection of the drinking groundwater resource from contamination by the
injection fluid. Under.the proposed regulations, each state shall protect water to 10,000 ppm
TDS, with certain exceptions. Designation of the exceptions requires knowledge of ground-
water which may, or may not, be readily available.
This analysis was developed to estimate the costs of an earlier set of draft regulations
which required states to designate protected underground waters; requiring mapping of
these aquifers. The estimate of the full cost of mapping underground waters is included
here as a point of reference.
There are different ways that could have been used to estimate the cost .of designating
underground drinking water sources, for example, visiting state agencies and collecting
information and data for each state, or summarizing experience through telephone conversa-
tions to knowledgeable people. However, these methods would have been both costly and
time consuming. In view of the limited time and budget that was available, an analytical
method was adopted based on relevant published data.
The cost analysis was based on estimating the cost for a representative analysis
performed for a specific state and then developing analytical formulas for estimating costs
applicable to other states as a function of the cost associated with the specific state. This
cost correlation was assumed to be a function of different parameters, each involving one
or more factors. The four parameters are:
geographical area of the state
population of the state and dependence on groundwater
groundwater resources
subsurface disposal of wastes
There are nine factors that describe the four parameters. Their symbols and units are
discussed below.
I. GEOGRAPHICAL AREA OF THE STATE
This parameter includes the factor:
(1) The area (A) of the state (S)* in (mi2) A(S) [mi2]
This parameter might also have included other factors such as physiography
or the geographical location of the state. However, since the area of the
state seems to be the most important factor, we may reasonably rely upon
it alone. It is clear that the bigger the state, the greater the effort for pre-
paring the insertion of groundwater aquifers.
*(S) in parenthesis indicates the state or gives the state number, that is, S=1, 2,.. .51 (including the District
of Columbia). See Table F-1.
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TABLE F-1
ESTIMATED EFFORTS REQUIRED TO PERFORM TASKS FOR MASSACHUSETTS (S=22)
Range of Efforts
(team-months)
Task
Tl
T2
T3
T4
T5
T6
T7
T8
TV 10
(22)
(22)
(22)
(22)
(22)
(22)
(22)
(22)
(22)
Effort for
Massachusetts
(team-months)
3/4
2
2
1
1
1/2
1
21/2
1 1/4
Allowable for all
the States
1.
1.
1/2.
1/2.
1/4.
3/4.
2.
1.
3/4
....12
....12
....2
6
....3
4
6
....3
T(22) = 12 team-months
= 1 team-year
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II. POPULATION OF THE STATE AND DEPENDENCE ON GROUNDWATER
This parameter takes into account the following factors:
(2) The groundwater use within a state as a percentage of the total
water use. GWU(S) [%]
(3) The population of the state P(S) [#}
(4) The population groundwater use factor for the state equal to:
PGWU(S) = GWU(S) P(S) = (2) (3) PGWU(S) [#]
Factor (4) gives the apparent population that relies on groundwater resources in each
state. It is also clear that the greater the factor the greater the dependence (population) on
groundwater and probably the greater will be the effort for inventorying the resource.
Numerical data for GWU(S) were taken from the Water Atlas of the United States*
(plate 32).
III. GROUNDWATER RESOURCE
This parameter takes account of the following factors dealing with the relative avail-
ability of groundwater within each state:
(5) Groundwater aquifer areas of each state as a percent of the total
area of the state. GWAA(S) [%]
Unconsolidated and consolidated aquifer areas were taken into account and numerical
information was taken from plate 27 of the Water Atlas of the United States. This factor
is not indicative of how much water might be obtained for a specific type of aquifer. Its
usefulness is in defining the parts (% of total) of a state where production aquifers of wide
areal extent can be found and, consequently, may have to be protected.
It is evident that the greater GWAA(S), the more effort would be required to identify
(inventory) the groundwater aquifers in each state.
'Geraghty, J. J., etal., 1973, The Water Atlas of the United States, Water Information Center, Inc.,
New York, New York 11050.
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(6) Groundwater narrow aquifers GWNA(S) [mi]
This factor serves to account for narrow aquifers along rivers where
groundwater can be replenished by perennial streams, including buried
valleys not now occupied by streams.
Only those channels which have been reasonably well defined and are believed to be
capable of supplying at least 50 gallons per minute to an average well were taken into
account. This factor is relevant because sand and gravel beds are among the most productive
aquifers and yields of individual wells in valley-fill deposits are commonly large. Numerical
information is taken from plate 28 of the Water Atlas of the United States. It is evident
that the greater the number of river miles, the more effort would have to be made in identify-
ing the state's aquifers that might serve as a drinking groundwater resource.
