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United States
Environmental Protection
Agency
Robert S. Kerr Environmental
Research Laboratory
Ada OK 74820
Research and Development
EPA/600/S2-85/034 May 1985
&EPA Project Summary
Enforcement of Regulations
Governing Ground Water
Contamination from
Underground Injection or
Disposal of Salt Water in
Kansas and Texas
Linda Alter, Rhonda G. Hakundy, and David M. Nielsen
Almost one half of the salt water
produced with oil and gas operations in
the United States is generated in Texas
and Kansas. Much of this produced
water is either reinjected into the sub-
surface in enhanced recovery operations
or disposed of through subsurface in-
jection.
The full report describes in detail the
Underground Injection Control (UIC)
programs relating to Class II wells in
Texas and Kansas. The UIC program
regulations, the individual agency ad-
ministrative procedures, and the meth-
ods of handling ground water contam-
ination incidents resulting from the
injection or disposal of salt water are
discussed. In addition, several case
studies of contamination caused by
Class II wells are detailed.
This Project Summary was developed
by EPA 's Robert S. Kerr Environmental
Research Laboratory, Ada, OK, to an-
nounce key findings of the research
project that is fully documented in a
separate report of the same title (see
Project Report ordering information at
back).
Introduction
The full report provides a concise
description of regulations, administrative
procedures, and methods for dealing with
ground water contamination incidents in
two states with a large number of Class II
injection wells. Class II wells are those in
which injected fluids are brought to the
surface in connection with conventional
oil or natural gas production and may be
commingled with waste waters from gas
plants which are an integral part of
production operations, unless these wa-
ters are classified as a hazardous waste
at the time of injection. The Class II
category also contains wells into which
fluid is injected for enhanced recovery of
oil and natural gas, and for storage of
hydrocarbons that are liquid at standard
temperature and pressure.
Ground water contamination incidents
due to injection operations are not well
documented in the literature. This is often
the case because alleged contamination
incidents are most commonly investigated
by state personnel who do not routinely
publish information in the literature, al-
though some reports are available in an
open file. In other instances, the source of
the contamination may only be inferred
and not officially documented. Problems
with these wells are more easily docu-
mented where injection operations cause
direct contamination through surface
expression such as flow through improp-
erly plugged or abandoned wells.
Results
Rules and regulations governing salt
water injection and enhanced recovery
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wells in the state of Kansas are admin-
istered by the Kansas Corporation Com-
mission (KCC) through the "General
Rules and Regulations for the Conserva-
tion of Crude Oil and Natural Gas"
(effective May 1, 1984). The latest rules
combine the enhanced recovery and
disposal injection wells into one group. In
addition, persons requesting copies of the
rules and regulations may also receive a
copy of "Fundamental Guide for Salt
Water Disposal Wells." This is a practical,
readable guide that briefly describes the
major considerations for completing and
operating a disposal well. The guide
includes diagrams of methods of com-
pleting injection wells and an example of
a completed permit application.
The Kansas Department of Health and
Environment (KDHE) is also involved in
administering the Underground Injection
Control program and has a concern for
environmental pollution related to dis-
posal of salt water. In addition to sharing
regulatory responsibilities for Class II
wells, KCC and KDHE maintain six joint
district offices located in Dodge City,
Wichita, Chanute, Topeka, Salina, and
Hays (Figure 1).
The Railroad Commission of Texas has
jurisdiction over Class II wells in that
state. The Underground Injection Control
Section of the Oil and Gas Division of the
Commission is charged with administer-
ing a program which processes and issues
new permit applications for injection/
disposal wells, oversees the operation of
injection/disposal wells for which per-
mits have already been issued, and
coordinates the protection of fresh water
with other state and federal agencies.
The division has a central office and ten
district offices to oversee the program
(Figure 2).
Underground injection procedures and
provisions to protect the ground water
resources of Texas from such operations
are prescribed by statewide rules in these
areas: Water Protection, Disposal Wells,
Fluid Injection into Productive Reservoirs,
and Underground Hydrocarbon Storage.
Conclusions/
Recommendations
Regulatory agencies in Kansas and
Texas maintain field staffs who perform
routine inspections of injection opera-
tions and respond to complaints about
alleged violations or actual contamina-
tion resulting from injection or disposal of
salt water. A search of state records for
selected periods indicated that ground
water contamination problems were most
frequently identified through complaints
of salt water in a water well or identifica-
tion of flowing abandoned wells. Lab
analysis for chloride content in water
wells and pressure testing of nearby
injection wells are the most common
methods used to investigate the causes
or sources of ground-water contamina-
tion.
Although extensive field work may be
conducted, few investigations lead to
positive identification of a source of
contamination. Investigations are fre-
quently complicated by the proximity of
abandoned salt water pits and currently
operating injection wells, the cost of many
of the investigative methods necessary
for determining mechanical integrity of
injection wells, complicated flow paths in
the subsurface, and the logistics of work-
ing with industry to determine what is
happening in an area without endang-
ering the production of oil or gas.
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Figure 1. Map of Kansas showing location of district offices.
2
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District Offices
J San Antonio
2 San Antonio
3 Houston
4 Corpus Christ! t^n-rii
Kilgore
6 Kilgore
7B Abilene
7C San Angelo
8 Midland
8A Lubbock
9 Wichita Falls
10 Pampa
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Figure 2. District map of Oil and Gas Division, Texas Railroad Commission.
Linda Aller, Rhonda G. Hakundy, and David M. Nielsen are with the National
Water Well Association, Worthington, OH 43085.
Jerry T. Thornhlll is the EPA Project Officer (see below).
The complete report, entitled "Enforcement of Regulations Governing Ground
Water Contamination from Underground Injection or Disposal of Salt Water in
Kansas and Texas," {Order No. PB 85-185 916/AS; Cost: $11.50, subject to
change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield. VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Robert S. Kerr Environmental Research Laboratory
U.S. Environmental Protection Agency
P.O. Box 1198
Ada, OK 74820
ft U.S. GOVERNMENT PRINTING OFFICE: 1985-659-016/27063
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Environmental Protection
Agency
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