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r
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i
 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

I
|                            COST OF COMPLIANCE

•                    PROPOSED UNDERGROUND INJECTION CONTROL PROGRAM

•                            OIL AND GAS WELLS

I

I
•                        "      PREPARED BY
"                           ARTHUR D, LITTLE,  INC,
I
                                   FOR
f                         OFFICE OF DRINKING WATER/
                     U,S,  ENVIRONMENTAL PROTECTION AGENCY


                      EPA CONTRACT No, 68-01-4698 (TASK 6)
I

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*
                                JUNE 1979
I
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-
-------
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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•
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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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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
V-1

V-1
V-3
V-5
V-6
V-9
V-1 6
V-22














NUMBER "
(in red)

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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
I


1
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VI-2J
VI-2
VI-4

VI-1
VI-1
VI-1


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0
VI-1 0

VI-2

VII-
VII-
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VII-5
VII-J7
VII-7

VII-

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VII-

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15
15
17
30
                                                                             PAGE NUMBER
                                                                                                iii
                                                                                                (in red

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                     THIS SHFFT TO BE USED FOR SCAMMER copv ON*LY
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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
                                                                            (in red)

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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
X-9
X-9
X-9
X-20

XI-1
XI-3
XI-3
XI-4
XI-5
XI-6
XI-7
XI-8
XI-9
                                                                               PAGE NUMBER
 ADL 1T1 279501.'.
                                                                                                  (in red)

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• THIS SHEET TO BE USED FOR SCANNER COPY ONLY
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
1

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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
r^CiL


I
PAGE

XII-

XII-


XII-
XII-

XII-

XII-



1

2


2
6

1 1

1 3


XII-15
XII-J15
1
XII-J20
XII-J22
XII-22
1
XII-J24
XII-S5
xn-b?
XII-S27
XII-

XIII

XIII
XIII
XIII
XIII
XIII
XIII
XIII
XIII


33

-1

-3
-3
-4
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-6
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-8


NUMBER V1

(in red)

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_ i me, i,. ii-L i i o L.L. L;~L.U ruri ;>ซ/-•;ป ;ktt-; uui- Y UuLY
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
i
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











1
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
T Vr L', . ' i M L. ri 1- LT i i ' 3 1 '• " 'T Crl ^ ' " • ,•!'.'• . ,
H j-f i. 	 	 _y 1 ' . - -; f ,-'.'-:--,', * " -,- [ i -'-, L C)\'C i. ',' 'l_l. VT _ ', * -T " - .-
^,,,,.,,,
1

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1

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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
1 PACt NU:.';L7Lr?

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1
TYf E ••."-• n r "• <--^-r"

i ; ;• ::
PAHAGF A-K cr.'L;i


1
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1

1

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1


1
1

I
fi
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1

1
1
1

, '. 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
                                                             1
 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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1
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
                                                                               iir,

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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
                                                             !

                                                             i

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
                                                              I
                                                              I
  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
                                                              t


  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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                                                            ical
                                                            ion
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
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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
                                                             i
 •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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V,i:? bSLlr.T 10 I,- UoLU Ft.);-; .-'^. !-,•-..•;;: f.'.V -. ...\'LY
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,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
PAGF NU.VS

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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.

                                                                  Arthur!) Lit iljn

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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.
                                                                                 Arthur I M.ittk

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 1
 _            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.
                                                                                 Arthur DI.itlie In

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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.



 I

              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
1
                                                                                Arthur DLutk', in

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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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                                                                                Arthur!) Little

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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.
                                                                                Arthur D

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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
                                                                                          Arthur D Little, Inc

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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
                                                                               Arthur D Little In-:

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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.
                                                                                 Arthur 0 Little I

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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
                                                                                            ArtNurHI irtl,. I —

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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
                                                                             Arthur D I.ittiuhr.

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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



AftllL

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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.
I
 —             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.
                                                                                 Arthur!) hale

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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
                                                                                Arthur I) Little lr

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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.
I

—            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.