(7) General availability of groundwater data in each state given in numerical
form as: high = 3, medium = 2, low = 1 and estimated by inspecting plate 29
of the Water Atlas of the United States AV(S) [#]
Although this factor does not include some investigations being carried out independently
by some states (for example, Massachusetts, California, Louisiana), it illustrates the pattern
of knowledge of groundwater resources and shows the major gaps remaining to be filled for
implementing an extensive UIC program. Under a long-range plan, the United States
Geological Survey (USGS) is working towards obtaining generalized or detailed groundwater
information for the biggest percent of the nation and reconnaissance type information for
the remainder. A complete study has been already performed under the assistance of the
U.S. Army Corps of Engineers for the Commonwealth of Massachusetts.*
It is evident that the greater the data availability, the less effort will be required for
inventorying the groundwater resources of the state.
IV. SUBSURFACE DISPOSAL OF WASTES
This parameter takes account of the following two factors:
(8) Existing number of injection wells (for example, subsurface disposal
of wastes through wells) by means of a well number
NW(S) (#]
States and Federal regulating agencies have mixed views on the whole subject of under-
ground waste disposa^ Some states favor the approach and others have a guarded attitude
about it or else forbid it entirely. Regardless of what the disposal laws might be, the
'Communication with USGS, Washington, D.C.
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probability of contaminating the groundwater resource of a state would generally increase
with the number of existing wells. Numerical information was taken from the earlier parts
of this report.
(9) Geologic suitability for underground waste disposal in each state in
numerical form as: suitable effort level equals 1, possible effort level
equals 2, well suited effort level equals 3. SW(S) [#]
Numerical values were estimated from an inspection of plate 68 of
the Water Atlas of the United States.
It must be recognized that many other factors could have been assigned to each of the
above parameters and also many other parameters could have been added. However, the
parameters selected were based on readily available data that were considered to have uniform
accuracy and precision.
All numerical values of the previously listed nine factors are given for each state in
Table F-2 and in the Columns (1) through (9); as for example:
S= 1, Alabama (AL);A( 1) = 50.9 x 103 mi2, P(l) = 3,462 x 103.
GWU( 1) = 4%, PGWU( 1) = 13.8 x 106, GWAA( 1) = 80%,
GWNA(1)= 1400 mi, AV(1) = 2, NW(1)= 110, SW(1) = 2.
For the purpose of this study, each state was assumed to designate and describe its
potable underground aquifers with the aid of a typical engineering team headed by a project
manager. It was further assumed that a specific state exists that could serve as a base for a
cost estimate. For any state, it was assumed that the team would work for one year (team-
year) and the project manager would work for two years in order to start up and complete
the inventory of the groundwater resource.
As a base state, Massachusetts was chosen because a groundwater inventory has been already
performed. Information also obtained from the USGS in Washington, D.C. lead us to the
conclusion that no other state has completed such a task.
Discussion with the USGS in Boston provided information on the approximate effort
that was required to inventory Massachusetts. This effort was then converted into an
equivalent one-year effort.
In the following analysis, the overall effort to perform the inventory in any other state
is correlated to the effort estimated for Massachusetts by means of a performance index I(S).
