ENFORCEMENT OF REGULATIONS GOVERNING GROUND
WATER CONTAMINATION FROM UNDERGROUND INJECTION OR
DISPOSAL OF SALT WATER IN KANSAS AND TEXAS
Linda Aller
Rhonda G. Hakundy
and
David M. Nielsen
National Water Well Association
Worthington, Ohio 43085
Cooperative Agreement CR-809353
Project Officer
. Jerry T. Thornhill
Applications and Assistance Branch
Robert S. Kerr Environmental Research Laboratory
Ada, Oklahoma 74820
This study was conducted
in cooperation with
East Central University
Environmental Research Institute
Ada, Oklahoma 74820
ROBERT S. KERR ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
ADA, OKLAHOMA 74820
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DISCLAIMER
Although the research described in this report has been funded wholly
or in part by the United States Environmental Protection Agency through
Cooperative Agreement CR-809353 to East Central University Environmental
Research Institute, it has not been subjected to the agency's peer and policy
review and therefore does not necessarily reflect the views of the agency and
no official endorsement should be inferred.
n
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FOREWORD
The Environmental Protection Agency was established to coordinate
administration of the major Federal programs designed to protect the
quality of our environment.
An important part of the Agency's effort involves the search for
information about environmental problems, management techniques and new
technologies through which optimum use of the Nation's land and water
resources can be assured and the threat pollution poses to the welfare of
the American people can be minimized.
EPA's Office of Research and Development conducts this search through
a nationwide network of research facilities.
As one of these facilities, the Robert S. Kerr Environmental Research
Laboratory is the Agency's center of expertise for investigation of the
soil and subsurface environment. Personnel at the laboratory are
responsible for management of research programs to: (a) determine the
fate, transport and transformation rates of pollutants in the soil, the
unsaturated zone and the saturated zones of the subsurface environment; (b)
define the processes to be used in characterizing the soil and subsurface
environment as a receptor of pollutants; (c) develop techniques for
predicting the effect of pollutants on ground water, soil and indigenous
organisms; and (d) define and demonstrate the applicability and limitations
of using natural processes, indigenous to the soil and subsurface
environment, for the protection of this resource.
This report contributes to that knowledge which is essential in order
for EPA to establish and enforce pollution control standards which are
reasonable, cost effective and provide adequate environmental protection
for the American public.
Clinton W. Hall
Director
Robert S. Kerr Environmental
Research Laboratory
m
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PREFACE
Enforcement of Regulations Governing Ground Water Contamination from
Underground Injection or Disposal of Salt Water in Kansas and Texas has
been developed under the guidance of East Central University Environmental
Research Institute in conjunction with the U.S. Environmental Protection
Agency, for use by all of those involved in efforts to implement state
Underground Injection Control (UIC) Programs. The report provides a
concise description of regulations, administrative procedures and reported
ground water contamination incidents in two states with a large number of
Class II wells.
For those concerned with implementation of a UIC program and with
protecting ground water, this document may be helpful as a ready summary of
different ways to administrate a UIC program and methods for investigating
ground water contamination by injection operations. Finally, this manual
partially fulfills a mandate contained in the Safe Drinking Water Act (P.L.
93-523) requiring the Administrator of the Environmental Protection Agency
to "...carry out a study of methods of underground injection which do not
result in the degradation of underground drinking water sources."
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ABSTRACT
The Underground injection or disposal of salt water produced with
oil and gas is regulated as a result of the enactment of the Underground
Injection Control (UIC) Program under the authority of the Safe Drinking
Water Act. The Act requires the EPA to develop minimum standards to
assist the states in establishing effective programs to protect underground
sources of drinking water from contamination resulting from the subsurface
emplacement of fluids through well injection.
Nearly half, of the salt water produced with oil and gas operations
in the United States is generated in the states of Texas and Kansas; much
of this is either reinjected into the subsurface in enhanced recovery
operations or disposed of through subsurface injection in wells designated
as Class II wells by UIC program criteria. In the .state of Texas, primary
enforcement responsibility for UIC program regulations, specifically
those pertaining to Class II wells, has been assumed by the Texas Railroad
Commission. In the state of Kansas, the Kansas Department of Health and
Environment (KDHE) and the Kansas Corporation Commission (KCC) have
jointly assumed primary enforcement responsibility. Each of these two
states has developed an effective program to deal with salt water injection
and disposal wells; each of the agencies in these two states administers
and enforces UIC program regulations differently.
This document describes in detail the UIC programs relating to Class
II wells that have been developed in the states of Texas and Kansas. The
UIC program regulations, the individual agency administrative procedures
and the methods of handling ground-water contamination 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 report was submitted in partial fulfillment of Cooperative
Agreement No. CR-809353 by the National Water Well Association under the
sponsorship of the Robert S. Kerr Environmental Research Laboratory, Ada,
Oklahoma and in cooperation with East Central University Environmental
Research Institute, Ada, Oklahoma. This report covers a period from
December, 1981, to December, 1983, and work was completed as of December,
1983.
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CONTENTS
Disclaimer ii
Foreword iii
Preface iv
Abstract v
Figures viii
Tables ix
Acknowledgements x
1. Introduction 1
2. Conclusions/Recommendations 6
3. Underground Injection in Kansas 8
Agency responsibilities 8
History of salt water disposal regulations 8
Summary of regulations 12
Rules and regulations 13
Administrative procedures 17
Contamination incidents by salt water disposal wells ... 21
4. Underground Injection in Texas . . . . 24
Agency responsibilities 24
History of salt water disposal regulations 24
Summary of regulations 26
Administrative procedures 29
Contamination incidents by salt water disposal wells ... 31
Appendices
A. Application forms used by KCC in the administration of the
Kansas UIC program 45
B. Forms used by KCC and KDHE to investigate salt water
contamination 49
C. Forms used by the Texas Railroad Commission in the
administration of the Texas UIC program 51
Dt Form used by the UIC staff to record complaints about
1 salt water injection or disposal wells 54
E. Texas statewide rule 8 - water protection 65
F. Texas statewide rule 9 - disposal wells 70
G. Texas statewide rule 46 - fluid injection into productive
reservoirs 74
VI 1
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»• \ FIGURES
Number Page
1 Map of Kansas showing location of district offices 15
2 Proper salt water disposal well completion 30
3 Stiff diagram used for brine fingerprinting 37
4 District map of Oil and Gas Division, Texas Railroad
Commission 45
A-l Application form for salt water disposal-wells in the state
of Kansas "1 75
A-2 Application form for enhanced recovery we!Is.in the state
of Kansas 77
B-l Form used by KCC field investigator to detail salt water
disposal well problem 79
B-2 Form used by KDHE field investigator to detail salt water
contamination 80
C-l Application to dispose of oil and gas waste by injection
into a porous formation not productive of oil or gas 81
C-2 Annular disposal/injection well monitoring report 83
C-3 Oil well potential test, completion or recompletion report
and log 85
C-4 Gas well back pressure test, completion or recompletion
1 report and log 87
C-5 Application to inject fluid into a reservoir productive of oil
or gas 89
C-6 Injection well data form 91
I
C-7 Fresh water data form 92
i
D-l Administrative form used by the UIC program to record
complaints 94
vm
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\ \ TABLES
Number Page
1 Disposal of produced salt water, 1963 6
2 Part of Table I setting minimum depths for the protection
of usable and fresh water in Kansas 16
3 Part of Table II setting minimum depths for salt water
disposal in Kansas . 17
4 Ground and surface water contamination incidents related
to class II wells investigated by KDHE and/or KCC between
1979 - 1982 ~. '38
5 Summary of wells plugged by the commission where the
problem was attributed to a disposal or injection
well, 1967 through 1975 61
6 Synopsis of complaints of alleged contamination by
underground injection, January, 1979 through June, 1980 ... 67
7 Summary of complaints involving injection/disposal wells,
January, 1982 through December, 1982 71
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.», , ACKNOWLEDGEMENTS
The authors wish to acknowledge the staffs of the Kansas Corporation
Commission, Wichita, Kansas, the Kansas Department of Health and
Environment, Topeka, Kansas and the Texas Railroad Commission, Austin,
Texas for their patience and assistance in the preparation of this
document. Without their helpful support, the writing of this document
would not have been possible.
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SECTION 1
V\ INTRODUCTION
OBJECTIVES AND SCOPE
This report has been prepared to provide 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. The report may also provide information to industry repre-
sentatives, government officials and others to help them understand the
potential problems associated with underground injection through Class II wells,
and provide examples of how two state programs have been designed to deal with
such problems. Although this report details the administration of regulations
in the States of Texas and Kansas, different regulatory and administrative
systems developed in other states may prove equally as effective in dealing
with similar problems.
This report is intended to be informative rather than prescriptive in
nature. Impetus for the report was provided by passage of Public Law 93-523
(The Safe Drinking Water Act), which requires the U.S. Environmental Protection
Agency (EPA) to develop minimum requirements for the establishment of effective
state programs to protect underground sources of drinking water from the sub-
surface emplacement of fluids through well injection. Additionally, the Act
states that these requirements not impede the re-injection of brine or other
fluids used in secondary or tertiary recovery unless drinking water sources
would be endangered (Federal Register, June 24, 1980).
For purposes of the Underground Injection Control (UIC) Program, injection
wells were classified into five categories as follows: (a) Class I wells are
(1) those used by generators of hazardous waste or owners or operators of
hazardous waste management facilities to inject hazardous waste beneath the lower-
most formation containing, within one quarter (1/4) mile of the well bore, an
underground source of drinking water; (2) other industrial and municipal disposal
wells which inject fluids beneath the lowermost formation containing, within one
quarter (1/4) mile of the well bore, an underground source of drinking water;
(b) CTa'ss II wells are wells which inject fluids (1) which 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 pro-
duction operations, unless these waters are classified as a hazardous waste at
the time of injection, (2) for enhanced recovery of oil and natural gas, and (3)
for storage of hydrocarbons which are liquid at standard temperature
and pressure; (c) Class III wells inject for the purpose of extraction of
minerals including: (1) mining of sulfur by the Frasch Process, (2) in situ
production of uranium or other metals, and (3) solution mining of salts or
potash; (d) Class IV wells include disposal wells used by hazardous and
radioactive waste generators and disposal site operators to dispose of hazardous
waste or radioactive waste (1) into a formation which within one-quarter mile
contains an underground source of drinking water, (2) above a formation which
1
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within one-quarter mile contains an underground source of drinking water, and
(3) which cannot be classified under (1) or (2); Class V wells includes injection
wells not covered by the four other classes.
Recognizing that there are many different ways that similar DIG regulations
can be administered in\ each state, this document attempts to detail the efforts
of both Kansas and Texffs. This document neither endorses nor criticizes the
adminstrative procedures, but simply details them for possible use by other
states with similar implementation responsiblities. In addition, reported
incidents of ground-water contamination by salt water injection wells and the
method of handling complaints are described.
HISTORICAL PERSPECTIVE OF PROBLEM
Since 1859, when the first oil well was drilled at Titusville, Pennsylvania,
the disposal of salt water has been an environmental problem. In the early
days of oil production, brine, disposal was often an uncontrolled discharge to a
stream or ditch (EPA, 1977). Practices such as this led to environmental
contamination which went unchecked until the late 1920's when industry began to
internally develop production practices and techniques which recognized the
impact on water resources (IOOC, 1966). In the succeeding years, studies of
the proper disposal of oil field brines were made by regulators charged with
protecting surface and ground-water supplies and by companies faced with the
problem of disposing of salt water, and the basis for today's regulatory frame-
work was established.
Ground and surface-water contamination from oil field salt water disposal
practices, primarily from surface discharges and unlined pits, are well-documented
in the literature (Fryberger, 1972; Oklahoma Water Resources Board, 1975;
Pettyjohn, 1971; Payne, 1966). As a result, the present disposition of salt
water produced with oil or gas is principally by underground injection. It is
estimated that there are approximately 140,000 Class II wells in use across the
United States.
Class II wells are generally associated with four activities: (1) to
maintain underground pressures which would otherwise be reduced by virtue of
the production of oil and/or gas; (2) cycling or recycling, to introduce residue
gas into a formation after liquifiable hydrocarbons have been extracted from
gas prpduced from the formation; (3) secondary recovery operations, to introduce
a fluid to decrease the viscosity of oil, reduce its surface tension, lower its
specific gravity, and/or to drive oil into producing wells, resulting in
greater production of oil, and (4) tertiary recovery operations to introduce
chemicals or energy as required for displacement and for the control of flow
rate and flow pattern in the reservoir (TRRC, 1983).
In developing background data for this report, representatives of state
agencies involved with the administration of regulations pertaining to salt
water Injection and disposal were contacted. Copies of regulations, forms and
published information on ground-water contamination relating to salt water
injection wells were obtained. Visits were made to the appropriate state
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agencies to interview agency personnel about administration and enforcement of
the regulations and the handling of complaints. Files pertaining to possible
ground-water contamination by injection wells were either manually searched by
the authors (Kansas) or compiled by the state personnel (Texas). Kansas records
were searched for the period January, 1979 to December, 1982. Information from
the state of Texas fta's/ obtained for: (1) January 1967 to December 1975, (2)
January 1979 to June V980, and (3) January 1982 to December 1982.
ORGANIZATION
This document contains four sections, five subsections and four supporting
appendices. Section 3 contains information on the state of Kansas; Section 4
on the state of Texas. The sections have been divided to provide an easy
reference of state responsiblities and regulations and to detail the information
on contamination by salt water injection wells during the study period for each
state.
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TABLE 1. DISPOSAL OF PRODUCED SALT WATER, 1963 (IOCC, 1966)
(BARRELS PER DAY)
.*-""
KANSAS
TEXAS
Volumes
Produced
5,011,400
6,127,671
For Water
800,000
2,736,755
INJECTION
Flood For Disposal Only
4,200,000
1,472,954
Impervious
Pits
1,800
1
Unlined
Pits
9,600
,262,719
Streams
and
Rivers
615,566
Other
Methods
39,677*
*unaccounted
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REFERENCES
' \
EPA, 1977, The Report to Congress: Waste Disposal Practices and Their Affects
on Ground Water; U.S. Environmental Protection Agency publication EPA-PB-265-
031, 512 pp.
Federal Register, vol. 46, no. 96, May 19, 1981, pp. 27333-27339.
Fryberger, J.S. 1972, Rehabilitation of a Brine-Polluted Aquifer; U.S.
Environmental Protection Agency publication EPA-R2-72-014, 61 pp.
Hopkins, Herbert T., 1963, The Effect of Oilfield Brine on the Potable Ground
Water in the Upper Big Pitman Creek Basin, Kentucky; Kentucky Geological Survey,
Report of Investigation 4: Series X, 36 pp.
Interstate Oil Compact Commission, 1966, Water Problems Associated with Oil
Production in the United States: Interstate Oil Compact Commission, Oklahoma
City, Oklahoma, 88 pp.
Oklahoma Water Resources Board, 1975, Salt Water Detection in the Cimmarron
Terrace, Oklahoma; U.S. Environmental Protection Agency publication EPA-660/3-
74-033, 166 pp.
Payne, Roy D., 1966, Salt Water Pollution Problems in Texas; Journal of Petroleum
Technology, vol. 18, pp. 1401-1407.
Pettyjohn, Wayne A., 1971. Water Pollution by Oil-field Brines and Related
Industrial Waste in Ohio; The Ohio Journal of Science, vol. 71, no. 5, pp. 257-
269.
Railroad Commission of Texas, 1983, Underground Injection Control, 35 pp.
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SECTION 2
r\ CONCLUSIONS/RECOMMENDATIONS
\
As part of the regulatory process, both states promulgated statewide rules
to ensure that Class II (salt water injection and disposal) wells would be
operated without endangering the ground-water resources of the state.. Although
the mandate of ground-water protection is the same for both states, the provisions
contained within the rules and the administrative procedures are different.
The rules have been tailored to address differing geologic conditions in each
state. Administratively, the enforcement of the UIC program for Class II wells
has been jointly assumed by two state agencies in Kansas and one agency in
Texas. Both states have attempted to integrate new provisions into existing
rules and administrative authorities.
A variety of enforcement options for rule violations are available in both
states. Similar enforcement actions such as the ability to immediately shut in
a well for serious violations, to revoke an operating permit or producer's
license or to seek remedies through the courts are used in both Kansas and
Texas. In the state of Kansas, a maximum fine of $10,000 a day for every
offense can be levied. In Texas, additional penalties such as pipeline severance
can be imposed. This penalty in Texas has historically proven effective in
enforcement of the rules of the Texas Railroad Commission. In Kansas, the
$10,000.fine is a relatively new enforcement tool, and its effectiveness as a
deterrent against violations has yet to be tested.
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, although 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 injection
wells are more easily documented in cases where injection operations cause
direct evidence of contamination through surface expression such as flow through
improperly plugged or abandoned wells. One of the most illustrative examples
of problems associated with injection in an area containing abandoned wells
that weire improperly plugged is cited by Hopkins (1963). In east-central
Kentucky, a pressurized injection well was located about 200 feet away from a
gas well used for domestic fuel. Upon initiation of injection operations, the
gas furnace in the living room of the farmhouse spouted brine. After injection
was stopped, the flow ceased.
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 identification of flowing abandoned wells.