                                                                  AithurD Little Ir

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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.
                                                                                 Arthur I) Little

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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:
I
—                 •  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
 I

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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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I
                       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
I

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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)

-------
                     THIS SHEET TO BE USED FOR SCANNER COPY ONLY
TYPEWRITER SETTING'
        ELEMENT.
        SPACING'
        MARGINS.
 PARAGRAPH ENDING.
10 PITCH
173 OR COURIER 12 MODIFIED
DOUBLE
I'-i INCHES (BORDERS INDICATED)
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
            i
            i
            '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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YPEVVRITEH SETTING
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PARAGRAPH ENDING.
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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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                      THIS SHEET TO SE USED FOR SCANNER COPY ONLY
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

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                             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 '_„'>-'^ ; _

                                               L,3E a PHD PENCIL GO"  •ป
                                               SPELL CL.T CC"-'? i,\Y •; , •;
                                               L;3t 3,EZ ?E -C;L
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

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                           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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                                          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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TYPEWRITER SETTING-   10 PITCH
        ELEMENT-   173 OR COURIER 1 2 MODIFIED
        SPACING:   DOUBLE
        MARGINS:   V, INCHES (BORDERS INDICATED)
 PARAGRAPH ENDING.   USE A 1 
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                                   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.

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                                    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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(VHITE OUT OR USE CORRECTING TAPE
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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.
                                                                                               \
                                                                                                I
                                                                                                I
                                                                                                i
                                                                                                i

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JG DASHES   USE 2 HYPHENS
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 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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                                             '.VH1T6 OUT OR USE CORRECTING TAP

                                             USE 2 HYPHENS   	

                                             'JSc A RED PENG! L DOT  ซ
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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                    THIS SHEET TO BE USED FOR SCANNER COPY OMLY
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               10 PiTCH

               !73 CH COU

               OCU81E




               uSc _-. I j 1
WHITE OUT OR USE COP

USE 2 HYPHENS

USE A RED PENC! L 30T
           •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
           t

           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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                                                      053   WHiTE OuT OR L.3E O
                                                      r-Eo,   UGH 2 '-iY?H = *13
 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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                  "O EC USED FC.t SCA.\Nฃ3 3GFY ONLY
                                              WHITE OU~ OR LปS= C

                                              USE 2 HY=>^S3
'S5CT:N*G TAP
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
                                                          j

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 primary—rreae 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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                      •HIS SHEET TQ BE USED FOR SCANNER COPY ONLY
TYPE'.",
 PAF'-i.J
RITER SETTING   10 PITCH
    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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                 THIS SHEET TO 3ฃ USED FOR SCANNER COPY OMLY
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    SPACING
    MARGINS.
GPAPH EMD!fiG
10 PITCH
173 OR COURIER 12 MODIFIED
DOUBLE
••i INCHES;3OR3=RS INDICATE
USE i 1,1 1  i  NOT „ 1 ;„ 1 )
WHITE OUT OR USE CORRECTING '
USE 2 HYPHENS
USE A RED PENCIL DOT ป
SPELL OUT COMPANY ">;A\-F
USE RED PENCIL
'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
        i
        jwells,  accounted for  57%  of the volume of injected fluids.
                                                         PAGE NUMBER
                                                                        ;in re HI

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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
                                                                 S NUMBER

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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
                                                              PAGE NUMBER

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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
                                                  PAGE NUMBER
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             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 •
                                                              PAGE NUMBER

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   BULLETS.
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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
                                                 'AGE NUMBER

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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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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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 TYPEWRITER SETT'NG
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                 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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3NG DASHES.

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     ADL

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        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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       o:.-!G  USE _ 1 il  ; \.;r
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                                    _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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         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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   I

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TYPEWRITER SETTING-
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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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                                       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-

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                                       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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                                       3U-LSTS   uSE A = = C Pc.NCiL OOT *
'captions are Illinois,  Indiana, and Kansas,  which requiire

I
Ian  annual renewal of  injection permits.

I
|
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!      3.   Requirements  for Injection Well  Operating Permits

I                                                          I
The  following material  on injection well  permit requiref-
1                                                          i
i                                                          |
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

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         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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 I

-------
         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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                                           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
                                                               PAGE NUMBER

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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
SPELL CuT CO'VPA%V r.;AV =
   :,?": ?c\ir
         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 ;
                                                          PAGE NUMBER

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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

-------
                                   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    	

USE .1 ^ED PENCIL DOT 9

3P=uL OUT COMPANY NA,V< =

,-SE 3ED PENCii.
  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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  rtJ C
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;;::::;;;; 1 W^


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• — ^-^:* :; ^
) \

CN
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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                      THIS SHEET 70 3E :j'i,ED FCR SCANNER COPY ONLY
•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.                                     '.