This index I(S) consists of the sum of all sub-indexes L(S), that correspond to the necessary
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TABLE F-2
COST ESTIMATES FOR DESIGNATING AND DESCRIBING THE UNDERGROUND
SOURCES OF DRINKING WATER IN THE UNITED STATES
State Index l(s) . Cost
(in OOOs)
1. Alabama (AL) 2.17 851
2. Alaska (AK) 1.91 773
3. Arizona (AZ) 2.94 1,082
4. Arkansas (AR) 2.16 848
5. California (CA) 3.41 1,223
6. Colorado (CO) 2.54 962
7. Connecticut (CT) 0.71 319
8. Delaware (DE) 0.66 297
9. District of Columbia (DC) 0.66 297
10. Florida (FL) 2.11 833
11. Georgia (GA) 2.56 968
12. Hawaii (HI) 0.77 346
13. Idaho (ID) 2.00 800
14. Illinois (IL) 2.49 947
15. Indiana (IN) 1.73 719
16. Iowa (I A) 2.33 899
17. Kansas (KS) 2.66 998
18. Kentucky (KY) 1.20 540
19. Louisiana (LA) 2.01 803
20. Main* (ME) 1.21 545
21. Maryland (MD) 0.72 324
22. Massachusetts (MA) 1.00 450
23. Michigan (Ml) 3.10 1,130
24. Minnesota (MN) 2.35 905
25. Mississippi (MS) 2.15 845
26. Missouri (MO) 2.50 950
27. Montana (MT) 2.26 878
28. Nebraska (NB) 2.87 1,061
29. Nevada (NV) 1.52 656
30. New Hampshire (NH) 0.77 346
31. New Jersey (NJ) 0.89 400
32. New Mexico (NM) 2.74 1,022
33. New York (NY) 1.54 662
34. North Carolina (NC) 1.83 749
35. North Dakota (ND) 1.27 571
36. Ohio (OH) 1.52 656
37. Oklahoma (OK) 2.98 1,094
38. Oregon (OR) 2.53 959
39. Pennsylvania (PA) 1.62 686
40. Rhode Island (Rl) 0.65 292
41. South Carolina (SC) 1.73 719
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TABLE F-2 (Continued)
State Index l(s) Cost
(in OOOs)
42. South Dakota (SD) 1.94
43. Tennessee (TN) 1.92
44. Texas (TX) 3.90
45. Utah (UT) 1.49
46. Vermont (VT) 0.85
47. Virginia (VA) 1.71
48. Washington (WA) 2.60
49. West Virginia (WV) 1.22
50. Wisconsin (Wl) 2.45
51. Wyoming (WY) 1.77
38,270
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tasks that have to be performed by the manager and the engineering team respectively. The
10 major tasks required for a study are assumed to be the following:
I Task 1: Initial meetings, collect and review available data, talk to
knowledgeable persons.
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W For Massachusetts, it was estimated that the above tasks could be performed within one
year by a team organized as described in the following section.
Task 2: Examine and analyze records of public groundwater wells and
supplies in terms of quantity and quality.
Task 3: Examine and analyze well logs (location, yields, etc.), plot and
show the aquifers.
Task 4: Geohydrologic mapping including aquifer potential.
Task 5: Determine areas excluded for water quality reasons (existing and
potential aquifers).
Task 6: Determine locations and numbers of waste disposal wells.
Task 7: Plot aquifers (main analysis).
Task 8: Prepare draft report (one camera ready copy).
Task 9: Obtain comments.
Task 10: Prepare final report (one camera ready copy).
The total cost for any state would consist of the managerial cost and the team cost. For
Massachusetts, the estimated cost is as follows:
Managerial Cost
The Project Manager will be involved with the case for approximately two years and will
need some secretarial services as shown below.
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Hence,
Cost Source Annual Cost ($)
Staff:
Project Manager (including overhead) 330,000
Secretarial Services (including overhead) 15,000
Expenses:
Report Preparation, Communications,
Travel, Miscellaneous, Printing 30,000
Total $75,000
For the two-year period that managerial functions would be required, the total cost is
estimated to be $150,000.
Engineering Team Cost
An engineering team consisting of four engineers, two draftsmen and one secretary
would be adequate to perform the inventory within a year (team-year), requiring the follow-
ing expenses:
Cost Source Annual Cost (S)
Staff:
Four engineers (including overhead) $200,000
Two draftsmen (including overhead) 60,000
One secretary (including overhead) 20,000
Expenses:
Unit's cost 20,000
Total $300,000
During the one-year effort of the engineering team, the team cost for Massachusetts is
estimated to be $300,000. Therefore, the overall cost (managerial and engineering) for
Massachusetts is estimated to be $450,000.
Introducing the index coefficient as previously discussed, the cost for any other state
will be equal to:
Cost(S) = I(S) 150,000 + I(S) 300,000
(Manager) (Team)
where I(S) the index of efforts required for state (S) compared to the effort required for
Massachusetts (S=l,... ,51). However, since managerial efforts cannot be linearly extrapolated
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to the engineering-team efforts (actual work), we further assume that the managerial cost for
any state cannot exceed $200,000 or
Cost(S) = I(S) 150,000 + I(S) 300,000 (Eq.-l)
(< 200,000) (any value)
(Managerial Cost) (Team Cost)
In the following, the methodology for estimating the state's indeces I(S) is given. [For
Massachusetts, I(Mass) = 1(22) = 1 ]
The overall state's index I(S) will result from the sum of the state's indeces Ij(S)
(i=l,. .. ,10) when performing the tasks 1 through 10 as listed above, or:
10
I(S) = 2 L(S), i=l,..., 10 (tasks)
i= 1 V
S= 1,... , 51 (states) (Eq.-2)
(in team-months)
For the different tasks, we have:
Task 1, ^(S): "Initial meeting " ^ (-)
We expect that the effort required to perform this task will be equal for all the states,
regardless of their size (population, area, etc.). We have estimated the effort required for
Massachusetts to be 0.75 (team-months) and, therefore, for every state we may write the
expression:
Ii (S) = Ii (Mass) in team-months
Task 2, I2(S): "Examine and analyze,...." Iz [0),(4)]
Examine and analyze records of public groundwater supplies depends on the number of
supplies, which consequently is a direct function of the area A(S) of the state [factor (1)],
and a function of the number of people using the groundwater resources GWU(S) [factor (3)],
or a function of the population groundwater use PGWU(S) [factor (4)].