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Regulatory agencies in the states of Kansas and Texas maintain field staff
who perform routine inspections of injection operations and respond to complaints
about alleged violations or actual contamination resulting from injection or
disposal of salt water. Lab analysis for chloride content in water wells and
pressure testing of .nearby injection wells are the most common methods used to
investigate the causies\or sources of ground-water contamination.
Although extensive field work may be conducted, few investigations lead to
positive identification of a source of contamination. This is due to the nature
of the problem, the cost of many of the investigative methods necessary for
determining mechanical integrity, flow in the subsurface etc., and the logistics
of working with industry to determine what is happening in an area without
endangering the protection of oil or gas.
The two states both have a well plugging fund which was established to
help remediate problems with improperly plugged or unplugged abandoned wells
where a legally responsible party cannot be identified or where a legally
responsible party does not have the assets to correct the problem. The state
funds are used only as a final option where no other sources or funds are
available and where there is a recognized problem w.tth the well.
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SECTION 3
i\
* \ UNDERGROUND INJECTION IN KANSAS
AGENCY RESPONSIBILITIES
The Underground Injection Control (UIC) Program in the state of Kansas is
jointly administered by the Kansas Corporation Commission (KCC) and the Kansas
Department of Health and Environment (KDHE). KDHE has been given statutory
(legislative) authority to regulate all wastes in the state. Therefore, KDHE
must enforce Section 1422 of the Safe Drinking Water Act, which gives the state
primary enforcement responsibility over the UIC Program. However, it is the
responsibility of KCC to enforce Section 1425 of the Act which pertains strictly
to Class II wells. This gives KCC the power to permit and, when necessary, to
plug salt water injection wells. In fact, KCC has primary control over Class
II wells, while KDHE's concerns are with environmental pollution related to
salt water disposal. In addition to sharing regulatory responsibilities for
Class II wells, KCC and KDHE also maintain six joint district offices. The
offices are located in Dodge City, Wichita, Chanute, Topeka, Salina, and Hays
(Figure I).
All rules and regulations in the state pertaining to fluid injection must
be reviewed by a ten member board. The board consists of one member each from
KCC, KDHE, Division Water Resources, Kansas Geological Survey, Kansas Water
Office, three organizations representing the oil and gas industry, a representative
of water management districts, and one public representative. In addition to
considering regulations, the board reviews minimum standards for water protection,
and disposal/injection practices. A previously established board developed
minimum depths necessary to protect ground water in the State. A part of that
table is shown in Table 2. These depths are determined by county and in some
counties by township. The board has also developed a list of the minimum depth
allowed for brine injection in each county and in some cases for particular
townships (Table 3).
HISTORY OF SALT WATER DISPOSAL REGULATIONS
i
Oil was first discovered in Kansas in 1860 when two or three wells were
drilled near Paola. The Civil War stopped development, however, and it was
some 30 years before new wells were drilled (Latta 1963). The first big oil
play was T914 when the El Dorado Field was discovered in Butler County. However,
it was not until 1920 that production of oil and gas exceeded 50 million barrels
per yeajr (Jewett 1979). The production of oil and gas also led to the production
of salt water. During the early years of production, neither the operators nor
the landowners gave any thought to the brine produced with oil.
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Figure 1. Map of Kansas showing location of district offices.
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TABLE 2. PART OF TABLE I SETTING MINIMUM DEPTHS FOR THE PROTECTION
OF USABLE AND FRESH WATER
Rule 82-2-123 TABLE I
(Revised March 1, 1967)*
Established depths above which usable and fresh water should be
protected by recommended methods
County Minimum Requirements
Allen R. 17E and 18E set a minimum of 150 feet, T. 25S R.
21E, set a minimum of 175 feet, T. 26S, R. 20E and 21E
set a minimum of 175 feet. In all other areas set a
minimum of 100 feet. In all cases, set through all
unconsolidated material plus 20 feet into the
underlying formation.
Anderson T. 23S, R. 20E and 21E set a minimum of 100 feet. T.
21S and 22S, R. 21E set a minimum of 100 feet. In all
other areas set a minimum of 125 feet. In all cases,
set through all unconsolidated material plus 20 feet
into the underlying formation.
S = Section
T = Township
R = Range
i
*This is only part of Table I, showing minimum depth requirements for
two counties. . .
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V
TABLE 3. PART OF TABLE II SETTING MINIMUM DEPTHS FOR SALT
WATER DISPOSAL
(Revised April 26, 1971)*
Rule 82-2-400 TABLE II
Established minimum depths for disposal wells*
The following depths are the absolute minimum depths which will be
permitted. Depths greater than those given may be required for some
areas.
County
Allen
Anderson
Atchison
Barber
Barton
Minimum Depths
350 feet
350 feet
500 feet
Township 34S Range 15W and Township 35S Rang 15W - -
200 feet. All other areas - - 500 feet.
Top of "Red Beds"
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The problem of brine disposal reached a clima.x sometime prior to 1935. In
1934, the state legislature enacted a law permitting the return of produced
brine to any subsurface formation that already carried highly mineralized
water. Another act allowed the use of produced brine for repressuring oil
zones (Latta 1963).
\ \
In 1952, a three-member board was established to set minimum depth standards
similar to those used in the state today. At that time the board consisted of
the KDHE, the Kansas Geological Survey and the Department of Agriculture's
Division of Water. Beginning in 1956, operators were required to file "intention
to drill" applications which gave an API number to each well. In 1967, a
regulation was adopted requiring that disposal wells be drilled to a depth of
at least 500 feet below the surface and at least 50 feet below any producing
oil or gas formation.
Following the passage of the federal Safe Drinking Water Act (SDWA), Kansas
adopted its underground injection regulations to comply with national requirements
and to retain primary enforcement responsiblity for the Underground Injection
Control Program.
Because the KCC had regulated salt water disposal and enhanced recovery
wells for over 25 years, it retained primary control over Class II wells.
However, because the main emphasis of the federal UIC program was the protection
of water, the KDHE continues to be involved in environmental concerns regarding
salt .water injection wells.
In January 1981, Kansas submitted its two-part UIC program to the U.S.
EPA. Part 1 (KDHE responsibility) addressed Class I, III, and V wells. Part 2
(KCC responsibility) addressed Class II wells. The EPA decided that it was
necessary for Kansas to rewrite portions of its Part I UIC program. Consequently,
the rules were rewritten and resubmitted to the EPA in February, 1983. Kansas
received primacy under Section 1422 of the SDWA in December, 1983, and under
Section 1425 in February, 1984.
KDHE has estimated that there are approximately 13,000 Class II wells in
Kansas. Of these, there are 6,000 permitted salt water disposal wells. It is
difficult to determine the exact number of enhanced recovery wells because as
many as 100 (or more) repressuring wells can be included on the same permit.
SUMMARY OF REGULATIONS
Rules and regulations governing salt water injection and enhanced recovery
wells in the state of Kansas are documented by the Kansas Corporation Commission
in the "General Rules and Regulations for the Conservation of Crude Oil and
Natural Gas" (effective May 1, 1984). The latest rules combine the enhanced
recovery and disposal injection wells into one group. Rules for injection
wells are found in Sections 82-3-400 through 82-3-411. Persons requesting
copies Of the rules and regulations may also receive a copy of "Fundamental
Guide fpr Salt Water Disposal Wells" by Rice Engineering and Operating, Inc..
This is a practical, readable guide which briefly describes the major considerations!
of completing and operating a disposal well. The guide includes diagrams of
various methods of completing a well and an example of a completed permit
application.
12
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RULES AND REGULATIONS
Section 400 of the rules and regulations states that it is necessary to
obtain a permit to operate an injection or disposal well in the state of Kansas
and that the proposed.injection zone must be separated from fresh or usable
water by impervious beds to give protection to the fresh and usable water
formations. It furthervstates that wells requiring well head pressure to
dispose of salt water must be completed with a packer, with certain exceptions.
Additionally, records concerning the amount and kind of fluid being injected
must be kept current for a period of five years and a report of such must be
submitted to the KCC at the end of each year.
Section 401 defines the information required in an UIC application. The
applicant must show certain specific information on the injection or disposal
well (see Appendix A). This section also outlines the data that must be
considered prior to issuing an order approving injection or disposal wells. An
example of an application form for a salt water disposal well is shown in
Appendix A, Figure A-l.
Disposal wells require separate orders for each-well but enhanced recovery
well orders cover multi-well projects. A copy of the application must be mailed
or delivered (by the applicant) to each operator producing or drilling wells
(offset operators) within a 1/2 mile radius of the proposed disposal well and
to the landowners. Notice of the application must be published in at least one
issue of a local paper having general circulation throughout the ,county or
counties in which the lease is located. Objections or complaints concerning
the proposed well must then be filed within 15 days after the application is
filed. Should an objection or complaint be filed, or should the KCC require
it, a hearing will be held. At the hearing anyone who has filed a complaint
must state any reasons why the proposed well may cause damage to fresh water
resource (or to a hydrocarbon resource). The KCC will then make a decision to
either grant or deny the permit based on the evidence provided.
Section 402 pertains to casing and cement. Injection and disposal wells
must be cased and the casing cemented in such a manner that damage will not be
caused to hydrocarbon sources or fresh and usable water sources. Specific
instructions are given for certain types of wells.
Cement bond logs or temperature surveys demonstrating adequate cement
protection may be submitted to the commission.
i
Section 403 outlines requirements pertaining to commencement and
discontinuance of injection or disposal operations. Immediately after injection
or disposal has begun the operator must inform the KCC of the date of commencement.
Within 90 days after permanent discontinuance, the KCC must be notified of the
date of the discontinuance and the reason for it. Though it is not stated in
the regulation, a commission representative must always be present during the
abandonment procedure to ensure that plugging is carried out in a satisfactory
manner. I
13
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Tubing and packer requirements are listed in Section 404. Wells must be
equipped to inject through tubing, below a packer set in the casing opposite a
cemented interval, immediately above the uppermost disposal perforation or open
hole interval. The use of a packer and tubing, including diagrams, is explained
in the "Fundamental Guide for Salt Water Disposal Wells". A corrosion-inhibiting
fluid or hydrocarbon*'liquid must fill the annulus between the tubing and the
casing. This liquid further protects the well casing from corrosion by foreign
fluids. The KCC may authorize packerless completions if specific stipulations
are met.
A tubingless completion may also be authorized if the certain criteria are
met throughout the life of the well.
The requirements concerning proper operation of a salt water injection or
disposal well are described in Section 405. Before operation begins, the casing
outside the tubing and above the packer must be tested. The test must be
witnessed by a representative of the KCC or KDHE. A pressure of 100 psi or the
maximum allowable disposal pressure, whichever is greater, must be used in the
test. The well must be shut-in for a period of 30 minutes. The allowable
pressure dropoff during this time will be set by the-representative of the
regulatory agency on a site by site basis, but typically 10 percent dropoff is
acceptable. Mechanical integrity must be established periodically during
operation of the well using either pressure tests or monitoring. Pressure tests
are required once every five years as outlined above. A minimum of 25% of the
tests must be witnessed by a representative of KCC or KDHE. Instead of pressure
testing, the operator may monitor and record the pressure in the annulus of
the well during actual disposal. Continual monitoring or periodic testing .of
an injection well should indicate when leakage is occurring or when the formation
or well are becoming plugged.
Section 406 states that the authorization to inject fluids into a well
remains valid throughout the life of the well, unless revoked by KCC for just
cause. This section gives KCC the authority to shut-in a well if just cause is
indicated. Just cause includes mechanical failures or other conditions which
indicate a well is not directing fluid into the permitted injection zone.
Furthermore, if an operator detects such a problem, the operator must notify
KCC of the situation within 24 hours (verbally) or within five days (in writing).
In addition to this notification, the operator must inform KCC and KDHE of the
plan intended to test and repair the well. Results of the testing and repair
will be,given to KCC and KDHE and will be included in the annual report. Any
downhole well repair should be included in the annual report.
Section 407 restates the requirement of keeping accurate records for five
years. Section 408 details the information which must be sent to KCC when a
transfer of ownership occurs. Section 409 defines an "existing" injection or
disposal well and the inventory forms necessary to obtain that status. Finally,
Section(410 states that the commission will establish a fee for each lease
involved in the application. This fee must be paid within 30 days after the
commission makes notice of the charge. The application fee is put into a
general ,operating fund which makes it possible for KCC to administer Class II
well regulations.
14
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Fundamental Guide for Salt Water Disposal Wells
The guide for salt water disposal wells includes sections covering topics
such as application procedures for obtaining a disposal well permit and plugging
procedures for a disposal well.
A
One of the most u\eful aspects of the guide is that it defines practices
required by KCC and KDHE when enforcing general statements found in the rules
and regulations that are considered necessary to prevent ground-water contamination
resulting from salt water disposal practices. For instance, Section 82-3-402
states "injection and disposal wells shall be cased and the casing cemented in
such a manner that damage will not be caused to hydrocarbon sources or fresh
and usable water sources". Section I (E) of the guide, explains that KCC and
KDHE require that surface pipe be set on a hard formation and cement circulated
to the surface. Casing must also be set and cemented through any disposal
formation that is loose and subject to caving. Many disposal wells can be
completed by setting the long casing string on a formation where open hole
completion is possible with injection through tubing and packer set near the
top of the disposal zone.
Other sections of the guide suggest the best of recommended methods of
completion or operation, of a disposal well to prevent salt water contamination.
Section III discusses tubing and lining. It suggests using the largest size of
tubing able to be run inside the size of casing that is used in a well.
Internally lined steel tubing is recommended.
Section 32-3-404 requires that the annulus between the tubing and casing
be filled with a corrosion-inhibiting fluid or hydrocarbon. The salt water
disposal guide describes a simple method of. filling the annulus by using oil,
and explains how to calculate the proper oil gravity which will protect the
annulus.
The same section (IV) of the guide recommends the use of packer when: (a)
the well fluid level is extremely low, and (b) the condition of the long casing
string is questionable. The guide also states that packers often leak resulting
in false indications of tubing or casing problems. Packers often become stuck
and have to be drilled out.
Section V of the guide defines normal injection rate, normal injection
pressure, maximum injection rate, maximum injection pressure, and tubing vacuum
and explains how to determine each. Section VI briefly explains remedial
treatment and clean-out methods used to stimulate wells. It also suggest the
best methods in use for stimulating the two main disposal zones in Kansas.
The two formations commonly used for salt water disposal are discussed in
Section II. The Arbuckle dolomite (lower Ordovician) is the recommended disposal
zone. Jhe guide lists reasons for the frequent use of the Arbuckle formation
and states that for high volume disposal, a total of 300 feet or more of open
hole in the Arbuckle is necessary. The Cedar Hills formation (Permian) is also
commonly used for salt water disposal in Kansas, but it can not be completed
open hoile because it is a poorly cemented sand. The Cedar Hills sand will
collapse into the borehole if not cased and cemented (and then the casing
perforated for injection).
15
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* N
o ,
GROUND LEVEL 1472'
-.' FRESH WATER STRATA
-CEMENT TO SURFACE
•Q%" SURFACE PIPE 250'
. STATIC FLUID LEVEL 750'
5'/2" CASING 4688'
3'/2" TUBING 4690'
DISPOSALZONE
TD 4968'
Figure 2. Proper salt water disposal well completion.
16
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ADMINISTRATIVE PROCEDURES
Both KCC and KDHE have developed standard procedures to handle complaints
about, or discoveries by their own personnel of incorrect operation of salt
water disposal wells. Most often, the problem is discovered because some type
of contamination has^, occurred. Consequently, the person affected by the
contamination (usually\the landowner) reports the problem to one of the two
agencies. The KCC and "KDHE follow slightly different procedures to investigate
the problem. This section will detail the standard procedures followed by each
of the agencies to enforce the salt water disposal well regulations.
KCC Procedure.
When a case of improper salt water disposal well operation is discovered,
the main KCC office is contacted about the problem. The director of the UIC
program determines the initial course of action to be taken by the Commission.
If a field inspection has not been made, the Wichita office notifies the
appropriate district office of the problem and instructs a field inspector to
inspect the site. A description of the site, which may include a discussion of
the problem with the landowner or a neighboring landowner, is filed on a standard
field report form (Appendix B, Figure B-l). The protlem may be further documented
with: 1) Polaroid pictures of the sits; 2) the registry of deeds indicating
the legal lease holder, or 3) in the case of a flowing (abandoned) well, a dye
test to determine whether the flow is caused by the use of an injection well.
The Commission then sends a letter to the operator of the well detailing
the problem and instructing the operator that the problem must be corrected.
Letters sent by the KCC to operators are of fairly standard form, indicating
the name of the lease and its' location, a statement to the effect that "a report
has been made to the KCC indicating....," and either a statement that action
must be taken within 30 days or legal action will be taken.
At the end of the 30-day period, the site is reinspected by the district
field inspector. If the problem has not been corrected, it is referred to the
Commission's legal counsel for action (Schoof, personal communication, 1983).
KCC's attorney then sends another letter to the operator threatening an
administrative hearing if the problem is not resolved by a given date. KCC
attempts to do as much as possible to correct the problem by working with the
operator. However, if this fails, the Commission can take several steps to
rectify the situation. First, an administrative hearing is conducted. At this
hearing, the KCC presents all of the information it has gathered pertaining 'to
the problem site and operations at the site which violate UIC regulations.