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,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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                                    ;C-5C CCฐ SCA^ER COPY ONLY
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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
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'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-/

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                     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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                                              Ar4i wen
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^           symptoms  that  something may be wrong.   Companies establish
                                                                      i
fk          ,their own policies for both the frequency  that  read-   ;

             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	

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         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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                                                    CCDY CNLV
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I
•          . 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
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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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                                         ru.-Y i-CA.-.jiMEH COPY ONLV
 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!

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                                     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




A _*I 	 Pi I :,
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         THIS Sri EC i  T:* 3E UScD ,-OR SCANNER COPY ONLY
 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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         THIS SHEET TC 3E USED FOR SCANNER COPY ONLY
                       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
                                                 'AGE .\UM3cR
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          "HIS GHcET TO BE USED FOR SCANNER COPY ONLY
    10 "ITCH
    ! 73 CR CCURi-3 '2 MCD'.F
    OOU8LE
    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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-------
         THIS SHEET TO 8ฃ USED FOR SCANNER COPY ONLY
    1". INCHES 30RDEBS INDICATED)
T-   i I "
                                        EQiTING
WHITE CUT OR USE CCPSEC
USE 2 r-iv?HE,\S
USE A "ED PENCIL OCT ' ป
SPELL OUT COMPANY '.|,-\<ฃ
USE RED PSNC'L
 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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         THIS SHEET TO 3E UScu FOR 3CAMMER COPY ONLY
(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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         THIS SHEET 70 3E USED FOR SCANNER COPY ONLY
V., i NICHES .'BORDERS I.NDiC
                                               WHITE OUT OR USE CORRECTING
                                               USE 1 HYPHENS
                                               USE A RED PENCIL DOT *
                                               SP=LL CUT COMPANY NAME
                                               USE RED 'EMCIL
 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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    1C PITCH

    173 OR CCU'nicR ^2 MGCIRED

    0 0 L 3 L E

    r, INCHES .BORDERS INDICATED!

    USE i 1 j. 1  { NOT _i 1 i. 1 )
CHANGES:

G DASHES.

 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
                                                  PAGE DUMBER

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                     3E USED FOR SCANNER CO^Y ONLY
       rCHSS iCPOc^S INDICATED'
                                                                   " " 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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       3R COuRIER :2
    10 '
    1 73
    I1. INCHES 309CS-S

    USE .1 I -I  ( "
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         THIS SHEET TO BE USED FOR SCANNcR CCPY ONLY
    1 73 OR COURIER 12 MCDlr'ED
    DCL3LS
    1": INCHES iBORGcHS INDICATED)
    USE :. 1^ I  ( ,-JCT J. 1 A 1 }
VHiTc OLT OP Jc5 ~CP
USc 2 HYPHENS    	
'jSc A RED "ENCIL DOT
SPELL OUT COMPANY N -
USE =f = D PENCIL
 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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                                          ••V!-"TE Qt,T OR USE CGP3ฃC

                                          USE 2 HYPHENS   	

                                          U3EA RED PENCIL DOT *

                                          SPELL OUT COMPANY NAME

                                          USE RED PENCIL
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.
                                                               P-GENUMBER

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          HIS SHEET TO 3~ USED FOR SCANNER COPY ONLY
10 ?!TCH
!73 OR CCuRIER 12 ,MODIC,ฃD
DOUBLE
', '-: INCHES {BORDERS INOICATEC
USE i 1 i 1  ( rj(rr  i 1 :. 1 v,
                                                "/HITS OUT CR 'j3= CCF:
                                                •JSE 2 HYPHENS
                                                USE A RED PENCIL DC-
                                                SPELL OUT COMฐA,\Y \A
                                                j5ฃ RED PENCIL
 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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      ADL
3=0 sE
             (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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          "HIS SHEET TO 3ฃ USED FOR SCANNER COPY ONLY
                                               WHITE CUT OP LSc COP^
                                               SPELL CUT COUPA.NY N
i        	~~"	?
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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    USc Jll.il  ( "ld^ _ ". _ ' ;
            (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
                                                               PAGE NUMBER