Assuming that the effort required for state (S) is a function of the effort estimated
for Massachusetts (typical state) and a function of their area and PGWU ratios and letting
the ratio be modified to an exponential value of 1 /3 for economies of scale,
1/3
A(Mass).P(Mass)
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It is assumed that the minimum effort required for any state to perform Task 2 (only)
is one team-month, and the maximum effort required cannot exceed the 12 team-months.
Task 3,13(S): "Examine and analyze logs " I3 [(1),(5),(6)]
Examination and analysis of the location and yield of logs depends on the area A(S) of
the state [factor (1)] and the extent of the ground water aquifers GWAA(S) [factor (5)], or
on the product of both factors (1) and (5). It will also depend on the length of the narrow
aquifers GWNA(S) [factor (6)], whose existence will cumulatively increase (estimated to a
3/4 power) the effort required to perform the inventory. Finally, the availability of data
records AV(S) [factor (7)] will also affect (power 1/3) the effort required.
Assuming that the disaggregated efforts to be made for state (S) are related (through
the parameters and variables) to the effort required for Massachusetts, the index for I3(S) is:
GWAA (S) A (S) GWNA (S)
I3 (S) = I3 (Mass) + L-L-
GWAA(Ma)-A(Ma) GWNA (Ma)
3/4 , 1/3
AV(S)
It is assumed that the minimum effort required for any state to perform Task 3 is one
team-month, and the maximum effort required cannot exceed the 12 team-months.
Task 4,14(S): "Geohydrologic mapping." UtdX^)]
Since it is clear that the bigger the state, the greater the effort required to perform
Task 4 (however to a power ratio of 1 /3) and also that the greater the availability of data
the less effort will be required (to a power ratio of 1/2) we might write a similar equation for
I4, that is:
r ACS)
I4 (S) = I4 (Mass) '
A (Mass)
It is assumed that the minimum effort required for any state to perform Task 4 is 1/2
team-month, and the maximum effort required cannot exceed the 2 team-months.
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Task 5, 14(5): "Determine areas excluded to water quality. . . .
The team effort requirements within the state will be: a function of the area A(S) and
the Population Groundwater use PGWU(S) or the factor A(S) PGWU(S); a function of the
total groundwater areas or A(S) GWAA(S); and a function of the extent of the groundwater
narrow aquifer GWNA(S). Finally, this cumulative effort will be inversely related to the
availability of data AV(S) of the state. The cumulative effort is adjusted for the effect of
economy of scale to a 2/3 power and the availability to a 2/3 power as previously. The
formula for I5 (S) will be:
r
1
A(S)-PGWU(S) A(S)-GWAA(S) GWNA(S)
+
AV (S)3/2 1 A (Mass) PGWU (Mass) ' A (Mass) GWAA (Mass) ' GWNA (Mass)
2/3
It is assumed that the minimum effort required for any state to perform Task 5 is 1/2
team-month, and the maximum effort required cannot exceed the 6 team-months.
Task 6, I6(S): "Determine waste disposal wells" MCS),
Following the above rationale for Task 6, the following equation is derived:
NW(S) 1 1/3 ,,,
I6(S) = I6(Mass)
NW (Mass)
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It is assumed that the minimum effort required for any state to perform Task 6 is 1/4
team-month, and the maximum effort required cannot exceed the 4 team-months.
Task?, I7(S): "Plot aquifers "
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Again, the efforts required to perform this task will be strictly related to the area A(S)
of the state and inversely related to the availability AV(S) of data, however, adjusted to a
power of 1/2 for economy of scale. Hence:
I7 (S) = I7 (Mass)
A(S)
A (Mass) AV (S)
1/2
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It is assumed that the minimum effort required for any state to perform Task 7 is 0.75
team-month, and the maximum effort required cannot exceed the 4 team-months.