The operator may present a defense of his operations at the hearing. Following
the hearing, the hearing examiner makes a recommendation to KCC. The Commission
relays this recommendation to the operator who has 10 days to comply with the
recommendations. The recommendations may be to plug the well or make a specific
correction. A fine as high as $10,000 per day may be imposed (1) every day
after tlhe 10 day period in which the correction was to have been made, or (2)
every c^ay after the hearing until a correction is made, in the event that the
operator does not appear at the hearing.
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Following the first hearing, the operator has the option of requesting a
second hearing. If the operator again refuses to comply with the Commission's
demands, the KCC can take the offender to the State District Court (Ellis,
personal communication, 1983). At any time during this process, if deemed
necessary, KCC can have one of its field inspectors shut in the salt water
injection well, or KCC can revoke the operator's production license. Finally,
following the District Court hearing, it may be necessary for the Commission to
plug a well that is inVyiolation with the State's UIC regulations if the operator
still refuses to comply with the court's demands.
KDHE Procedure
Every complaint received by KDHE about a salt water disposal well, is
referred to and investigated by the appropriate district office (if received by
the main office in Topeka). Either a field investigation is carried out Within
72 hours, or the operator of the questionable operation is contacted by phone.
Frequently KDHE investigates the site with the person who made the complaint or
with the operator involved. Following his investigation, the field inspector
then writes to the offender, detailing the problem and requesting that the
problem be corrected within two weeks. If the problem concerns an unpermitted
salt water disposal well, KDHE refers the operation to KCC, which is then
responsible for bringing the operation into compliance.
The field inspector checks the sita again after the two week period. If
the contamination problem has not been resolved, KDHE can issue an administrative
order or take the offender to court. The administrative order is sent by
certified mail to the operator of the injection well. It demands that the
operation be closed within 30 days within which time the operator may protest
the closure. If the operator takes no action in that 30 day period, another
certified letter is sent to the operator. This time the letter states the sum
of the fine imposed on the.operator for violation UIC regulations. In the event
that KDHE decides to take the offender to court, it must decide whether to take
the case to the County Court or to the State District Court, depending on the
local situation. Either KDHE or the complainant may also sue an operator in
civil court. When a private citizen sues an oil and gas producer for salt
water contamination, KDHE is responsible for providing the appropriate information
concerning the case.
Like KCC, KDHE has the authority to shut in wells at the discretion of its
field inspectors. There is no pipeline severenCe in Kansas (the authority to
shut off oil and gas production from the operator's producing wells) however,
KDHE caln revoke an operator's license for his oil and gas production wells due
to a violation of UIC regulations (Glotzbach, personal communication, 1983).
Part of the process of terminating a salt water contamination problem
involves defining the source and direction of movement of the contamination.
For this reason, KDHE owns a drilling rig to drill ground-water monitoring
wells. One method of defining the source of salt water contamination, which
KDHE utilizes, is salt water "fingerprinting". This technique assumes that
waters priginating from the same place retain essentially the same chemistry
(except that they are diluted). Therefore, on a water chemistry diagram such
as a Stiff diagram, which shows a chemical analysis of water in distinctive
graphical shapes, water having the same origin should have similar chemistries
and thus similarly shaped Stiff diagrams (Figure 3) (Denig-Chakroff, unpublished).
18
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Na
1000-
Ca
100"
Mq.
100
Fe .
100
Cl
'•DOO
.
100
30,
Figure 3. Stiff diagram used for brine fingerprinting (Denig-Chakroff, unpublished).
19
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TABLE 4. GROUND AND SURFACE WATER CONTAMINATION INCIDENTS RELATED TO CLASS II
WELLS INVESTIGATED BY KDHE AND/OR KCC BETWEEN 1979 - 1982
Water Contamination Incidents Reported in Kansas, 1979 - 1982
« V
V
Source of Problem -.
Storage Tank/Ponds**
Emergency Pit Full /Overflowing
Overflowing Dike
Tank Overflow/Leak
Unpermitted Pond/Pit
Line Leaks**
Disconnected Line
Line Leading Directly to Open Pit
Line Directly to Stream
Injection Wells**
Pump Failure
Not Accepting Sufficient Brine
Packer or Tubing Leak
Must Have Automatic Controls
Casing Leak
Must be Modified to Comply
Unpermitted Wei 1
Flowing Abandoned Well
Undetermined Source***
Eastern*
2
21
1
11
2
23
2
6
1
28
26
5
2
2
-
1
12
24
7
Western
5
3
8
—
3
-
4
•*
12
1
-
3
-
1
-
2
19
5
Total
7
24
1
19
2
26 .
2
10
1
40
27
5
5
2
1
1
14
43
12
*The 6th Principal Meridian is considered the boundary between Eastern and
Western Kansas (Figure 1).
**General problem - more specific source unidentified.
***Saline water detected, after monitoring and/or tests; source not pinpointed.
Many still under investigation.
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CONTAMINATION INCIDENTS BY SALT WATER DISPOSAL WELLS
It is very difficult to separate incidents of ground-water contamination
from those of surface-water contamination. The problem of documenting cases of
ground-water contamination due to salt water disposal is further complicated
because it is diffidifU; to determine the cause of most ground-water contamination.
The twelve unresolved contamination incidents listed in Table 4 (listed under
"undetermined source"), all involved ground-water contamination. All twelve
cases are incidents of saline water detected in domestic or irrigation wells,
or flowing out of springs, stream banks, or abandoned wells (both plugged and
unplugged) or in natural drainages. Unlike contamination problems detected on
the surface, these problems can not be "visibly" traced back to their sources.
Each of these cases is documented by several pages of water quality analyses,
flag tests, and drilling or plugging records. In one case, numerous auger
holes were drilled by KDHE to sample water quality in an area surrounding a
household well contaminated by saline water. However even with thorough
documentation of the existence of a problem, the source of contamination in
each of the cases remains undetermined.
The slow flow of ground water makes it difficult to always reach a conclusion
as to the source of a ground water pollution problem. In the past, evaporation
pits and ponds were used to "store" salt water from oil and gas production.
Salt water seeped from these pits into the ground water and slowly moved away
from its point of origin. Because ground-water movement is slow, salt water
from those pits remains in the ground and will be drawn into water wells and
will discharge naturally into surface drainage for many years.
Proving a salt water disposal contamination incident in Kansas is further
complicated because many of the water bearing zones in the state have high
background mineralization. Because saline water is present does not mean it
was produced by a salt water disposal operation; it may have been caused by
natural mineralization.
Case #1
One of the well-documented but yet unresolved ground-water problems in
Kansas was reported by a landowner in September, 1979. The landowner discovered
a 10 foot diameter area of subsidence surrounding an abandoned, plugged well.
He reported that two years earlier his 30 foot deep house well went dry and he
was forced to have a deeper (60 foot) well drilled. The first test well drilled
in an attempt to establish a new house well had a chloride content of
4041 milligrams per liter (mg/1). Another 60-foot well was drilled which
produced water with a chloride content of 542 mg/1. Three neighboring wells
tested by KDHE produced saline water. KDHE then drilled several auger holes in
the area to determine the source of the salt water. Water quality analysis
from these holes and the plugging records of a nearby abandoned well did not
help in defining the source. Six additional holes were drilled in the area
highest mineralization and near an abandoned unplugged well. The water quality
analyses from these wells were helpful but inconclusive. Unfortunately, with
the augering equipment that KDHE owned, the agency was unable to do any further
analysis. KDHE suggested that the landowner hire a driller to drill several
holes in two particular locations to help in defining the problem. KDHE also
21
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suggested that if the landowner chose not to have further test drilling done,
another house well should be drilled in a third suggested location. A final
report on this situation was sent from KDHE to the landowner in February, 1980.
Case # 2
* \
Though it is difficult, it is not always impossible to determine the source
of saline ground water; the cooperation of local oil and gas producers help to
make this problem solvable. For example, another complaint concerning a
contaminated house well was made to KDHE by a landowner who had a 35 foot deep
house well drilled. After three months of use, the well water developed a bad
taste and odor. A second well was drilled to a depth of 55-65 feet and water
from the well was tested by a private laboratory. When it was found that the
chloride content of water from the well was 1130 mg/1, KDHE requested all of
the producers in the area to check for leaks in their salt water disposal well
surface pipes. Several producers contacted KDHE to inform the agency that they
had run pressure tests on their wells and found no evidence of salt water
leakage. One of the nearby producers ran a pressure test and found no evidence
of leakage, but told KDHE that he had unsuccessfully attempted to pull the
tubing on his salt water disposal well to check for leaks. He decided, on his
own accord, to abandon the disposal well and complete another deeper well for
salt water disposal. Six months after the complaint to KDHE (March, 1981), it
appeared that the source of ground-water contamination had been eliminated.
Case #3
Pits and ponds are considered a major source of saline ground-water
contamination; however, it is difficult to draw a direct connection between
ground-water contamination and a salt water pond without extensive ground-water
monitoring data. There is at least one case in Kansas in which a ground-water
contamination problem was inferred to have been caused by a salt water storage
pond. In this instance, a saline seepage zone developed adjacent to a salt
water pond. During a KDHE inspection, the district geologist discovered the
seepage zone; a sample of the seepage water had a chloride content of 50,000
ppm; and the operator was ordered to stop the seepage from the pond or his pond
permit would be revoked. The letter also stated that Kansas was attempting to
eliminate the use of salt water ponds at salt water disposal operations.
Therefore, the operator was to take this into consideration when deciding how
to solve the seepage problem.
It should be understood that salt water ponds in Kansas are allowed only
for emergency or temporary storage purposes. The regulatory agencies prefer
the use of salt water storage tanks. In view of the number of contamination
incidents related to emergency pits (Table 4) this is an understandable position.
In examining Table 4, it is immediately realized that the number of
contamination problems caused by injection wells is high. This table only
lists detected problems and there may be as many or more undetected problems of
a different nature. Again, though most of the contamination sources listed in
Table 4 indirectly affect the ground surface, ground water may be indirectly
affected by many of these contamination sources.
22
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REFERENCES
Denig-Chakroff, Dave, 1982, The Stiff diagram: a water "fingerprint" that may
help identify the source of ground water contamination; Unpublished document in
partial fulfillment of the requirements for Geology 851, Dr. Jay Lehr, Professor,
The Ohio State University, Columbus, Ohio, 14 pp.
Latta, Bruce F., 1963, Fresh water pollution hazards related to the petroleum
industry in Kansas; Transactions of the Kansas Academy of Science, vol. 66, no.
1 , pp. 25-33.
Jewett, John Mark, 1979, Oil and gas in Eastern Kansas; University of Kansas
Publications, Lawrence, Kansas, pp. 3-13.
Rice Engineering and Operating, Inc., no date, Fundamental guide for salt water
disposal wells; Unpublished document, distributed by the Kansas Corporation
Commission, Wichita, Kansas, 18 pp.
23
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SECTION 4
* \ UNDERGROUND INJECTION IN TEXAS
AGENCY RESPONSIBILITIES
The Underground Injection Control (UIC) Program in the state of Texas is
jointly enforced by the Texas Department of Water Resources (TDWR) and the
Railroad Commission of Texas (RRC). The Texas Department of TDWR has jurisdiction
over Class I, II, IV and V wells and the RRC has authority over Class II wells.
The Commission also has authority over Class II wells used for the enhanced
recovery of oil and gas and underground hydrocarbon storage.
The Underground Injection Control Section of the Oil and Gas Division of
the Commission is charged with administering a program which (1) processes and
issues new permit applications for injection/disposa-1 wells, (2) oversees the
operation of injection/disposal wells for which permits have already been
issued, and (3) coordinates the protection of fresh water is Texas with other
state and federal agencies. The Oil and Gas Division has a central office and
ten district offices to oversee the program. Each of the ten district offices
is staffed with engineers, geologists and engineering technicians who are
involved as needed for monitoring, inspection and reporting. Figure 4 is a map
showing the delineation of the districts and the city in which each district
office is located.
HISTORY OF SALT WATER DISPOSAL REGULATIONS
The RRC was created in 1890 for the primary purpose of regulating the
railroad industry. It was the first•regulatory agency authorized for the
State of Texas.
The Commission's oil and gas regulatory role began in 1917, when pipelines
were placed under its jurisdiction. Two years later, the Legislature enacted a
statute requiring oil and gas conservation, forbidding waste, and giving the
jurisdiction for regulating this industry to the Commission.
The Commission has been active in the control of underground injection
activities for more than forty years. The first permit to inject gas into a
reservoir producing oil or gas was in 1928; the first permit to inject water .
into a producing reservoir was issued in.1938. The permits specified that
injected fluids must enter no formation other than those authorized. By 1955
the Railroad Commission adopted a policy requiring all operators of wells
drilled|in new areas to obtain a letter from the Board of Water Engineers
stating the depth to which ground water should be protected. In 1961, the
Commission required that a letter from the Texas Water Commission stating that
the dri)ling of such injection well and the injection of such salt water or
other such waste into such subsurface stratum will not endanger the fresh water
strata in that area and that the formation or strata to be used for such salt
water or other such waste disposal are not fresh water sands.
24
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'C"~~! ~': p"15"' ~"' ~' nr
Dillrict Offices
I SAN ANTONIO
7 SAN ANTONIO
3 HOUSTON
J CORPUS CHRISTI
5 KILCORE
6 KILCORE
78 ABILENE
7C SAN ANCELO
8 MIDLAND
8A LUBBOCK
9 WICHITA FALLS
10 PAMPA
Figure 4. District map ot Oil and Gas Division, Texas Railroad Commission.
25
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In the ensuing years, revision of the laws and regulations pertaining to
salt water disposal and injection required a strengthening of the regulations
in this area. In January, 1969, a Commission order outlawed the use of salt
water disposal pits for both the storage and evaporation of salt water. On
January 2, 1980, the"*'Underground Injection Control (DIG) Section of the Oil and
Gas Division was created to administer a program consistent with state and
federal law, including oversight of the injection, disposal, and hydrocarbon
storage well permits already issued, processing and issuing new permit appli-
cations, and coordinating with EPA and other federal and state agencies
in a concerted program to protect fresh water in Texas. And, on April 23,
1982, Texas became one of the first two states to receive primacy in enforcement
of the UIC program.
A better concept of the magnitude of the program for Class II wells in
Texas can be provided by reviewing some statistics. According to a report
prepared by the Water Task Group of the Midcontinent Oil and Gas Association
(1975), in 1973, there were over 51,500 salt water injection or disposal wells
in the state. Approximately seventy percent of these wells were used for
secondary recovery or pressure maintenance operations. Approximately 16,000
wells were used for salt water disposal. This number was evenly divided between
disposal into non-productive and productive formations. Over five billion
barrels of salt water were injected for disposal and recovery operations in
1973. By 1983, the estimated number of injection/disposal wells had been
reduced to 44,500. However, the responsibilities of enforcement of the UIC
regulations did not decline proportionately.
SUMMARY OF REGULATIONS
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. Certain provisions included
in rules regarding casing and plugging of wells are also applicable. Appendices
E, F, G and H contain the complete text of these rules and a summary of the
applicable provisions of the rules are described below.
Water Protection
This rule requires that fresh water whether above or -below the surface,
shall be protected from pollution whether drilling, plugging, producing or '
disposing of salt water already produced. This rule applies to all operators
conducting oil, gas or geothermal resources development and production operations.
The rule prohibits the use of salt water disposal pits for storage and
evaporation of oil field brines and geothermal resource waters or other
mineralized waters, without specific approval from the Commission. The rule
outline's instructions pertaining to the use of basic sediment pits, impervious
collecting pits, disposition of oil field brines, geothermal resource waters,
or other mineralized waters, and exceptions to the rule, as well as penalties
to be imposed if the rule is violated.
26
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The rule provides instructions regarding the disposition of all wastes so
as to ensure adequate pollution prevention. All data applicable to salt water
haulers, including permitting, identification, and salt water hauling operations,
are also outlined.
Disposal Wells 4 \,
" V
Information regarding the disposal of salt water, or other oil and gas
waste, by injection into a porous formation not productive of oil, gas or
geothermal resources is outlined. Other matters contained in the Rule consist
of filing of application (Form W-14); notice and opportunity for hearing;
protested applications; geological requirements; and special equipment
requirements.
The Rule also outlines instructions regarding records maintenance; monitoring
and reporting; testing; plugging; and penalties to be imposed for non-compliance
with the rule. Besides permit revocation., penalties may also be imposed for
non-compliance with the rules.
Fluid Injection into Productive Reservoirs
This statewide rule governs applications for the permitting of fluid
injection into reservoirs productive of oil, gas or geothermal resources.
Application for a permit is on Forms H-l and H-1A. The rule also contains
matters regarding the application review; notice and opportunity for hearing;
protested applications; and modification, suspension or termination of permits.
Also included are requirements regarding casing and cementin.g (in accordance
with another statewide rule); special equipment (tubing and packer, pressure
observation valves); records maintenance; monitoring and reporting; testing;
plugging; and penalties for violation of the Rule.
Underground Hydrocarbon Storage
This rule prescribes the methodology for permitting an underground
hydrocarbon storage facility. It outlines the procedures for filing an
application; technical requirements pertinent to the storage facility; notice
of and opportunity for hearing; transfer or permits; and subsequent Commission
action.