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                          USE A RED PENCIL DOT  *
                          SPELL OUT COMPANY NAVE
                          USE RED PENCIL
             (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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LSe A 3 = 0 PENCIL DC

SPELL OUT COMPANY

USE RED PEfNlCiL
                   (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
                                                          PAGE NUMBER

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            'HIS SHEET TO 3E USED FOR SCANNER COPY ONLY
>GiMS.
      V, INCHES iBONDERS ..NDIC
WHITE OUT OR USE CO
USE 2 HVPH = \5
USE A RED ?ENC:L 3C
SPELL OUT CCWr^NY
USE RED PENCIL
  ]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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     se :, 1^.1  ( rjCT  A 1 ^ " •
VvhiTE OUT CR USE CORRECT

USE 2 HYPHENS

USE A RED PENCIL DO" *

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
(                                                             \
\                                                             I
\                                                             i
i
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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.          .
                                                                 PAGE NUMBER

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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
                                                  E NUMBEFi

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          "HI3 SHEET TO BE USED FOR SCAMNE8 COPY ONLY
                                               ,VH!T= CUT OR USE CORRECTING
                                    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
                                                                 "F \'i -MRi

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    ic PITCH
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    JOUBLE
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    USE ^.l:.l (  ->\C~ I!..':
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.
                                                  PAGE NUMBER

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1
THIS SHEET TO 3E USEC FOP. 3CA
1. z;vp,-cp SSTTPi.j iJ.'iTCH
ELrVENT '~>3 OR COuPlER '2 MC3I= ฃ0
SPACING CCwBLE
MARGINS V2 INCHES (BORDERS INDICATED'
r™1™
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ACL SPEL.L CUT COMPANY N~\1S
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) .

















,






PAGE NUMBER

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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
                                               XGE NUMBER

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USE _!. 1 _i 1  i ~'iCj~  ^ ', _
             (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
                                                                PAGE DUMBER

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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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use i l ji i  ( *iCT  i i „ n
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5P"' [_ Q1J7 COMPANY ''JAM-

USE ?ED ?ฑ^4C;'_
                   (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.
                                                AGE NUMBER

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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 = — ;\
= -i:/3"-
"-'- j:\
> i ,i 3 • j | %
I^.-.; = ^=-n,N
j

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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









                                         AGE NUMBER

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                                                    V !
 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.
                                                            ,\n-3 o i

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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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            (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
                                                     ;-GZ NU'viSSR

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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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     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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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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       (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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      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
                                                  J -+\i z i\U .:6cn

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      'JBLS

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;"3 DASHSE,  USE 2 HYPHENS    	

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    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
                                                               i

                                                               *
    The  subjects raised  in paragraph  (m) ,  (n) ,   (o) ,  and  (p)j
                                                               i
                                                               I
    have  been discussed  elsewhere in  this  chapter.          j
                                                               i
                                                               i
                                                               i
               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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            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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        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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                                                     - 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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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

-------
          "-<•; 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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 I

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                      Ic. L,S5D FOR SCANNER COPY ONLY
 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-

-------






I
I
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



1
V
I
^
1

1
1



1

1
1

1




1
1







1
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.

-------
         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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         TriS SHEET TO 3E USED FC3 5CAM.MER COPY ONLY
;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-

-------


















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

i


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-"(

-------
  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
I
'          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

-------
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.  !
                                                      i
                                                      j
                                                      i
    Abandoned wells are  distributed throughout the i

    regions in the same  proportion as  oil producing!

    wells.                                            |
                                                      i
                                                      i

                                                      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
                                                      i
                                                      !
    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.
\
i
(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
i

-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
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     JThe  first assumption is that  in  states  with a high

     I                                                         1
     jpercentage of ER oil, there will  be  a  greater number of!
     i

     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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                               ' j\jf i ~* i ป Jt ~_ ,™\ V^ V~/ J"^ T 'vJ > J IM *
 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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                       i H13 SHEET 7'L- BE USED FOr- .rCA'Vrd:,? COPY C-MLY
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™


•
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                                                            '-•5 : ^ ~t~ *'i':C. _ ~C *  •*



                                                             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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   -a
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   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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  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