TaskS, I8(S): "Prepare draft report" I8 (All above)
It is expected that the effort required for the preparation of the draft report will be
proportional to the mean of the cumulative efforts required to perform all the Tasks 2
through 7 (Task 1 constant effort) or
i=7
[2ii
i=2
It is assumed that for any state max I8 (S) = 6, min I8 (S) = 2 and that for a high value of
7
. 2 I8 (S) = 5.25 (e.g., California) the maximum theoretical a-value will be equal to a = 1.25
(in that case 1.25 x 5.25 = I8(S) 6.25 > 6.0, we keep I8 = 6), since in that case a lower
relative effort (compared to the sum of efforts) will be required by drafting the state's report.
If so, a-values for the different states will be allocated for Task 8 according to the ratio:
1 i=7 ,
11.2 S Ii(S)
6 i=2
which results from the analytical expression of a straight line, going through points (1.25 ; 2)
and (5.25 ; 1.25) of a cartesian system, or:
ZI^S) -1.25 a(S)-2 11.2 -SIj(S)
(S)
re
5.25-1.25 1.25-2
Finally, for I8(S), we derive:
1 ,=7
Is(S) = S US)
6 i=2 '
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งThis task will require efforts similar to those for performing Task 8. A reasonable
estimate is:
1
I
o (S) = Is (S)
2
As mentioned earlier, the index I(S) for each state will be equal to the sum of all indeces
derived and will be correlated to the indeces of Massachusetts, which was considered to be
our typical state. The team-month estimates for Massachusetts and the minimum and maxi-
__ rnum efforts required to perform the different tasks as mentioned above are given in Table F-l
I
By substituting into the previously derived equations, the I(S) values for Massachusetts
ง given in Table F-3 and taking account for the index variations, were finally derived (team-
months efforts) for:
g Task 1 : Ij (S) = 3/4
Task 2: 1 ^ I2 (S) = 0.29 [(l)-(4)] 1/3 ,
I 0.02
^m. T--I--I. I^T/C*\_ r/i\ / c\ , / s-\
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(7)l/3
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1 111
T-irl- 4- 1 /^ ^" T fV\ .
Task 4. !/2
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EXAMPLE (Alabama, S=1)
To illustrate the use of the above equations, the following calculations for the state of
Alabama (S=l) are performed by using the information listed in Table F-3:
Alabama (AL): S=l; Area A(l) = 50.9; Population P(l) = 3,462;Groundwater Use
GWU( 1) = 4; Population Ground water Use PGWU( 1) = 13.8; Groundwater Aquifer Areas
GWAA(l) = 80; Groundwater Narrow Aquifers GWNA =1400; Availability of Data
AV(1) = 2; Number of Injection Wells NW(1) = 110; Suitability for Injection SW(1) = 2;
therefore:
Level of Effort
Task 1: Ij (S) = 0.75 team-month (t-m)
1/3
Task 2:
Task 3:
Task 4:
Task 5:
I, (1) = 0.29 [(50.9) -(13.8)] = 2.6 t-m
I3(D
U(l) =
M0=-
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[
" 50.9 "
7.8
1
3/4
(50.9)-(80) + (1400)] =10 t-m
1/3 j
1 "> <- ..
1
2 23/2
l.J l-lll
2l/2
"(50.9) -(13.8) (50.9) -(80) 1400
340 234 250
2/3
1.6 t-m
1 f HO 1 1/3
Task 6: I6 (1) = 2 = 0.50 t-m
2 1100
Task 7: I, (1) =
50.9 1
7.8
1/2
= 1.80 t-m
11.2-2.98
Task 8: I8(l) = 2.98 = 4.9 t-m
4.9
Tasks 9, 10: I9 i00)= = 2.4 t-m
Arthur D Little, Im
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State's Index:
10 26
I(l) = SIj(l) = 0.75 + 2.6+ 10+ 1.3+ 1.6 + 0.5+ 1.8 + 4.9 + 2.4 = 26 t-m = = 2.17 team-years
i=l 12
Total Cost
Since 2.17 x 150,000 results to a marginal cost exceeding $200,000, we assume that
$200,000 will be the relevant managerial cost for Alabama, whereas, the total cost for
inventorying the drinking ground water resource will be equal to:
I
Cost (Ala) = 200,000 +2.17x300,000 = 851,000
I
V For the principal state of Massachusetts, we have:
Cost (Mass) = 150,000 + 1 x 300,000 = 450,000
* Table F-2 summarizes the estimates of state indeces I(S) and the cost for implementing
a groundwater resource inventory program. The information for performing the analysis is
given in Table F-3. Table F-4 lists the estimates for performing the subtasks for each state.
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