The rule also prescribes the system for monitoring and reporting, testing,
plugging, and penalties to be assessed for violation of the rule.
REGULATORY AND PERMITTING PROCEDURES FOR. CLASS II WELLS
Casing and Cementing
Cl.ass II wells must be cased and cemented to confine the injection fluids
to the'injection interval. Cement around surface casing must be circulated to
the surface by the pump and plug method and the casing cement must meet certain
specified quality. If a well is converted from a production well to a disposal
27
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well and injection is into a formation above the producing formation, one of
the following criteria must be met to determine the height of cement above the
disposal zone:
a) presence of 100 feet of bonded cement as determined by a cement bond log,
b) 250 feet oft.cement as evidenced by a temperature log, or
c) 400 to 600 feet of cement as determined by a slurry yield calculation.
Tubing and Packer
All new wells must be completed with tubing set on a mechanical packer
which shall be set no higher than 100 feet above the top of the permitted
interval. Existing wells must have been so equipped at the time of the first
workover or no later than January 1, 1984.
Completion Reports
A completion report (Form W-2 or G-l) must be filed with the appropriate
district office within 30 days of completion or conversion to disposal, injection,
or underground hydrocarbon storage operations to reflect the new or current
completion.
Operating Requirements
Pressure limitations are established to provide adequate assurance that
injection will not initiate fractures in the confining zone.
Mechanical Integrity
All Class II wells must be pressure-tested at least once every five years
to determine if leaks exist in the casing, tubing, or packer. The appropriate
district office must be given 48-hour notice prior to the test. The long string
casing must be pressure tested at the maximum authorized injection pressure or
500 psig whichever is less, but must be at least 200 psig. This test must be
conducted prior to the beginning disposal operations and at least once every
five years thereafter. As an alternative to the pressure-testing, the operator
may monitor the tubing-casing annulus pressure and report the results annually
to demonstrate that no additional pressure-testing is needed.
Monitoring and Reporting
i
The pressure and injection volume of each well shall be monitored on at
least a monthly basis and reported to the Commission annually on Form H-10.
For Class II wells, except hydrocarbon storage facilities, any downhole problem
must be reported to the appropriate district office within twenty-four hours
and confirmed in writing within five working days. Operators of hydrocarbon
storage facilities must report problems to the appropriate district office
immediately and must confirm this report in writing within five days.
i
Area of Review
1
Class II disposal and injection well operators must examine the data of
record for wells that penetrate the proposed injection zone, within a quarter
mile radius of the proposed well to determine if all abandoned wells have been
28
-------
plugged in a manner that will prevent the movement of fluids into strata other
than the authorized zone. Applicants for new permits must submit a map showing
the location of all wells of public record within a 1/4 mile radius as part of
their permit application.
For those wells^'that penetrate the top of the injection zone, the applicant
must attach a tabulation of the wells showing the dates the wells were drilled
and the present status of the wells.
If the applicant can show, by computation, that a lesser area will be
affected by pressure increases, then the lesser area may be used in lieu of the
fixed radius.
No permit will be issued where the information submitted indicates that
fresh water sources will be endangered unless permit conditions require
appropriate corrective action in the area.
Plugging and Abandonment
All Class II wells must be plugged upon abandonment in accordance with
commission regulation. Plugging must begin within rrinety days after injection
operations have ended. The purpose of plugging is to assure the protection of
all formations bearing usable-quality water, oil, gas, or geothermal resources..
ADMINISTRATIVE PROCEDURES
Complaints and Enforcement
Suspected cases of ground water contamination or situations which may lead
to contamination of ground water may be discovered in a variety of ways. First,
field inspectors may notice a problem or violation during routine on-site
inspections of Class II wells. Second, the operator may notice changes in
annular pressure or other signs that a leak in the casing, tubing or packer may
be present and notify the district office. Third, a landowner or other party
may file a complaint with the Commissioner about operator activity or problems
with a water well. In all instances, it is the field inspector who must
investigate and initiate any enforcement actions.
In suspected ground water contamination incidents, the complaint is often
the mos,t common route of recognition. A citizen will complain about the quality
of water in a water well or discharge seepage of salt water at the land surface.
A citizen may either call the district office or the central office in Austin.
When a complaint is received, a complaint form (Appendix D) is filled out. If
the complaint is received in the district office, a copy is sent to the central
office for coordination to assure that all complaints are followed through. If
a complaint is received in the central office, a copy of the complaint is
forwarded to the district for investigation. Regardless of the office in which
the complaint was received, the complaint is logged on a 3 x 5 card which
contains the following information:
i
- complainant name,
- company (operator),
- lease,
29
-------
- county,
- type of problem,
- action taken, and
- date resolved.
The complaint is assigned a follow-up date and filed by the name of the
complainant. The lst\nd 15th of every month, the card file is checked for
status of the complaint"^ If the central office has not been advised of district
action or resolution, a follow-up letter about the complaint is sent to the
district requesting an update. When the complaint is resolved, it is filed by
county. An automated tracking system is proposed for a a more efficient way of
handling complaints. Through this procedure and tracking system, it is assured
that each complaint received is investigated and followed up until eventually
resolved.
It is the responsibility of personnel in the district offices to investigate
complaints and respond to other field problems. To assist inspectors in
investigations, Statewide Rule 2 grants representatives of the Commission the
permission to enter upon any lease and make any tests necessary to determine
compliance with the rules. If a problem is brought to the attention of the
district personnel by a complaint, the inspector interviews the complainant and
files a written report, sending a copy to the complainant. The inspector then
contacts the operator and makes an inspection. If the inspection finds a
situation where pollution is occurring or is imminent, the commission may order
the well shut in under the applicable rule provisions. If the violation is
minor and not directly causing pollution, the operator will be given a specified
time to correct the problem. In either situation, the inspector will file a
report detailing the investigation and any recommendations for resolution. If
penalty actions are anticipated or requested, a draft list of information which
will assist in efficient processing of the action has been formulated by the
division. The following information also serves to document the details of the
investigation:
1) date,
2) operator,
3) lease and number,
4) field,
5) county,
6) operator address,
7) type of discharge or violation (leak, pit, leaking well, etc.),
8} type of fluid, ,
9) source of fluid,
10) estimated amount of fluid,
11) size of area affected,
12) chloride concentration (field test),
13) date sample(s) submitted to lab,
14) custody tag number,
15) date violation first noted,
15) is violation still continuing?
17) if not, give date corrected,
18} depth of fresh water in area and chlorides,
19) any water courses affected?
30
-------
20) identification of water course,
21) list actions in this case (attach correspondence),
22) list any previous violation by operator and give dates,
23) describe violations (exact details and dates),
24) name of inspector(s),
25) attach pictVtes of site,
26) attach plat or lease showing area affected, where samples collected
and location of wells, tanks, pits, etc.,
27) attach any appropriate inspection tickets or worksheets, and
28) additional information.
If the violation is not corrected, the district directors may request a
show-cause hearing by the Commission. The hearing is placed on the commission
docket and notification is sent to all parties and published in the Texas Register.
At the hearing, all testimony and evidence is heard and an examiner recommends
a course of action to the Commission which specifies a time period within which
the violation must end. The order issued by the Commission may 1) maintain the
shut-in order, 2) order pipeline severance, 3) modify revoke or suspend the
operator's permit, 4) require the well to be plugged, or 5) impose other
necessary corrective measures.
If the violation is still not resolved as the Commission has ordered, a
second hearing may be held and the operator may be fined $500 per day for
contempt and may be subject to up to six months imprisonment for each contempt
citation.
The Commission may further request that the Attorney General seek civil
penalties or other injunction to remedy the violation. A maximum of $10,000
per violation or per day of violation may be collected where an oil or gas
disposal well is involved. A maximum of $5,000 in criminal violations may also
be collected. Finally, the commission may invoke other less-used powers to
remediate the violation.
CONTAMINATION INCIDENTS BY SALT WATER DISPOSAL WELLS
In an effort to document ground water contamination incidents related to
underground injection or disposal of salt water, files of plugging reports and
complaints were compiled by state personnel and made available for this study.
Information on wells plugged by the Railroad Commission was available for the
years ^967 through 1975. Information for more recent years was based on
complaints received by the Commission which alleged contamination due either to
salt water injection or disposal wells. Data were available for the periods
January 1979 through June 1930 and January 1982 through December 1982.
The information available from plugging records of the Commission where
the problem was attributed to either a disposal or secondary recovery well is
included in Table 5. Information on the cost of plugging, a brief description
on the'situation, the area contaminated and completion or operation dates have
been included. The cost figures are for the year during which the investigation
was conducted and are not referenced to a base year. The costs also reflect
31
-------
TABLES. SUMMARY OF WELLS PLUGGED BY THE COMMISSION WHERE THE PROGRAM
WAS ATTRIBUTED TO A DISPOSAL OR INJECTION WELL, 1967
THROUGH 1975
CO
ro
SUMMARY
Cost: $1868.00 - TD 2010 -
leaking oil and salt water.
The leakage is apparently
being caused by water in-
jection on offsetting leases,
of which there are three.
Cost: $648.70 TD 420 -
originally plugged 1957. Started
leaking to surface 1968. Well
offset by shallow waterflood.
Injection well shut down - leak
stopped.
Cost: $976.50 - The most apparent
source or cause of this problem
is shallow disposal wells.
Originally plugged 1950 (Well 1) -
Well 1-B TD 3194 - wells adjacent
to waterflood
Leaking salt water through hole
in surface casing
Cost: $972.25 - TD 1310 - leaking
salt water and gas 58,000 ppm.
Salt water is apparently the
result of waterflood operations
to the east, north and northeast.
TD 1767 - 48,000 ppm salt water.
Leakage probably caused by
waterflood operations to the east.
DATE OF
COUNTY INVESTIGATION
Wichita
1968
AREA
CONTAMINATED
Land damage
SECONDARYCOMPLETION OR
DISPOSAL RECOVERY OPERATION
WELL WELL DATES
3*
x ^- 1921
Shackelford 1968
Hubbard Creek
Watershed
1954
Young
Runnels
Runnels
Baylor
1968
1968
1968
1969
Land damage x
Land damage & creek -
Land damage
Land damage
1938
1950
1951
1961
Archer
1969
Land damage
1925
-------
TABLE 5. (continued)
co
CO
Plugging report indicated Knox 1969
108' of 8 5/8" set and
cemented w/90 sacks cement.
RRC determined there was no
surface pipe in well. SWD
from 203'-600'. SWD well
deepened in 1964 to 2000+ feet.
Contamination in 1968
caused by hole in casing
which allowed salt water to
be pumped into the zone from
200' to 300'.
Cost: $2206.40 TD 3509' Stephens 1969
15 BPD salt water - 53,150 ppm
cl. Well is offset of Unit
Waterflood. Nearest injection
well about 1800'--South.
Cost: $1,147.45. TD 3182. Stephens 1969
Originally plugged 1923. Hole
full of mud and left 106' of
8 1/4" and 230' of 12 1/2" pipe
in well. Adjacent well used as
a disposal well but quit when
leaking well was discovered.
Cost: $953.45 TD 827' - leaking Throckmorton 1969
10 BPD' salt water. 350' injection
well 600' NE of leaking well.
Cost: $817.60. Well offsetting Coleman 1969
a waterflood of a 400' sand
Cost: $2,518.63 - leaking salt Wood 1969
water 32,000 ppm cl TD 4991 -
originally plugged 1954. Offset
lease SWD well has casing leak
@ 200' which is contributing to
problem.
Irrigation Wei 1
1959
1921
1922
Land damage
Ground water
Land damaae
1926
1925
1951
-------
OJ
-p.
TABLE 5. (continued)
OriginaTTy plugged 1957 -
TD 2400' - Form 4 indicates
that 100' of surface pipe had
been set and cemented with 40
sacks of cement. They also
reported that a cement plug
was placed at the surface;
however, we were able to run
a string line to a depth of
about 110', so evidently
this plug was not set. Two
water injection systems in
the area could be causing
the well to leak. Disposal
well seems to be the most
likely source for the
problem. A tracer survey
revealed a hole in the pipe
at a depth of 1800'. The two
wells are 3000' apart.
Cost: $1676.50 - TD 1795 -
leaking 20-30 BPD salt water.
Waterflood on adjoining lease
800' south of leaking well
shut down in September. Presently
injecting 100 BPD into well #10
about 1600' SE of leaking well.
Well apparently started flowing
salt water in 1961. There have
been a number of breakouts in the
past (1965-67) as a result of
overcharged conditions in this
area. Pressure on this well
was measured @ 115 psi after it
had been shut in 11 days. Injection
from about 700-800 psi.
Cost: $847.74 TD 4156 SWD well
about 3/4 mile south of leaking
well.
Knox
1970
Land damage
1957
Knox
1970
Land damage
1962
Cooke
1970
Land damage
Throckmorton 1970
Land damage
1961
-------
TABLE 5. (continued)
CO
01
Cost: $1,216.23 - Injection
project 1/2 mile away
TD 2350 - Cost: $1325.50 -
Haskell
Knox
1970
1970
Land damage
Ground water x
x ?
1960
reportedly plugged with mud
in 1960. Salt water leaking
from hole in pipe just below
steel cap. 75,700 ppm cl.
SWD may have been the source of
the leakage. Had hole in pipe
at 1800' in 1969.
Cost: $1185.48 TD 3100' - well Stephens 1970
plugged by RRC in 1968. Began
leaking again 5 BPD salt water,
shallow zone charged by a
bradenhead injection several
years ago.
Cost: $169.50 - TD 418. Several Stephens 1970
shallow disposal wells ranged
in depth from 100-490' leaking
well flowing salt water 88,000
ppm cl.
Cost: $2434.04. TD 2478. Water Crane 1971
flow from the well is quite
variable, ranging from no flow
to an estimated 300 BPD. 142,000
ppm cl.
Cost: $9560.04 - TD 2960' - Howard 1971
originally plugged 1947. Leaking
75-100 BPD salt water 113,000
ppm cl.
Cost: $3046.87 - wells standing Mitchell 1971
open. A waterflood 4500' SE of
leak may be contributing.
Gonzales Creek
1921
Pecan Creek
1948
Land damage
1934
Land damage
Large fresh water
tank
Land damage
1937
1965
-------
TABLE 5. (continued)
CJ
cr>
TD 1250 - leaking salt water Cooke 1972
11,500 ppm. The leakage is
apparently being caused by ,
waterflood operations. Plugging
report indicates that it was
plugged with mud.
TD 4050 - Cost $1338.21 - Young 1972
flowing salt water 5-10 BPD.
Originally plugged with mud.
Annul us salt water disposal from
354'-2302' from April 1961 -
Feb. 1971.
Cost: $660.83 - seeping mud and Young 1972
salt water. Well is located
about 3500' south of a SWD well.
Cost: $871.25 - TD 2801' - Howard 1972
Injection of water at about 600
Ibs. pressure may be contributing
to the leak.
Cost: S942.00 TD 1025 - leaking Navarro 1973
Cost: $2952 - plugged 9/73 Jack 1973
Flowing 500-800 bbls/day.
Injection well 5500' from plugged
well - not believed a problem
9/73 broke out (at injection well)
on 11/30/73 flowing salt water
and oil. 12/7/73 one of City
wells went salty (150 ppm to 500
ppm)
Land damage
1935
•s*'
1950
Land damage
Land damage
Land damage
Surface and probably
aquifer. City water
wells 190-345' - not
contaminated (9/73)
1941
1958
1
or
more
1936
(drilled)
1941
(plugged)
-------
TABLE 5. (continued)
Cost: $857.80 - TD 1020 - leaking Shackelford 1973
1/2 BPD apparently due to water
injection on offset lease.
Cost: $96,041.46 - TD 5796 - Haskell 1974
originally plugged 1954, replugged
1973 - salt water 10-15 BPD 24,900
ppm cl.
Cost: ? - plugged 3/74 - Salt water Cooke 1974
broke out in and around 60' water
well - also mud and salt water
appeared in vicinity of a dry hole
200' NW of water well. Base of
fresh water 1300' (Trinity Sand).
Found tubing leak in 2 of injection
wells. Nearby 500' water well not
now contaminated.
Cost: $1891 - plugged 1/75 Wichita 1974
1/29/75 mud and water forced way Shackelford 1975
into house through cement slab
of house. Flow decreased when
injection stopped.
Cost: $7,694 Plugged: 8/75 Harris 1975
Flows salt water - Another
old well leaked SW & abandoned
8/74 (near disposal well)
1 disposal well is WDS-38,
permitted 4/68
3 disposal wells 3100'; 2700';
& 2150' - Report connects flow
from well w/injection rate of
all three injection wells
Land damage
1949
Land damage
1954
Water well and
trinity aquifer
and surface
1956
Surface
Surface
1
or
more
1953
1941 (Drilled)
1948 (Plugged
w/mud only!
Surface and probably 3
ground water
1920
-------
TABLE 6. SYNOPSIS OF COMPLAINTS OF ALLEGED CONTAMINATION BY
UNDERGROUND INJECTION, JANUARY, 1979 THROUGH JUNE, 1980
DATE RECEIVED
1/79
COUNTY
Archer
COMPLAINT
Breakout of abandoned well. Well replugged with State funds.
