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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
 \.
        *'\."~

          \
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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