o'/Vx Z.K ?^ 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 ------- 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. Nebraska 40° WCAIUI NOITON ! PMIlllfS ! 5MIIM T Kwlll "^IIHJIHC 1 ; W«! ', 1 ,. _ ±v. _L _ <£> -!<"'' SHM.OAN 0,,NAU I foois T MIMN7\| „,„„,„ /0\ I p, _ _ J>^X-^~^~~T<. I «.,,„ W«HIIA rscori y,ANI - r - T ~ ? i_ScaJeinmiles_ o> I Oklahoma \37° Figure 1. Map of Kansas showing location of district offices. 2 ------- 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 ------- United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 Official Business Penalty for Private Use $300 OCQC3<9 PS U S 5NVIR PROTECTION AGENCY REGION 5 LIBRARY Z30 S DEAR8CRN STRSET CUCAGO IL 60604 ------- |