Con-
OJ
CO
2/79
3/79
3/79
3/79
4/79
4/79
4/79
5/79
Young
Montague
Cooke
Archer
Wise
Wichita
Young
Jack
tributed to salt water injection programs on surrounding leases*
Complaint of two SWD* wells equipped with 4 1/2" casing only/ No
apparent relative pollution problem.
Water well contamination which complaining party believed contribu-
table to nearby SWD well. Conclusion: No apparent violation re:
SWD well. Contamination of well apparently due to col i form bac-
teria infiltration and high concentration of manganese in aquifer.
Breakout of abandoned well. Well replugged by operator of adjacent
lease. Breakout contributed to increased salt water injection on
this lease.
Complaint of stock pond contamination due to tubing or packer failure
in SWI** well. Tubing replaced, problem resolved.
Concern that newly completed SWD well would cause problems with
nearby city water wells. Inspection revealed well properly equipped.
Lab analyses of water samples) revealed no contamination of city
wells. No further complaints to date.
Breakout of 3 abandoned wells. Wells reentered and replugged by
operator of waterflood on adjacent lease. Breakout occurred as
injection program expanded.
Casing leak in SWD well resulting in salt water flowing to the ground
surface. Well repaired, problem resolved.
Complaint that newly drilled shallow well was salty. Inspection
revealed water well had been drilled adjacent to abandoned well
replugged with State funds September 4, 1973. Abandoned well was
flowing +_ 1000 bbl/day salt water prior to replugging. Breakout
contributed to SWI programs on surrounding leases.
-------
TABLE 6.(continued)
£779
Wichita
9/79
10/79
11/79
11/79
12/79
12/79
Knox
Archer
Archer
Archer
Clay
Wichita
1/80
2/80
2/80
Knox
Clay
Archer
Brackish water flowing into newly constructed stock pond. Com-
plaintant believed nearby SWI well causing problem. Inspection
revealed no apparent malfunction in SWI wells. Pond dug adjacent to
irrigation ditch containing brackish water. This was concluded to
be most probable cause of contamination.
Complaint of salt water being injected flown annulus of producing
well. Situation rectified through pipeline severance. No apparent
pollution problem. e_-
Tubing failure on SWI well on lease resulted in salt water flowing to
the ground surface. Tubing replaced, area cleaned.
Breakout of abandoned well. Replugged with State funds. Breakout
contributed to increased secondary recovery operations in area. No
particular SWI well found to be defective.
Breakout of abandoned well. When nearby SWI well was shut in, flow
from breakout ceased. SWI well recompleted, no further problems.
Vegetative kill areas which ranch foreman felt was caused by nearby
SWI wells. Inspection of wells revealed no apparent malfunction.
Kill areas concluded to be due to abandoned pit localities upslope.
Breakout of unidentified abandoned well in the community cemetery.
Re-entered and replugged with State funds. Contributable to large
waterflood operations to the'north and west. Viewing the number of
abandoned poorly plugged or unplugged wells in the cemetery and in
the area, and the scope of secondary recovery operations in the area,
this type problem -can be expected to occur again at any time.
Breakout of abandoned well. Well replugged with State funds.
Contributable to workover of SWI wells on adjacent lease.
Water well contamination which complainant felt was due to SWI wells
on nearby lease. Tests showed no apparent malfunction of SWI wells.
Area residents stated that this particular aquifer had been high in
salt for + 30 years.
Breakout of abandoned well on adjacent lease. Operator of adjacent
lease reentered and replugged leaking well. Contributed to SWI well
recently completed nearby in same zone.
-------
TABLEjB.(continued)
-P.
o
3/80
3/80
4/80
4/80
4/80
4/80
5/80
5/80
5/80
5/80
Young
Young
Clay
Archer
Archer
Knox
Wichita
Jack
Wichita
Archer
Salt water flowing to ground surface due to tubing failure in SWI
well. Tubing repaired, problem resolved.
Seepage of brackish water near city. City feared contamination of
nearby fresh water wells. Tests of nearby SWI wells revealed no
apparent problems. Recent inspection revealed seep area has dri«d
up. Appears to be contributable to abandoned pit locality neapby.
>
Salt water flowing to the ground surface as the result of tubing
failure. Tubing replaced, problem resolved.
Salt water breakout. Well No. 5 on adjacent lease was found to be
equipped for SWI through 5 1/2" casing only. No. 5 shut in, breakout
ceased.
Dug cellar in yard, pit filled with salt water. Found that cellar
pit had been dug _+ 50 yards from prior breakout locality.
Breakout of abandoned well resulted in salt water filling fresh water
pond. SWD well shut in and breakout ceased. Tubing leak and casing
leak repaired, contaminated pond currently being pumped out.
Complaint of salty water seep near property. Complainant felt
nearby SWD well was causing problem. Test of SWD well revealed no
apparent problem. Seep area surrounded by old salt scald areas.
Apparently contributable to leaching of ground salts.
Packer failure in No. 4 SWI well on adjacent lease resulted in salt
water flowing to the ground surface. Packer replaced, problem
resolved.
Breakout of abandoned well.
breakout ceased.
Tubing leak in nearby SWD well repaired,
Pit dug while constructing grain elevator filled with brackish water,
owner blamed nearby SWD well. Test of well revealed no apparent
malfunction. Low chloride content of seep water led to conclusion of
high ground water table. Substantiated by later reports and
i nqui ries.
-------
TAB-LE.&.tcontinued)
6/80
7/80
Clay
Cooke
Leakage from nearby SWD well resulted in salt water flowing to the
ground surface and contaminated stock pond. SWD well to be plugged,
contaminants currently being removed from affected pond.
Complaint of salt water surfacing around SWD wells. Found to be
result of tubing failure. Tubing replaced, problem rectified.
r*'
*salt water disposal
**salt water injection
-------
plugging procedures in accordance with the rules at the time the well was plugged!
A review of Table 5 indicates that land damage accounts for over 60 percent of
the areas which were contaminated, while ground-water contamination was confirmed
in only four of the cases and suspected in another two cases. Flowing abandoned
wells provided the best documentation of ground-water contamination which could
be linked to injection, operations.
\
Information for more recent years was obtained based on complaints and
showed similar results. Table 6 contains a description of the complaint and
findings for the period January 1979 through June 1980. Of the 31 .complaints
in which contamination problems were attributed to underground injection, eleven
were found linked to abandoned wells which flowed at the surface and which
could be associated with nearby injection operations. According to available
information, no reports of ground-water contamination resulting from complaints
about saline water in a water well were directly attributed to injection
operations. Table 7 contains a summary of the information available for
1982. Of the 220 complaints received which alleged problems due to injection
or disposal wells, there were 12 incidents of breakouts through abandoned or
improperly plugged wells, 59 confirmed cases of surface problems and 149 cases
where no pollution or damage occurred. The Commission further concluded that
during 1982 no contamination of ground water was confirmed or documented.
To better understand the difficulty in positively documenting ground-water
contamination from injection operations, the following two case histories serve
to illustrate the procedures and perseverence necessary to attempt to document
a problem.
Case #1
Complaints from occupants of two farmhouses approximately one mile apart
relating to increased chlorides and iron in well water were received by the
Commission at approximately the same time. The houses were located in Sutton
County in a sparsely populated area near a fairly new oil field which had been
developed around 1959. The complainants indicated that they had never experienced
any problems before. A quick reconnaissance of the area revealed that one
field to the north of the houses was under waterflood and was producing at
approximately 2700 feet. Another operator west of the houses had 4 producing
wells and one disposal well. The water wells were developed in approximately
35 feet of alluvium at a depth of approximately 85 feet.
Thp investigation began with a trial and error process to check the
condition of wells in the area. Testing began with a bradenhead pressure test
using fresh water. By testing the wells, one injection well was found to have
holes in the tubing and the tubing was replaced; another-well had a leak in the
long string at 1400 feet which was subsequently repaired. Neither of these
wells could be directly implicated as the source of the problem. An additional
gas well located to the southwest of the houses was also checked for leaks.- A
leak inUhe casing two feet below the ground was found and subsequently repaired,
but agajn, could not be confirmed as the source of the problem. Fluorescein
dye was also used to try to confirm a source, but to date, no source of ground-
water contamination has been documented despite an intensive field effort.
42
-------
TABLE 7. SUMMARY OF COMPLAINTS INVOLVING
INJECTION/DISPOSAL WELLS, JANUARY, 1982
THROUGH DECEMBER, 1982*
PROBLEMtfR FINDING NUMBER OF WELLS
- '
**Sa1t water surface breakouts through
unplugged or improperly plugged
abandoned wells 12
Salt water spills 4
Injection/disposal wellhead leaks 1
Flowline leaks 30
Salt water in pits or firewall 11
Salt water in waterway, drainageway,
or ditches "" 3
Bleed-off water to land surface 1
Injection/disposal well pump leaks 2
Salt water seeps immediately adjacent
to injection/disposal well 2
Salt water tank leak or overflow 5
No damage or no pollution 149
TOTAL 220
*No contamination of ground water was confirmed or documented.
**These abandoned wells were plugged or re-plugged with state
I funds when a responsible operator could not be located.
43
-------
Case #2
When a salt water breakout occurred in Limestone County, the breakout
appeared to be definitely caused by injection well operations. The breakout
occurred approximately 1800 feet away from a production and injection well
which were located oVi'ly 200 feet from each other. The field had been developed
in the 1920's and production was from a depth of approximately 2900 feet. Well
records showed two unidentifiable map symbols in the vicinity of the breakout.
Testing of the quality of the breakout fluid and fluid being injected through
the injection well indicated that the two were of approximately the same quality.
The breakout was a source of particular problem because it was flowing into a
lake which served as the source for a public water supply. The problem with
documenting the source of the breakout was complicated when it was discovered
that the breakout was on the opposite side of a fault from the production/injection
wells. The injection well was shut in to determine if the breakout would stop.
The flow was somewhat reduced, but did not stop. It was then thought that a
nearby quarry may be contributing to the problem. In the interim, the operator
of the disposal well volunteered to have 390 barrels of salt water a day hauled
away from the breakout to help ease the urgency of the problem. The breakout
site was found to be an abandoned unplugged borehole_ which was subsequently
plugged with State funds.
Additional cases of suspected problems, but unconfirmed documentation may
thus make compilations of figures such as those found in Tables 5, 6, and 7
misleading because they do not convey the magnitude of the problem, only the
documentation that a problem exists.
44
-------
APPENDIX A
" i
APPLICATION FORMS USED BY KCC IN THE ADMINISTRATION OF
THE KANSAS UIC PROGRAM.
To:
STATE CORPORATION COMMISSION
CONSERVATION DIVISION - UIC SECTION
200 COLORADO DERBY 8UILOINC
•ICHITA, KANSAS 47302
APPLICATION FOR INFECTION 1ELL
DISPOSAL! IENHAKEO RECOVERY! I
DATE
Operator License i
Operator:
Name a
Address
Deepest usable water formation
Docket No.
_,Sec. ,T S,R
feet fro» N/S lection line
feet fro» t/E section line
WELL SO.
Lease Kj.
Field Na>
County
Contact Person Name
Phone_.
Depth
feet to zone bottom
Old »ell Being Converted} JNewly Drilled Cell
Qel,
to be drilled!I
Mechanical Integrity Test Completed yES__NO__ DATE
Fieldman observing or scheduled ~
_tested/scheduled
Test results enclosed
D
Not applicable
u
Surface elev. feet, »ell Total Depth feet, Plug back depth feet
INJECTION F06MATION DESCRIPTION
name top/bottom perf/open hole
depth
to
LIST Of WELLS SUPPLYING SALT »ATER (use entra sheet If needed)
LEASE
OPERATOR
1.
2.
3.
it.
LEASE
NAME
LEASE
DESCRIPTION
•ELL
IDENT f
6.
7.
PRODUCING
FORMATION
STRATA IEPTH
TOTA1. DISSOLVED
SOLIDS
1.
2.
i.
6.
7.
8.
Liquid Injection Rate: Ha&
or Gas Injection Rate: Hax~
Injection Pressure: Mln
bbl/day, Mln_
'_ scf/day, «ln_
_pslg, Ha.
bbl/day
scf/day, Type of gas
pslg
LIIHOLOCY fro. Injection Zone up to deepest Usable later:
Estimated Ma*lM« safe Injection pressure_
FOHH U-1
Figure A-1. Application form for salt water disposal wells in the state of Kansas.
45
-------
Name and Addresses of those receiving copies of this application and attachments:
OFFSET OPERATOR'S AND
LANDOWNERS CORRECT NAME HAILING ADDRESS
A notice of this application was placed In the following general circulation
newspaper:
Paper Name Oate of Issue
Address page of notice
I hereby certify that the statements herein are true and correct to the best of my
knowledge and belief:
Applicant or Duly Authorized Age/it
Subscribed and sworn to before me this day of 19 .
Notary Public
My Commission Expires
INSTRUCTIONS
1. Attach plat map showing subject well and all known oil and gas wells
abandoned,being drilled, and dry holes within 1/2 mile, giving name of
operator, landowner, and all leases and wells to be connected to the system.
1. Attach Drillers Log (Form ACO-1). Appropriate Surety must be on file with
Conservation Division.
3. Fill in schematic drawing of subsurface facilities Including: Size, setting
depth, amount of cement used, measured or calculated tops of cement of
surface, intermediate (if any) and production casing; size and setting depth
of tubing: type and setting depth of packer; geological zone of Injection
showing top and bottom of injection Interval.
-------
ENHANCED RECOVERY APPLICATION
(Complete the following)
1. Present dally oil production of lease or unit from formation to be
repress'yred. barrels.
Z. Number of'presently producible wells on lease or unit producing from formation
to be repressured. wells. (Include the well to be used HS Input,
If producing or dry and abandoned.)
3. Number of Injection wells ultimately to be used in repressurlng the lease or
unit. wells.
*. Number of wells, completed In formation to be repressured, to be converted to
input wells. wells.
5. Number of wells to be drilled for input wells. wells.
6. Number of oil wells to be drilled to formation to be repressured on lease or
antt. wells.
7. Estimate of maximum dally oil production on lease or unit from formation to be
repressured. barrels.
8. Project will ultimately be: a five spot , a seven spot , a
nine spot , a peripheral , or an Irregular flood.
9. Supplemental information for additional producing formations other than
formation to be repressured.
FORMATION NAME NUMBER Of PRODUCIBLE WELLS DAILY OIL PRODUCTION
NOTE: If estimated maximum daily average oil produced per well Is more tnan 50
barrels, this-application will be set for Hearing.
ENHANCED RECOVERY INOECTION FLUIDS:
Original fluid quality/analysis:
Additives:(chemical name, formula, phase, concentration)
ToKicity: high , medium , low , none
Carcinogensls: high , medium , low , none
Density of fluid: Ibs/gal or gm/ml or gas gravity
Viscosity of fluid: cp
Estimated injection zone permeability: md
Well Treatment Plan:
Figure A-2. Application form for enhanced recovery wells in the state of Kansas.
47
-------
WELL COMPLETION:
STRING
i '•<
SIZE \^
SETTING
DEPTH
CEMENT
SACKS
CEMENT
TOPS
BOTTOMS
CONDUCTOR
SURFACE
INTERMEDIATE
PRODUCTION
TUBING
TUBING TYPE 4 GRADE:
PACKER TYPE 4 DEPTH:
LIST LOGS ENCLOSED:
?)^ InStalldtton- <"rke" appropriate lines, Indicate cement, and show
Figure A-2. (continued)
FORM U-1
48
-------
APPENDIX B
FORMS USED BYfcCC AND KDHE TO INVESTIGATE SALT WATER CONTAMINATION.
FIELD REPORT
DATE:
OPERATOR:.
LEASE:
LOCATION: Sec.
COUNTY:
. Twp. .
Rge.
REMARKS: (What was said or seen)
FOR THE STATE (signed)
i MAKE TWO (2) COPIES. KEEP ONE AND SEND THE ORIGINAL TO: KCC. 200 Colorado-
Derby Building, Michigan. Kansas 67202.
I
FigUre B-1. Form used by KCC field investigator to detail salt water disposal well problem.
49
-------
State of Kansas
Department of Health & Environment
Division of Environment
Bureau of Oil Field and Environmental Geology
Topeka, Kansas 66620
REPORT OF INVESTIGATION
Initial Report: Recheck:
Date of Investigation: Location:
Company, City, etc: County:
Problem:
Reason for Investigation: :
Persons Interviewed: —-
Findings: .—
Action and/or Recommendation:
Date Investigator
l
Figure B-2. Form used by KDHE field investigator to detail salt water contamination.
50
-------
* , APPENDIX C
\
FORMS USED BY THE TEXAS RAILROAD COMMISSION IN THE ADMINISTRATION
OF THE TEXAS UIC PROGRAM.
urw5».(,0unS CEMEV
'O' DE:E»MINED Br MOit si« CAiINO «IC"
16 \ame Mtrte and >Ot" ot T0t).ng P*->
U Total Oeoth nl We"
18 injection
TOO
23 Date Weil >• «J
S Growrx] Suri*ce Elevation
e'»f«"s Gr>( interval a
30 i* injection Sritem
CD Open 0' CH C
31 li "section t»
Inject-on ftes^u'* (P%U
r
D,,, DNO
j 1
3S Njm* anO Address o* Surface O-«e'
*) Score* ot ftu,(ft iOc;ogo" and thai data and f^.is stated t^efei" are t'ue to"tci •
in
-------
INSTRUCTIONS (W-14)
1. Kilo (he original application. including all ailachmcnls. with (he Director of I'nflergrniiiid
Injection Control. Railroad Commission of Texas. I1. (). Drawer 12!lf>7. Capitol 'Siaiiun. Austin.