-------
                                        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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                                       '-: - j. c:.
             ;      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   \
"                                                         !
i                                                         "
'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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             !      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 year—approximately 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
                                                         I
                                                         i
 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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         THiS SHEET TO 3E USED FOR SCANNER COPY ONLY
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.
                                                                                                    A .-t-Knr- ^ I iH-Id \t

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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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                      IE. USED FQP SCA.-.NER COPY O^L
 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-
i
!
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
\                                                         1


-.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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          •-ii~ .;:-.ฃ27 T--: 35 OScO FOR SCANNER COPY
(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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                             OR 3CAMN5R COPY ONLY
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
                                   ซ
I                                                         i

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



1


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             TABLE VI11-21

COMPLIANCE COSTS FOR AREA OF REVIEW
      Source: Arthur D. Little, Inc., estimates.
 I

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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\
3QAPH ENDING.   USE  ll^l  i >\OT ^. "! . 1
                                                •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
                                                                        /X-l I

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          THIS SHEET TO BE USED FOR SC.A.VNcR COPY OMLY
\T  "'D jR COURIER 12 MCCI-'^Q
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'-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
                                                    3AGE NUMBER  /X_~l3_

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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

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                     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

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                     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

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                    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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                                                         %N^
                                                                 Arthur Pi I \tt\f*

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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,=
                                                USE ^ฃD 3E'-JC:L
 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
                                                    AGE .NUMBER

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    13 r-'TCh
    1 73 OR COURI3R ' 2 ?,;COic'ฃ:

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WHITE OUT GO USS CCR~=C
USE 2 HYPHENS

USE A RED PENCIL CCT ป
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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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         THIS SHEET TO 3E 'JSED .=OR SCANNER COPY ONLY
1'; INCHES ''BORDERS INDICATED!
USE -.111 (  NOT c. 1 „ 1 )
                                               WHITE OUT OR 'JSE CORRECT!MG
                                               USE 2 HVPHEMS
                                               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
    • 0 PITCH
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' 'ป
 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
                                                                /X-

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          THIS SHEET TO BE USED FOR SCANNER COPY ONLY



    10 PITCH                               C'-iA.'j-jES  WHITE OUT OR USE JCRF
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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
                                                                                 Arthur HI irrle Inr

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                                                -3E A 3ED 35NC!L DCT  *
                                           AD'_   EP5LL CUT COMPANY NAMc
                                        EDITING   USE-cD PENCIL
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
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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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                                                                                    I

                                                                                    I

                                                                                    I
                                                                 GE NUMBER     —

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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
                                                  PAGE NUMBER

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       ";CH€5 .3OP3SPS -NDICATE
  CHANGES   •,%<;-, TE OUT OR ',SE CCP.~=C~''.r
ING DASHES.   '-SH 2 HYPHENS   	
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     ADL.   SPELL OUT COMPANY NAME
  EDITING   'JSS HED PENCii.
jand being enforced at  the  time injection is started.   j
I                                                            j
iThe result  is  that all  new injection  wells constructed I
i                                -*                           i
j                                                            1
jin  existing  injection  fields must comply only with state
I                                                            i
!requirements  in force  at  the time the new program is   !
*                                                            i
'put into effect.   As more  fully discussed in Chapter VI!,
                                                            ]
                                                            i
;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
|
•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
                                                                 1-3

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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   ;
1                                                            i
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     \
1                                                            i
! 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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        !by  the appropriate unit  cost to produce the  total incre,-
        |                                                         _   i
        i
        jmental cost of  compliance.   These  are direct costs and,

        i                                                            i
        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.
                                                                     E NUMBER

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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

-------
                               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

-------
                         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
   AOL.   SPELL OUT COMPANY %AV z
 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.

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          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
l
\
'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.                     :           •
                                                      E NUMBER

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               • 73 OR COURiES '*2 ''lODIFiED
               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
                                                                     E DUMBER

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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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i          \
            ;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.

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          •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                                                         !
; tion—the 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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                              Arthur D Little!

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                       THIS SHEET TO BE U3E3 =CR SCANNER COPY ONLY
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                  1 ^3 OR COURIER 12 MOJIFirD
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                  USE :, 1 i i  ( NOT  ^ 1 ^ 1 )
                                        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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 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



       
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                                      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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    USE i 1 j, 1  (\iCT  A 1 i " )
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•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 .     '
                                                   PAGE NUMBER

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    ;o PITCH
    173 OR COURIER 12 MODIFIED

    OOL'BLE
    V: INCHES (BORDERS INDICATED!