Texas 7871 I. Kile one- copy of I lie application and ils attachments with the appropriate DiMnei
Office.
2. Allach complele electrical log of this well or log of a neart>y well Attach any older logging and
testing data available for (he well such as ceinenl Ixnid logs.
.'t. Altai-h a U-ller from (he Te.xas Department ol Water Resources siiilini! liial the well will not
endanger (he usable quality water s(rala in I he area and t hat the If irmadon or stratum used lor
disposal does nut eotilam usable quality waier To obtain ibis letter, snhinil two copies ol Korm
W 14. a plal with surveys marked, and a re|)resem alive eleetrical log to I he Texas Depart men I of
Water Resources. I' O Hox IMOH7. Capitol Station. Austin. Texas 7H711.
•4 Attach a map showing the local ion and depth of all wells ol public record wit Inn one quarter I :l
mile radius ol the wrlibore wnh surveys marked Kor those wells which |>enelrale the topol the
-
lal Allach a plal of leases showing the location of the disposal well lease and ownership of
offsetting leases
Ibl 1 1 1 Send a copy of the application, including bolh sides of the form, to the surface owner, the
offset operators, and to the county and city clerk of the county and city in which (he well is
located. Attach a signed statemeni indicating the dale (he copies of the application were mailed
or delivered and the names and addresses of the persons to whom copies were sent.
12) Attach an affidavit of publication signed by the publisher that notice of the application
has been published in a newspaper of general circulation in the county where the wells will be
located. Notice instruct ions and forms may be obtained from the Commission's Austin Office or
the District Offices.
Id No public hearing will be held on this application unless an affected person or local
government requests a public hearing. Any such request fora public hearing shall be in writing
and contain: 111 Ihe name, mailing address, and phone number of ihe person making the
request: and 121 a brief description of how the protestant would be adversely affected by the
granting of the application. If the Commission determines thai a valid protest has been received.
or that a public hearing would be in the public interest, a hearing will be held after ihe issuance
of proper and timely notice of ihe hearing by the Commission. If no protest is received within
fifteen 1 151 days of publication or receipt in Austin of ihe application, (he application may he
processed administratively.
I
Figure C-1. (continued)
52
-------
Return To
DIRECTOR UndtrirouM Inaction Control
Oil infl Gas Division ^, \
Riilrotd Conmission ol Teus \
CapiM Sttton-PO r»l«r 12967 \
Austin. Teus 78711
RAILROAD COMMISSION OF TEXAS
OIL AND GAS DIVISION
Annual Disposal/Injection Well
Monitoring Report
Form H-10
4/83
4U-031
UIC CONIROl NO
PLEASE TYPE OR PRINT
1. OPERATOR'S NAME
READ INSTRUCTIONS ON REVERSE SIDE
~ T~¥RC~OPERAT6~R~NO~
3 ADDRESS
1 RRC DISTRICT NO
5 COUNTY
6 FIELD NAME
(Exactly as shown on proration schedule)
7 FIELD NO
8 API NO
9 LEASE NAME
I0a OIL LEASE NO lOb GAS 10 NO 11 WELL NO
MONTH
INJECTION PRESSURE
TOTAL VOLUME INJECTED
BBl
15 TUBING • CASING ANNULUS PRESSURE
(Oot'Onal Mo-.tonngi
MCF
16 I 1 "Reck here tl an alternative mechanical integrity monitoring procedure other than annulus monitoring is used ATTACH OETAIIS
TfrJeoth to Too ol Inaction Zone 18 Depth to Bottom ol Inaction Zone 19 Is Imection througn Tubing or Casing1 20 Depin ot Tubing Packer
Ft Ft D 1 Tubing D 2 Casing ft
21 Tyoe d Inieclion Fluid
[HI I S>H Walei LJ ? fresh Water
3 Brackisn Water I _ 1 4 Air I _ I 5 Gas I _ | 6 LPG I I 7 Other
I 1 1 Yej
22. Are me miected lluids produced from sources other than your own?
It ans«ei is yes. identity other sources by operalor. source, and type ol fluid. ATTACH A LIST.
1 No
23 Well Suius (insert code no I
D
SEE INSTRUCTIONS
CERTIFICATE
I declare under penalties prescribed in Sec. 91.143. Texas
Natural Resources Code, that I am authorized to make this
report, that this report was prepared by me or under my
supervision and direction, and that data and facts stated therein
are true, correct, and complete, to the best of my knowledge.
Signaluie
Name of Person (type or print)
Telephone .
Title
Area Code
Number
Date
RRC COPY
figure C-2. Annular disposal/injection well monitoring report.
53
-------
INSTRUCTIONS (H-10)
vv
'WHEN TO FILE-The Annual Monitoring Report Form (Form H-'l Oils computer-generated on the first
day of the last month of the reporting cycle for each disposal. Injection, or hydrocarbon storage well
and mailed to the operator. Form H-10 must be completed and returned to the Austin Office within 30
days after the last month of the reporting cycle (item 12). Reporting has been scheduled on a
staggered cycle, by RRC District, according to the following timetable.
DISTRICT REPORTING CYCLE
01.02 January through December
03 February through January
04 March through February
05. 06. 6E April through March
7B May through April
7C June through May
08 July through June
8A September through August
09 November through October
10 December through November
WHERE TO FILE - File the original form. Including any attachments with the Director of
Underground Injection Control. Railroad Commission of Texas. P. O. Drawer 12967. Capitol Station.
Austin. Texas 78711.
WHAT TO REPORT -
A. Correct any erroneous computer-printed information (Items 1 through 12) and supply any
missing Information. Including the API No. (Item 8). if an API number has been assigned.
B. Report data on the Injection pressure (Item 13) and the Injection volume (item 14) for the
specified reporting cycle. In addition, all monitoring records must be retained by the operator for
at least five years.
C. Report the minimum and maximum tubing-casing annulus pressure (Item 15). if this
monitoring option Is selected, and include the number of readings made each month.
D. If a monitoring or testing procedure other than monitoring the pressure of the tubing-casing
annulus is used or Is required, check Hem 16 and attach an explanation.
E. Report the current status of the well (Item 23) using one of the following codes:
1 - Authorized to Inject, but not yet drilled
2 - Drilled but not yet completed
3 - Active
4 - Temporarily abandoned
5 - Other (specify on front side. Item no. 23)
F. Return all Forms H-10 which are received on any well(s) which Is no longer being operated for
disposal. Injection, or underground hydrocarbon storage. Provide an attached explanation such
as a copy of Form W-2. G-l. W-3. P-4. etc.
G. Form H-10 must be completed and returned to the Austin Office within 30 days after the last day
of the reporting cycle on all wells operated for disposal. Injection, or underground hydrocarbon
storage purposes. If you do not receive Form H-10 on a well of this type that you operate, obtain
blank Form H-10 from the Railroad Commission District Office or the Austin Office (Supply
Section).
Figure C-2. (continued)
54
-------
RAILROAD COMMISSION OF TEXAS
Oil and Gas Division
Jt. 'l
Form W-2
Kcv 4 I Kl
483-0*6
... 42-
Oil Well Potential Test, Completion or Recompletion Report, and Lop;
I KIKI.lt NAMK. l.ix |H-r RKC Kft.irtN or Wildr.nl
•2 I.KANK NAMK
I (U'KKAriWSNAMK iKvu'ily .1* shint-n mi Korni I1 5. ()ri;.ini/ali
I Al i| WKSS
;i ()|H-r.iiMi h.iv < h.uiLlrd wiihin I.IM Hu diivs. i
j lmli.il !•..!.-1,11.,I | |
D
HI. ttliH k ,iiul Stirvrvl
tih Distance and direelinn lc> nrarcsl town tn this «mntv
(.AS II) or
Oil. l.KASK J
7)ii TJ I WKl I Ml 1
,-,. ,„ D
I-I ( Kinjilrtioii IT ni
SKCT1ONI: i'OTKNTLAI. TEST DATA IMPORTANT: Test should be for 24 hours unless otherwise specified in fit-Id rules.
:"' 1' .-1 irsl i ih Sn i>| hKlirs IrMtll ! 17 CriKllHtlfill It
, Sl/C * '1\1K' t
'.-• IT..II.I. :n>ti 'luriiiu Oil llhUS 1 ( i.i-. MCK
:,„ ,:•„.„ * !
.'.• I ,i>i III.IIMI-J4 III! MIII.S | I'.J- • Ml K
l'...ui K,h ,
J! ^.is ^u.th n^-i1. .lunmi Ihix t,-^i • i 1 i 1 M DilpriKl
S,s 1_J S,, [_| i
KKMAKhS
cihrKi lH•
Hiiwint* lulitiii; t'r»-—.urc
rs:
' l'.isnu!lT-wiri-
i1^:
2.1 ltl|n-lii.til..i> l«:
Klllo
INSTRUCTIONS Kilc;uioriaiiiaiandl I To report a
es u! tins form. "I'o report a retesi. till in only the front side
k
r
!
U'KI.I.
! •< 1,
Mllll
TKSTKK
is inir. i
diurr Wr
— - . " ' " ' — — i
S ( KHI'-KH Al'ION
ilTt-t I and ininplrlr In Ihr Ix-Nt nl nn kn- .vi It-lie*'
^
J TrMrr "^.inic i>l t nmp.inv KH( Krprrsrnt.isnr
OCKKATOK S CERTIHCATlON
IttiTljirf iindrrpfiKUlirsprrMnttrdniSiv HI l
i and (oniplrtr In (tic IK-M ol mv
l\ytf\ ur prlnirt! nainr ol oprraiors rrprrscnUllvr
;ilf mo day
Figure C-3. Oil well potential test, completion or recompletion report and log.
55
-------
DATA ON WELL COMPLETION AND LOG (Not Retired on Rltc-ill
Jt Ivpr nl I
2*i IVrniii rc> Drill
D| 1 I 1 I—I I 'Injl K*t k «
Drrprimti: | | Hut! I In k | | iHrirr | | , Hrrpril
> hritl llns irjl *.is nlitl i
Kuir 17
KM .•!•'
t'7 \Hlllli>'f i>l pr.nllM lilt: wlls nil It.I- li-.ist- i
ihis in-ld iffwr\Ml)inC , | Sjtnt Ij-as.
i»l--i..ln.ns , |
i.' ln\.iti..ii l»( KKM Ul (.K I U i !~TiW,i«. ilirrMiMit.il si irvrv m.ifir--chr t
.irirMl rhi
p-» i—,
| | W-, | I N.
1h-irniiiiiiil I
i; ,
, .Hrhl
(^ N u.-l] IM..|I.|,|.- i ..ni|.l • I'i II iiKillipli' K>iM|ilclii>n hxl .ill r<-s«-n.'.ii n.iiiirs it|.l.-t|..M*. MI •:;!•>. u.-ll ti,.1 • nl I. ,--
..i <..is ||> No r,AS •;. ,.r . ( > 1 ( ' V\ I I !
D,-
TASINC* RECORD IKrpon All Strings Srt in Wrlll
MI i IISIAC.I- • ivi-f a-..\MIII \: T
n iihCiiisKi •• ii..u-1/f
IIKil.liM'IM I K\H.M 's.,,1,-
1 1
Sl/i-
1 •
1
1
1 :\KK KK< OKI '
Mil' j (i..it,.,n j s,^ ks f .-iii.-ni : ^ ti-i-H
\ '
1" i
II HIM. I(K( OKI I
I Drplli Sri
Ik-pill
Id MAHKS ....
Figure C-3. (continued)
56
-------
• Type or print only
483-04;
RAILROAD COMMISSION OF TEXAS
Oil and Gas Division
Form G-1
Krv -I 1 KM
IAIIN,, 42-
"9as Wel1 Back Pressure Test.
Completion or Recompletion Report, and Log
HKI.I) NAMK Us (x-r KKC Kniircls or Wildcat)
'2 I.KASK NAMK
:i (H'KKA'IOUS NAMK IKxactly as shown on Form I' 5. OrHiini/.nn.n Krponi
•1 ADIWKSS
UM.UKIII IS*t linn. ttl(M k. and Survryl
II «i|HT.iinr has » Manned wirhin lasi Wt days.
IMIIW lnrtntT ojxramr
5b IXsldivc and ilirii'Mon In nrarrst Inwn In ihls
12 M wnrkmvr fir m lass. ei«- lormrr flrtd Iwtth rrsi-rxi.1 rI & (las H) or
(ill Ir.tv nn (iAS It) iir I Oil- O | WKI.I.
HK1.H fr KKSKHVOIK Oil. I.KASK " C.as- (1
iM|»lrtion ri.u
1 1 l'ni|...s«- ,.t llliiiL:
I ..... ,il I'ntrllll.il 1 _ 1
1 _ 1
1 _ 1
Well K-.i.id oulv 1 _ 1
IKxpl.tln in rrm.irksl
Krtr
Ki-«.l.i
"" ...... "'""""" DV--
GAS MEASUREMENT DATA
D.ilr nl 1
T",;,
• r2'
/ T
• |
> ' .
•VI
' li.ih.- S
r.;i
Ori
Mi-
Mi-.isurrmctii
*rrrn>%
'21 Mi t -.11
Orll «r I )i>4ii-
Mrlh.-i (( h.M k Oil
.:T.^PS°D .
XI p^ ,.r
< li'ikr IT'ss
•lislllM-l —
•h»kr L
l>til
»«
3()rlftrr Will
Mi-li-r
I1<-ti Ir-Olp
n ri:;^
,.,,„,
''?„''
DCrllliiil
1 'rover
t'"Fi"'
WD
Kv"
•..i-.prtKltMiI«liturtiii: II-M
M< 1
Volume
MCI- HAN
FIELD DATA AND PRESSURE CA1CULATIONS
CK llhl ('itn
Ki.i. | I mil- -I "f""( |,/.ki- ~j~W.-llli.-.Hl l-n-ss nw.-llhr.i.l ll..w F IV-'
-.. ! Ifm.M.., . Si/.- |l'u. |iS'A I -1.11.1. •>
. L .. _
Shul in Trinp
I'nlli.in llnlr ' t-inp
UW-pi
,7
^-:=r=
fi.
r : •• • ;-—^- •_ -_-- ----_-••, j---_
•' ; _;4"_".i"*z".".jziji."_'._'-"_i^i J i
VM I I IKSII.Ksl KKIIHI AIIHN Mi-i l.irrnnili-r |«-ii.illlrs|.r
tiiMiislKtl hv ih>- «.jif-iiil
-------
DATA ON WELL COMPLETION AND LOG (Not Required on Retest)
17 Fvpe
ol Completion
New Well*' I'v 1 Deepening |
., \ .,
J Mug Ilack I I
nl
Olhrr | I
IH Permit to DnM.
llufl liark or
Deepen
Rule 37
DATK. I'KRMIT No
i ASK N< i
2O Number til producing wells on this lea.v in
ihis field (reservoir) Including this well
Tola! mnnl>rr <>l dirrs
in ihls Ir^sr
72 Date t1u£ Itark. Deepening. ! Commenced ' Completed 23 DiMdnre to nearrsi well
WorkOvrr nr Drilling
Siitnr Ix-asc S* Krvr\pol
W.iier Intet tnni
Ivrmit
S.ill Water Dis(.*.
I'ennli
other
(in ol well, relative to nearest lease boundaries
•e- on which this well Is located
25 Elevation IDF. RKB. RT. GR, KTC 1
27 Top ol I'av
28 Toial IVpth ! 29 P B Depth
26. Was directional survey made other
lhan Inclination (Form W— 121?
30. Surface Casing 1 '
Determined by| Fle.ld I 1 I Rrcommen
1 Rules 1 Railroad C
D v~
tat inn \*
n v.
U Name »l
or (las ID No
DF1KLD fr RKSKKX'OIH
Nn
DnllinR Coniraclor
GAS ID or I Oil— O
Oil. I.KASK " [ ('.as- (.
1
j
1
.
WKI.I.
Drilled •
bv
;t5 Is ( r inniii
Atl.it hid '
n v,,
|,K,|S I.H.Ix
riL AtlKl.ivit
D v,
CASING RECORD (Report All Strings Set in Well)
CAS1V. SIZE
• »7 LINER RECORD
Siir TOI*
Bottom
S«rks Cf ment
Srrrrn
.w
IVHIM; RECORD
^i/e Depth Sri ' I*a( ker Sri
39 Producing 1
From
. From
iierval (this completionl Indlcair depth of pedordtion or open hole
To
T..
j From TI>
; From
To
ACiD SIK'T KRACTl'RE. CKMKNT SOUKE/.E. KTC
Drpth !nterv;iJ
Ainnuni dnd Kind ol MatrnaJ L'sr<1
4 i KOKMATION KKC'OHI) 'LIST IJKITHS i)K THINCICAI. tiKOUKlK'AI. MAKKKHS AN[) KOKMATION TOPSI
Fnrmanons | IVpih 1 Knrmarluns
! !