    USE Alii  ( MOT  A 1 .1 1 )
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 3ULLHT3

   -DL

 EDITING
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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
|
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.monitoring visit with other routine required  visits to

i
'the  wel 1 site .
                                                                PAGE .NUMBER
                                                               JUir

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                 (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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    1"i INCHES ''BORDERS INDICATED)
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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
                                                  PAGE .NUMBER

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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   	

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      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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    Vi INCHES (3ORDEHS INDICATED)
    USE >\ 1,11  ฃ MOT  A 1 A 1 )
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   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 )
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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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    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
                                                    AGE NUMBER

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' = '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.

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             'HIS SHEET TO BE USED FOR SCANNER COPY ONLY
ARGIN'S.  ' * INCHES'BORDERS INDICATED!
   CHANGES.  wrCT-cuTCR jsฃc??
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   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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      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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    10 P!TC^

    173 3P COURIER 12 MODIFIED

    DOUBLE

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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
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    1-2 INCHES ;aOPDERS INDICATED)
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         ,  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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                    TH!S SHEET TO BE USED FOP SCANNER COPY ONLY
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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

-------
                                           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
1
1
1
1
I
1

|
1
1
1
1
1
                                                                                                        I it-tip inr

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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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                                                            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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                           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      '
                                           PAGE NUMBER

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          'HIS SHEET 1C BE USED FOR 3CAMNER COPY ONLY
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          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
                                                 PAGE -NUMBER

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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 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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          -us
                                              .'/(••IT; OUT 0ฐ USE C'
                                              '.,55 2 HYPHENS
 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



                                                  PAGE MUWBER

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   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 + NT•c•C + NT•R'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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;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 permittee—once 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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       173 OR COURIER '2 MCDI = I=Q
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ARGINS.  T2 INCHES (BORDERS INDICATES!

=.\DI-;G.  usE^l^l  ;NOT  -i-n
                                                     -~
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   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

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     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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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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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 "< -

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         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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    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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    Vi INCHES 'BORDERS INDICATED)
    USE >_ 1 i i ;  \o~
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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 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 ~? ~ ;'
                                                          s I  _ 1,
                                                          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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                      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
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                       APPENDIX A


ARTHUR D. LITTLE, INC./INTERSTATE OIL COMPACT COMMISSION
                SURVEY OF STATE AGENCIES
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•                                                                          Arthur!) Little, Iru

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Agency name:


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Division, unit:


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Address:


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Total Division or Agenc


in co



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e estimate the number ol
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ull-time equivalent professionals.
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13
engineers, inspectors an




full-time equivalent clerical and
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data processing staff:


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are the current requirements for a ne
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Is cemented surface casing through t


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fresh water zone required?





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To what radial distance is the review


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cd
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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:

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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.


I


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                                                                                                              Arthur D Little. Ir

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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—
                                                                                  Arthur D Little, In

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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
                                                                                              Arthur HI ittl/^ Inr

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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
                                                                           I iff IP Ir

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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.
                                                                                        Arthur HI ittleli

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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.
                                                                               Arthur D Little, In

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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
                                                 1           •
                                                                              Arthur D Little, Ir

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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
                                                                            Arthur D Little. Ii

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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.


I


I


I


I


I


I


I

f
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.
                                                                                              Arthur-Hi

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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
                                                                              Arthur D Little

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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.
                                                                              Arthi ir D Little.1

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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)
i
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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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1
1


f Tasks 9, 10; I9 10(S): "Prepare final report"


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-\
^* iasK o. i^i^io) — , /ซ li i ) I jrn o
(7)l/3
|rn\ ~ii/3 1
1 111
T-irl- 4- 1 /^ ^" T fV\ — .
Task 4. !/2
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                     8    I!
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                                              lซcaS"S3;5t3'ซ2-    „  *    .."Si    S-SaS53S-"Tป^50a    0  =
                                                                                                                                  Arthur D Little, I

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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=-
0.02
[
" 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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                                                                                              Arthur D Little, lr

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