! :
ivpih
HKMAKKS
H
Figure C-4. (continued)
58
-------
RAILROAD COMMISSION OF TEXAS
OIL AND GAS DIVISION
Knnn H • 1
IKi-v 4 K2I
INJECT FLl'ID INTO A RESKRVOIR PKODU.TIVK OK Oil. UR GAS
2. RRC District
5. Leeae Neme(s) and RRC Lease Numberfs)
6, Reservoir Discovery Date
7. Hove ony injection permits been granted previously to ony operator in this reservoir? [^ Yes !~~! No
If answer to mis question is "NO", ALL OPERATORS IN THE RESERVOIR MUST BE NOTIFIED of mis application, end copies of
notification attached hereto.
Check the Appropriate Block(s):
I | New Project or f I Expo
lion of Previous Authority to Add Either: ; New Lesse(s) 01
Authority Dated **y [ " ^ Administrative Actio
~1 Additional Well(s) on Same Lease(s)
RESERVOIR AND FLUID DATA ON ENTIRE RESERVOIR
9 Name ol Reservoir
) 10. EstimeTedI Productive Area e( Entire Re
11 Composition (land, llmeatone. dolomite, etc.)
12- Type of Structure (Include cross-section and • true rural map!.}
13. Subaea Depth of Oil-Water Contact (ft.)
14. Subiea Depth of Gas-Oil Contact (ft.)
15- Original Bottom Hole Pressure (psig)
16. Current Bottom Hole Pressure (psig)
21. Formation Volume Factor
Original: .
'•22. Type Drive During Primary ProducUo
RESERVOIR AND FLUID DATA
23 Number of Productlv*
within project Area
Average Effective Pay Thieknv** (ft )
26- Averac* Horizontal Permeability frrtd* )
. 2? Range of Horu
39. Average Porosity (".t
30 Gravity of Oi! ,de* API,
PRODUCTK3N HISTORY OF RESERVOIR
J3 Stage of primary Depletion of Project Area
SUBMIT ATTACHF.D SHE E T'Sl GIVrNC THE OIL GAS i *'ATER
PRODUCTION BY YEARS SINCE PI^C OVE RY & TOTA L5 FOR
THE LAST t YEARS GIVE THESE FIGURES BY MONTHS
40. Type of Injection Project (Check the appropriate block(s):)
(~~j g«terflood, [^Misclble Displacement. [^Thermal Rec
TYPE OF INJECTION PROJECT AND RESULTS EXPECTED
lure Meintenam e.
41- Current Estimated Oil Saturation (% of pore space)
43- Estimated Original Oll-In-PUce fbble.)
Result of Injection (bbli )
Q
INJECTION DATA
45. Type of Injection Fluid (Check the appropriate block(i):)
Qj S«It Water, (^j Brack)ah Water. [^1 Fresh Water. £^} Gaa. [^ Air.
(specify)
46. Source of Injected Fluid(e) (formatloti(s) and depthfi) in ft.)
48. Total Number of Injection Wells to be Approved in thia Applicatio
50 Total Estimated Maximum Dally Rate of Injection for All WelU In this
Application, (bbls./day)
47. Injection Pattern and Spacing
49. Eatimated Maximum Daily Rate of Injection per ft*
ximum Injection Pressure to be Used (psig)
52. UST COMPLETE INJECTION WELL DATA ON FORM H-IA AND ATTACH.
( APPLICANT MUST COMPLY WITH THE INSTRUCTIONS AND SIGN CERTIFICATION ON REVERSE SIDE
Figure C-5. Application to inject fluid into a reservoir productive of oil or gas.
59
-------
INSTRUCTIONS (H-l)
•i V
I. File (he orlglhalVappllcallon. Including all attachments, ulth the Director of Underground Injection
Control. Railroad'Commission of Texas. P. O. Drawer 12967. Capitol Station. Auslln. Texas 7H7I I. Kile
one copy of the application and Its attachments with the appropriate District Office.
2. Attach complete electrical log or similar well log of one of the proposed Injection wells. Attach any other
logging and testing data available for the well such as cement bond logs.
3. (a) For a new project, attach a map with surveys marked showing the location and depth of all wells of
public record within a one quarter C/il mile radius of the project area.
(b) For an expansion of a previous authority, attach a map with surveys marked showing the location and
depth of all wells of public record within one-quarter ('.) mile radius of the additional wells, unless such
data previously has been submitted for (he project.
(c) For those wells In 3(a) or 3(b) that penetrate the top of the Injection Interval, attach a table of wells
showing the dales drilled and their present status. Identify any abandoned well which available data
Indicate Is unplugged or Improperly plugged. The Director of Underground Injection Control may adjust or
waive (his daia requirement In accordance with provision of the "Area of Review" section of Statewide
Rule 46.
4. Attach a leller from the Texas Department of Water Resources for a well within the project area stating the
depth to which usable quality ground water occurs.
5. Attach Form H- 1A showing each Injection well to be used in the project. Up to three wells can be listed on
each H-1A Form.
6. Attach Form H-7. Fresh Water Data Form, for a new Injection project that Includes the use of fresh water.
An updated H-7 must be attached to Form H-l for an expansion of a previously authorized fresh water
Injection project unless the fresh water is purchased from a commercial supplier, public entity, or from
another operator.
7. (a) Attach a plat of lease(s) showing producing wells. Injection wells, offset wells, and Identifying ownership
of all surrounding leases.
(b)( 1 ISend a copy of the application to the surface owner, the offset operators, and to the county and city
clerk of the county and city In which the well Is located. If this Is the Initial application for fluid Injection
authority for this reservoir, send copies of the application to all operators In the reservoir. Attach a signed
statement Indicating the date the copies of the application were mailed or delivered and the names and
addresses of the persons to whom copies were sent.
(2) Attach an affidavit of publication signed by the publisher that notice of the application has been
published In a newspaper of general circulation In the county where the wells will be located. Notice
Instructions and forms may be obtained from the Commission's Austin Office or the District Offices.
(c) No public hearing will be held on this application unless an affected person or local government
requests a public hearing. Any such request for a public hearing shall be In writing and contain: (1) the
name, mailing address, and phone number of the person making the request: and (2) a brief description of
how the protestant would be adversely affected by the granting of the application. If the Commission
determines that a valid protest has been received, or that a public hearing would be In the public Interest.
a hearing will be held after the issuance of proper and timely notice of the hearing by the Commission. If
no protest Is received within fifteen (15) days of publication or receipt In Austin of the application, the
application may be processed administratively.
CERTIFICATE
Signature
I declire under pennies prescribed in Sec 9] 143. Tent Nilunl Resources
Colt. Itiil I im lutnonnd lo mme Inn report. Ihll Irlis repon wls preplred Dy me
or under my supervision jnd direction. ind tnit diU ind Ucts stated therein are Name of Person (type or print) Title
true, correct, ind complete, to tne best ol my kmmfedie
Telephone Date
Art. Code Numfxr
I
Figure C-5. (continued)
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RAILROAD COMMISSION OF TEXAS
OIL AND GAS DIVISION
l ['ISiNG »ND 'I'BJNG
~1,.S |V!V I '•"• 'II CIVIM i ','P Pf •t«MNtn R-'HOl 1 -.'I
D D
D D
?6 is ihi: *e'i
n Jtlf jbO»f vfl Oul iftPCt'Cf .'one'
!~~| ^
WEtl CASING AND 1U6ING
] SEHINC
SACK? CEMfN' TOP or CEMCftl
TOP OflEOMlNin B>
19 PfF'o'J!'0" v 0:*"
?? Name c1 Re«f.o-'
?3 "itect-on StSiem OP*« o
D D
*(H CASING «NO l
P.' HOlE Sl/E
_L
;-: Nj^* Moo*- and Depth ct Tub-ng Pjc
18 Ground Surface Edition )9 Pfrforjt>on w OP--> Ho'*>
?3 Inieti.on S*\lem Open or
:-••:.-: :..-••..„.*.
76 Is itus w'l MJ ri\rd and completed thai *alrr < an pnu* no nlrVf
lormadon Ina" the abovr srt oui injection /ooe' P~J |pi^ f"!
Figure C-6. Injection well data form.
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RAILROAD COMMISSION OF TEXAS
OIL AND GAS DIVISION
Form H - 7
(Ed. 1/1/68)
FRESH WATER DATA FORM
1. RRC District
2. Field Name (ae per current pro ration schedule)
J, County
4. Reservoir (Into which fresh water is to be injected)
5. Operator
6. Lease Name(a) and RRC No(*). (on which fresh water Is to be injected)
7, Name of Fresh Water Formation or Source
9. Gro** Thlckne** of Freeh Water Formation (Feet)
8. Depth to Top of Fre»h Water Formation (P«et)
10. Net Thickne** of Freah Wat*r Formation (Pact)
11. Total Number of Acre* In Project Area where Applicant hat Exclusive Uae of Freah Water Right a for Subject Project. Include Land
Description. (Also fumiah plat. See "Required Attachment*" on back.)
12.
14.
Volume of Recoverable Fresh Water-In- PI ace beneath Applicant'*
Water Right* Acreage (Barrel*)
Total Volume of Freah Water to be U*ed in Injection Project
(Barrel*)
13. Rat* of Recharge of Freeh Water Formation beneath Subject Water
Right* Acreage (Barrels/Day)
15. Fre*h Water Withdrawal Rate* for Project (Barrels/Day)
17. Name* of and Distance* to Municipal Water Supplier Utilising Same Freeb Water Formation or Source (within 20 mile radlu*)
1 CITY/TOWN DISTANCE AND DIRECTION
18. Name of Shallowest Salt Water or
BrackUh Water Supply Zone
19. Depth of Shallowest Salt Water or
Bracki*h*Water Supply Zoo* (Feet)
20. Rate of Salt Water or Brackl*h Water Available
from Ail Source* for Project (Barrel*/Day)
(OVER)
Figure C-7. Fresh water data form.
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21. Reason for U*0 of Prach Water
(Explain neceaclty of using fr««h watar rathar than aalt watar.l
REQUIRED ATTACHMENTS:
1. WATER QUALITY ANALYSIS REPORT ON FRESH WATER FORMATION.
2. PLAT(S) SHOWING FRESH WATER RIGHTS ACREAGE (AS PER ITEM II) AND LOCATION
AND DENSITY OF FRESH WATER SUPPLY WELLS.
I declare under penalties prescribed in Article 6036c, R.C.S., that I am authorized to make this report, that
thia report was prepared by me or under my supervision and direction, and that data and facts stated therein
are true, correct, and complete, to the best of my knowledge.
SIGNATURE
OPERATOR NAME OF PERSON (TYPE OR PRINT)
ADDRESS
Fiijure C-7. (continued)
TELEPHONE: AREA CODE.
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« APPENDIX D
\
FORM USED BY THE UIC STAFF TO RECORD COMPLAINTS ABOUT
SALT WATER INJECTION OR DISPOSAL WELLS.
COMPLAINT
COMPLAINTANT:
ADDRESS: __ TELEPHONE:
DATE RECEIVED: HOW RECEIVED:
COMPLAINT AGAINST:
OPERATOR:
LEASE:
FIELD:
COUNTY:
NATURE OF COMPLAINT:
DATE OF INSPECTION: INSPECTOR:
COMMISSION ACTION:
DATE COMPLAINTANT APPRISED OF COMMISSION ACTION:
DATE COMPLAINT RESOLVED:
i
I
I
1 DATE AUSTIN NOTIFIED:
Figure D-1. Administrative form used by the UIC program to record complaints.
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APPENDIX E
TOAS STATEWIDE RULE 8 - WATER PROTECTION
\
(a) Fresh Water to be Protected
Fresh water, whether above or below the surface, shall be protected
from pollution whether in drilling, plugging, producing, or disposing of salt
water already produced.
(b) Exploratory Wells
Any oil, gas or geothermal resource well or well drilled for exploratory
purposes shall be governed by the provisions of statewide or field rules which
are applicable and pertain to the drilling, safety, casing, production, abandoning
and plugging wells, and all operations in connection therewith shall be carried
on so that no pollution of any stream or water cours"e of this State, or any
subsurface waters, will occur as the result of the escape or release or injection
of oil, gas, salt water, geothermal resource or other mineralized waters for
any well.
(Reference Order No. 20-56, 841, effection 1-1-69).
(c) (1) All operators conducting oil, gas, or geothermal resources
development and production operations are prohibited from using salt water
disposal pits for storage and evaporation of oil field brines, geothermal
resource waters or other mineralized waters.
(A) The provisions of this rule do not affect the use of burning
pits which are used exclusively for the burning of tank bottom waste accumulation.
(B) Impervious collecting pits may be approved for use in conjunction
with approved salt water disposal operations, provided that authority must be
received for use of such pits from the director of the oil and gas division or
his delegate. If the director of the oil and gas division declines administratively
to grant, to continue, or to extend the authority to use a pit, the operator
shall make a recommendation for final action by the Commission.
(C) Discharge of oil field brines, geothermal resource waters or
other mineralized waters into a surface drainage water course, whether it be a
dry creek, a flowing creek or a river, except where permitted by the Commission,
is not an acceptable disposal operation and is prohibited.
' (D) Disposition of oil field brines, geothermal resource waters or
other mjineralized waters through off-lease facilities where transportation is
by tank trucks, pipelines or other means, is the initial responsibility of the
lease operator and shall not be initiated until such method of disposition is
permitted by the Railroad Commission. Such permit shall be subject to review
and cancellation should investigation show that the permit method of disposition
is abused.
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(2) Exceptions to the provisions of this rule may be granted by the
Railroad Commission on special request where good and sufficient cause is shown.
(3) Penalty for non-compliance with any part of this rule shall be
pipeline severance f4pr each lease operated in violation of this rule.
\
(4) In any instance where a salt water disposal pit is presently in use
and is abandoned, due to cessation of flow of salt water thereto, whether
voluntary or mandatory, such pit shall be backfilled and compacted.
(d) Pollution Prevention
(Reference Order No. 20-59, 200, effective 5-1-69)
(1) The operator shall not pollute the waters of the Texas offshore
and adjacent estuarine zones (salt water bearing bays, inlets, and estuaries)
or damage the aquatic life therein.
(2) All oil, gas, and geothermal resource well drilling and producing
operations shall be conducted in such a manner as to preclude the pollution of
the waters of the Texas offshore and adjacent estuarine zones. Particularly,
the following procedures shall be utilized to prevent pollution.
(A) The disposal of liquid waste material into the Texas offshore
and adjacent estuarine zones shall be limited to salt water and other materials
which have been treated, when necessary, for the removal of constituents which
may be harmful to aquatic life or injurious to life of property.
(B) No oil or other hydrocarbons in any form or combination
with other materials or constituent shall be disposed of into the Texas offshore
and adjacent estuarine zones.
(C) All deck areas on drilling platforms, barges, workover unit
and associated equipment both floating and stationary subject to contamination
shall be either curbed and connected by drain to a collection tank, sump or
enclosed drilling slot in which might reasonably be considered a source from
which pollutants may escape into surrounding water. These drip pans must be
piped to collecting tanks, sumps or enclosed drilling slots designed to
accommodate all reasonably expected drainage. Satisfactory means must be
provided to empty the sumps or enclosed drilling slots to prevent overflow or •
prevent pollution of the surrounding water.
(D) Solid combustible waste may be burned and the ashes may be
disposed of into Texas offshore and adjacent estuarine zones.
Solid wastes such as cans, bottles, or any form of trash
must be transported to shore in appropriate containers. Edible garbage, which
may be- consumed by aquatic life without harm, may be disposed of into Texas
offshore and adjacent estuarine zones.
i
(E) Drilling muds which contain oil shall be transported to
shore or a designated area for disposal. Only oil-free cuttings and fluids
from mud systems may be disposed of into Texas offshore and adjacent estuarine
zones at or near the surface.
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(F) Fluids produced from offshore wells shall be mechanically
contained in adequately pressure-controlled piping or vessels from producing to
disposition point. Oil and water separation facilities at offshore and onshore
locations shall contain safeguards to prevent emission of pollutants to the
Texas offshore and adjacent estuarine zones prior to proper treatment.
(G) All deck areas on producing platforms subject to contamination
shall be either curbed and connected by drain to a collecting tank or sump in
which the contamiment will be treated and disposed of without causing hazard or
pollution, or else drip pans, or their equivalent, shall be placed under any
equipment which might reasonably be considered a source from which pollutants
may escape into surrounding water. These drip pans must be piped to collecting
tanks or sumps designed to accommodate all reasonably expected drainage.
Statisfactory means must be provided to empty the sumps to prevent overflow.
(H) Any person observing water pollution shall report such
sighting, noting size, material, location and current conditions to the ranking
operation personnel. Immediate action or notification shall be made to eliminate
further pollution. The operator shall then transmit the report to the appropriate
commission district office.
(I) Immediate corrective action shall be taken in cases where
pollution has occurred. An operator responsible for the pollution, shall remove
immediately such oil, oil field waste, or other pollution materials from the
waters and the shore line where it is found. Such removal operations will be
at the expense of the responsible operator.
(3) The Commission may suspend producing and/or drilling operations
from any facility when it appears that the provisions of this rule are being
violated.
(4) (Reference Order No. 20-61, 214, effective 10-1-70)
The foregoing provisions of Rule 8(d) shall also be required and
enforced as to all oil, gas or geothermal resource operations conducted on the
inland and fresh waters of the State of Texas, such as lakes, rivers, and streams.
(e) Salt Water Haulers
1 (1) A person who transports salt water for hire by any method other
than by pipeline shall not haul and dispose of water containing salt or other
mineralized substances produced by oil and gas operations, off a lease, unit,
or other oil or gas property where it is produced unless such transporter has
qualified for and been issued a Salt Water Hauler Permit by the commission.
(A) Application for a Salt Water Hauler's Permit will be made
on thelcommission prescribed form, and in accordance with the instructions
thereoiji, and must be accompanied by:
1 (1) Salt Water Haulers Permit bond on the commission
prescribed form
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(2) Vehicle Identification information to support
commission issuance of a Vehicle Identification card
(3) A statement of Haulers Authority to use a
commission approved disposal system
4l \ (4) Submit each truck for inspection by
commission district personnel
(B) A Salt Water Hauler's Permit when issued will expire
August 31 of each year, but it is subject to renewal by the filing of a Renewal
Certificate, and a copy of a Salt Water Hauler's Permit Bond for the next permit
period,
(C) Each Salt Water Hauler shall conduct operations in
strict compliance with the Instructions and Conditions stated on the permit
issued which provide:
(i) This permit, unless suspended or revoked for
cause shown, shall remain valid until August 31 of the permit year (Permit
period September 1 to August 31 set by Law).
(ii) Each vehicle used by a permittee shall be marked
on both sides and the rear with the permittee's name and permit number in
characters not less than three inches high. (For the purposes of this permit
"vehicle" means any truck tank, trailer tank, tank car, or other container in
which salt water will be hauled by the permittee.)
(iii) A Vehicle Identification Card must be obtained
from the district office and carried at all times with the vehicle described
thereon. This card will contain the permittee's name, permit number, vehicle
description, vehicle number, permit authority, and a list of all approved
disposal systems that the permittee is authorized to use.
(iv) This permit is issued pursuant to the information
furnished on the application form, and any change in conditions must be reported
to the commission on an amended application form. The permit authority will be
revised by the amended application.
/
(v) This permit authority is limited to the hauling,
handling, and disposal of salt water that is produced in connection with the.
drilling or producing operations of an oil or gas well.
(vi) This permit authorizes the permittee to use
only those approved disposal systems for which he has submitted affidavits from
the operators stating he has permission to use the systems. A list of the
systems that the permittee is to use will be placed on the back of the Vehicle
Identification Card.
renewal
each year
1 (vii) The permittee must file an application for a
ipermit, using his assigned permit number, on or before August 31 of
ir.
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(viii) The permittee must compile and keep current a list
of all persons by whom he is hired to haul produced salt water, and furnish
such list to the commission upon request.
(2) A record shall be kept by each Salt Water Hauler showing daily
salt water hauling operations under the permitted authority.
\
(A) Such daily records shall be dated and signed by the vehicle
driver and it shall show the following information:
(i) Identity of the property from which the
the produced water is hauled.
(ii) Identity of the commission approved disposal system
to which the water is delivered.
(iii) The volume of water received at the
property where produced.
(iv) The volume of water transported and delivered to the
approved disposal system.
(3) Such record shall be kept open for the inspection of the
commission or its representatives.
(C) Such records shall be kept on file for a period of two (2)
years from the date of operations and recordation.
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APPENDIX F
""TEXAS STATEWIDE RULE 9 - DISPOSAL WELLS
Any person who disposes of salt water or other oil and gas waste by
injection into a porous formation not productive of oil, gas, or geothermal
resources shall be responsible for complying with this rule, Chapter 27 of the
Texas Water Code, and Title 3 of the Natural Resources Code.
(a) General. Salt water or other oil and gas waste, as that term is
defined in Chapter 27 of the Texas Water Code, may be disposed of, upon
application to and approval by the commission, by injection into nonproducing
zones of oil, gas, or geothermal resources bearing formations that contain
water mineralized by processes of nature to such a degree that the water is
unfit for domestic, stock, irrigation, or other general uses. Every applicant
who proposes to dispose of salt water or other oil a-nd gas waste into a formation
not productive of oil, gas, or geothermal resources, must obtain a permit from
a commission authorizing the disposal in accordance with this rule. Permits
from the commission issued before the effective date of this rule shall continue
in affect until revoked, modified, or suspended by the commission.
(b) Geological requirements. Before such formations are approved for
disposal use the applicant shall show that the formations are separated from
fresh water formations by impervious beds which give adequate protection to
such fresh water formations. The applicant must submit a letter from the Texas
Department of Water Resources, Austin, Texas, stating that the use of such
formation will not endanger the fresh water strata in that area and that the
formations to be used for disposal are not fresh water bearing.
(c) Application. The application to dispose of salt water or other oil
and gas waste by injection into a porous formation not productive of oil, gas,
or geothermal sources shall be filed with the commission in Austin. On the
same date, one copy shall be filed with the appropriate district office.
(d) Notice and opportunity for hearing.
i
(1) The applicant shall give notice by mailing or delivering a copy
of the application to the surface owner of the tract on which the well is
located, to each adjoining offset operator, to the county clerk of the county
in which the well is located, and to the city clerk or other appropriate city
official of any city where the well is located within the municipal boundaries
of the city, on or before the date the application is mailed to or filed with
the comjmission.
• (2) In order to give notice to other local governments, interested,
or affected persons, notice of the application shall be published once by the
applicant in a newspaper of general circulation for the county where the well
will be located in a form approved by the director of underground injection
control (hereinafter "director"). The applicant shall file with the commission
in Austin proof of publication prior to the hearing or administrative approval.
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(3) Protested applications.
(A) If a protest from an affected person or local government is made
to the commission within 15 days of receipt of the application or of publication,
or if the director determines that a hearing is in the public interest, then a
hearing will be held^-on the application after the commission provides notice of
hearing to all affecteo\persons, local governments, or other persons, who
express an interest in writing in the application.
(B) For purposes of this rule, "affected person" means a person who
has suffered or will suffer actual injury or economic damage other than as a
member of the general public and includes surface owners of property on which
the well is located and adjoining offset operators.
.(4) If no protest from an affected person is received by the
commission, the director may administratively approve the application. If the
director denies administrative approval, the applicant shall have a right to a
hearing upon request. After hearingj the examiner shall recommend a final
action by the commission.
(e) Subsequent commission action.
(1) A permit for salt water or other oil and gas waste disposal may
be modified, suspended, or terminated by the commission for just cause after
notice and opportunity for hearing if:
(A) a material change of conditions occurs in the operation or
completion of the disposal well, or there are material changes in the information
originally furnished;
(B) fresh water is likely to be polluted as a result of continued
operation of the well;
(C) there are substantial violations of the terms and provisions of
the permit or of commission rules;
(D) the applicant has misrepresented any material facts during the
permit issuance process; or
(E) injected fluids are escaping from the permitted disposal zone?
i
(2) A disposal well permit may be transferred from one operator to
another operator provided that:
(A) Written notice of the intended permit ransfer is submitted to
the director at least 15 days prior to the date the transfer is to take place; and
' (B) the director does not notify the present permit holder of an
objection to the transfer prior to the transfer date stated in the above notification,
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(f) Area of review. The applicant shall review the data of public record
for wells that penetrate the proposed disposal zone within a one-quarter (1/4)
mile radius of the proposed disposal well to determine if all abandoned wells
have been plugged in a manner that will prevent the movement of fluids from the
disposal zone into fresh water strata. Alternatively, if the applicant can
show by computation tfjiat a lesser area will be affected by pressure increases,
then the lesser area maty be used in lieu of the one-quarter (1/4) mile radius
area of review. The applicant shall identify in the application any wells
which appear from such review of public records to be unplugged or improperly
plugged and any other unplugged or improperly plugged wells of which the
applicant has actual knowledge.
(g) Casing. Disposal wells shall be cased and the casing cemented in
compliance with §3.13 (051.02.02.013) in such a manner that the injected fluids
will not endanger oil, gas, geothermal resources or fresh water resources.
(h) Special equipment.
(1) Tubing and Packer. New wells drilled or converted for disposal
after the effective date of this, rule shall be equipped with tubing set on a
mechanical packer. Packers shall be set no higher than 100 feet above the top
of the permitted interval. Existing disposal wells shall be so equipped at the
time of the first workover but no later than January 1, 1984.
(2) Pressure valve. The well head shall be equipped with a pressure
observation valve on the tubing and for each annulus of the well. Operators of
existing disposal wells shall comply with this requirement by no later than
January 1, 1983.
(3) Exceptions. The director may grant an exception to any provision
of this paragraph upon proof of good cause. If the director denies an exception,
the operator shall have a right to a hearing upon request. After hearing, the
examiner shall recommend a final action by the commission.
(4) The operator shall report the appropriate district office within
24 hours any significant pressure changes or other monitoring data indicating
the presence of leaks in the well. The operator shall confirm this report in
writing within five working days.
(k) Testing.
(1) Before beginning disposal operations, the operator shall pressure
test the long string casing. The test pressure must equal the maximum authorized
injection pressure or 500 psig, whichever is less, but must be at least 200 psig.
(2) Each disposal well shall be pressure-tested in the manner provided
in paragraph (k) (1) at least once every five years to determine if there are
leaks in' the casing, tubing, or packer. The director may prescribe a schedule
and mail notification to operators to allow for orderly and timely compliance
with this requirement.
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(3) As an alternative to the testing required in paragraph (k) (2),
the tubing-casing annulus pressure may be monitored and included on the annual
monitoring report required by paragraph (j) provided that there is no indication
of problems with the well. The director may grant exception for viable
alternative tests or surveys such as monitoring of injecton rate/injection
pressure relationships.
>ik
(4) The operator shall notify the appropriate district office at
least 48 hours prior to the testing. Testing shall not commence before the end
of the 48-hour period unless authorized by the district office.
(5) A complete record of all tests shall be filed in duplicate in the
district office on the appropriate form within 30 days after the testing.
(1) Plugging. Disposal wells shall be plugged upon abandonment in
accordance with Statewide Rule 14.
(m) Penalties.
(1) Violations of this rule may subject the operator to penalties
and remedies specified in Chapter 27 of the Texas Water Code and Title 3 of
Natural Resources Code.
(2) The certificate of compliance for any oil, gas, or geothermal
resource well may be revoked in the manner provided in §3.68 (051.02.02.073)
for violation of this rule.
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APPENDIX G
TEXAS STATEWID,E,,RULE 46 - FLUID INJECTION INTO PRODUCTIVE RESERVOIRS
(a) Permit Required. Any person who engages in fluid injection operations
in reservoirs productive of oil, gas, or geothermal resources must obtain a
permit from the commission. Permits may be issued when the injection will not
endanger oil, gas, or geothermal resources or cause the pollution of fresh
water strata unproductive of oil, gas, or geothermal resources. Permits from
the commission issued before the effective date of this rule shall continue in
effect until revoked, modified, or suspended by the commission.
(b) Filing of application. An application to conduct fluid injection
operations in a reservoir productive of oil, gas, or geothermal resources shall
be filed in Austin on the form prescribed by the commission. On the same date,
one copy shall be filed with the appropriate district office. The form shall
be executed by a party having knowledge of the facts- entered on the form. The
applicant shall file the fresh water injection data form if fresh water is to
be injected.
(c) Notice and opportunity for hearing.
(1) The applicant shall give notice by mailing or delivering a copy
of the application to the surface owner of the tract on which the well is
located, to each adjoining offset operator, to the county clerk of the county
in which the well is located, and to the city clerk or other appropriate city
official of any city where the well is located within the corporate limits of
the city on or before the date the application is mailed to or filed with the
commission.
(2) In order to give notice to other local governments, interested,
or affected persons, notice of the application shall be published once by the
applicant in a newspaper of general circulation for the county where the well
will be located in a form approved by the director of Underground Injection
Control (hereinafter "director"). The applicant shall file with the commission
in Austin proof of publication prior to the hearing or administrative approval.
i
(3) Protested applications.
(A) If a protest from an affected person or local government is
made to the commission within 15 days of receipt of the application or of
publication, or if the director determines that a hearing is in the public
interest, then a hearing will be held on the application after the commission
provides notice of hearing to all affected persons, local governments, or other
persons,, who express an interest in writing in the application.
1 (B) For purposes of this rule, "affected person" means a person
who has suffered or will suffer actual injury or economic damage other than as
a member of the general public and includes surface owners of property on which
the well is located and adjoining offset operators.
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(4) If no protest from an affected person is received by the
commission, the'director may administratively approve .the application. If the
director denies administrative approval, the applicant shall have a right to a
hearing upon request. After hearing, the examiner shall recommend a final
action by the commission.
(d) SubsequentVomniission action.
(1) An injection well permit may be modified, suspended, or terminated
by the commission for just cause after notice and opportunity for hearing, if:
(A) A material change of conditions occurs in the operation or
completion of the injection well, or there are material changes in the information
originally furnished;
(B) Fresh water is likely to be polluted as a result of continued
operation of the well ;
(C) There are substantial violations of the terms and provisions
of the permit or of commission rules;
(D) The applicant has misrepresented any material facts during
the permit issuance process; or
(E) Injected fluids are escaping from the permitted
injection zone.
(2) An injection well permit may be transferred from one operator to
another operator provided that:
(A) Written notice of the intended permit transfer is submitted
to the director at least 15 days prior to the date the transfer is to take
place; and
(B) The director does not notify the present permit holder of
an objection to the transfer prior to the transfer date stated in the above
notification.
(e) Area of review. The applicant shall review the data of public record
for wells that penetrate the proposed injection zone within a one-quarter (1/4)
mile rqdius of the proposed injection well to determine if all abandoned wells
have been plugged in a manner that will prevent the movement of fluids from the
injection zone into fresh water strata. Alternatively, if the applicant can
show by computation that a lesser area will be affected by pressure increases,
then the lesser area may be used in lieu of the one-quarter (1/4) mile radius
area of review. The applicant shall identify in the application wells which
appear from such review of public records to be unplugged or improperly plugged
and any; other unplugged or improperly plugged wells of which the applicant has
actual knowledge.
(ft) Casing. Injection wells shall be cased and the casing cemented in
compliance with Statewide Rule 13 in such a manner that the injected fluids
will not endanger oil, gas, or geothermal resources and will not endanger fresh
water formations not productive of oil, gas, or geothermal resources.
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(.g) Special equipment.
(1) Tubing and packer. New wells drilled or converted for injection
after the effective date of this rule shall be equipped with tubing set on a
mechanical packer. Packers shall be set no higher than 200 feet below the
known top of cement behind the long string casing but in no case higher than
150 feet below the base of usable quality water.
(2) Pressure valve. The wellhead shall be equipped with a pressure
observation valve on the tubing and for each annulus of the well. Operators of
existing injection wells shall comply with this requirement by no later than
January 1, 1983.
(3) Exceptions. The director may grant an exception to any provision
of this paragraph upon proof of good cause. If the director denies an exception,
the operator shall have a right to a hearing upon request. After hearing, the
examiner shall recommend a final action by the commission.
(h) Hell record. Within 30 days after the completion or conversion of an
injection well, the operator shall file in duplicate^in the district office a
complete record of the well on the appropriate form which shows the current
completion.
(i) Monitoring and reporting.
(1) The operator shall monitor the injection pressure and injection
rate of each injection well on at least a monthly basis.
(2) The results of the monitoring shall be reported annually to the
commission on the prescribed form.
(3) All monitoring records shall be retained by the operator for at
least five years.
(4) The operator shall report to the appropriate district office
within 24 hours any significant pressure changes or other monitoring data
indicating the presence of leaks in the well. The operator shall confirm this
report in writing within five working days.
(j) Testing.
i
(1) Before beginning injection operations, the operator shall pressure
test the long string casing. The test pressure must equal the maximum authorized
injection pressure or 500 psig, whichever is less, but must be at least 200
psig.
, (2) Each injection well shall be pressure-tested in the manner
provide'd in paragraph (j) (1) at least once every five years to determine if
there are leaks in the casing, tubing, or packer. The director may prescribe a
schedule and mail notification to operators to allow for orderly and timely
compliance with this requirement.
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(3) As an alternative to the testing required in paragrph (j) (2).,
the tubing-casing annulus pressure may be monitored and included on the annual
monitoring report required by subsection (i) provided that there is no indication
of problems with the well.. The director may grant an exception for viable
alternative tests or surveys such as monitoring of injection rate/injection
pressure relationships.
V
(4) The operator shall notify the appropriate district office at
least 48 hours prior to the testing. Testing shall not commence before the end
of the 48-hour period unless authorized by the district office.
(5) A complete record of all tests shall be filed in duplicate in
the district office within 30 days after the testing.
(k) PIugging. Injection wells shall be plugged upon abandonment in
accordance with Statewide Rule 14.
(1) Penalties.
(A) Violations of this rule may subject the operator to penalties
and remedies specified in Title 3 of the Natural Resources Code and' any other
statutes administered by the commission.
(B) The certificate of compliance for any oil, gas, or geothermal
resource well may be revoked in the manner provided in §3.68 (051.02.02.073)
for violation of this rule.
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