Railroad Commission of Texas
Injection Well Permitting
Oil and Gas Regulatory Conference
September 24-25, 2013 - Austin, Texas
Rick Behal
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Injection Well Permitting
Introduction
• Filing a complete and correct application initially is the
most effective way to expedite an application.
• Injection/Disposal Well Permit Testing and Monitoring
Seminar Manual
http://www.rrc.state.tx.us/forms/publications/HTML/index.
php
• Filing Requirements: Forms and attachments
• Technical Review: What are we looking for?
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“Crossing the Pecos River”
•
•
•
RRC – ESTABLISHED 1891 TO REGULATE RAILROADS, ACQUIRED JURISDITION OVER
OIL & GAS IN 1917 TO PREVENT MONOPOLIES, UNFAIR PRICING, PIPELINE
DISCRIMINATION
POWERS EXPANDED IN 1919 TO REGULATE PRODUCTION TO PREVENT WASTE
NOW HAS AUTHORITY OVER O&G, PIPELINES, GAS UTILITIES, & SURFACE MINING,
NO LONGER HAS ANY AUTHORITY OVER RAILROADS
Injection Well Permitting
• There are over 409,000 oil and gas industry wells
in Texas
• First injection well in Texas permitted in 1936
• There have been about 107,000 wells permitted
for injection
• Over 55,000 have current permits, approximately
33,000 are active
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Injection Well Permitting
Objectives
• Protect surface and groundwater, public health
and safety
• Prevent waste and promote conservation
• Protect correlative rights to develop mineral
resources
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Injection Well Permitting
Statutory Authority
(Oil and Gas Division)
• Safe Water Drinking Act (1974):
- RRC primacy on April 23, 1982.
• Chapter 27 of the Texas Water Code:
- Well is in the public interest
- No harm to oil, gas or other mineral formation
- Both ground and surface water protected
- Financial responsibility
• Title 3 of the Texas Natural Resource Code
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Injection Well Permitting
Railroad Commission Rules Permitting
• 16 TAC § 3.8 – Water Protection (pits, discharges, waste
haulers)
• 16 TAC § 3.9 – Oil and Gas Waste Disposal into Nonproductive Formations (Chapter 27 of the Water Code)
- About 15,000 permitted (approx. 5000 active)
• 16 TAC § 3.46 – Fluid Injection into Productive Formations
(Natural Resources Code)
- About 40,000 permitted (approx. 28,000 active)
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Injection Well Permitting
Permitting Forms: Which to file?
• Is the injection formation productive or
non-productive?
• “productive” = current or past production within a 2
mile radius of the proposed injection well
• File original application to Austin office
• Mail a copy to the district office
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Injection Well Permitting
Forms
• Form W-14
– To apply for Disposal into a Non-Productive Formation
– Statewide Rule 9
• Form H1 and H1A
– To apply for Injection /Disposal into a Productive
Formation
– Multiple Zones: If a mix of Productive and NonProductive
– Statewide Rule 46
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Injection Well Permitting
Fees
• Rule 9 (Forms W-14) – non-productive formations
$100 permit application fee (per wellbore)
• Rule 46 (Form H-1/H-1A)– productive formations
$500 permit application fee (per wellbore)
• Exception Request
$375 (additional) each exception request
• These filing fees are non-refundable
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Injection Well Permitting
Administrative Staff:
• Juanita Jimenez
(512) 463-3576
Juanita.Jimenez@rrc.state.tx.us
• Molly Edwards
(512) 463-4032
Molly.Edwards@rrc.state.tx.us
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Injection Well Permitting
Preliminary Review
• Check Organization Report (Form P-5)
- Must have active P-5 before application is reviewed
• Check Certificate of Compliance (Form P-4)
- Verify that applicant is operator of lease
- Check for any outstanding violations
• Check UIC (Underground Injection Control)well
Inventory
- Is this application for a new or amended permit?
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Injection Well Permitting
Dual Authorities
• Only one permit may be valid on an
injection/disposal well at any given time
- An amended permit supersedes the old permit
• Plan re-permitting to coincide with workover
• Whenever a dual authority is discovered, the
older permit is cancelled
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Injection Well Permitting
Attachments
• Electric Log
• “Water Board Letter”
• ¼ mile Area of Review (AOR) plot and table
• Notice: ½-mile AOR, notice list and signed/dated
certification statement
• Publication clipping and affidavit
• Fresh Water H-7, questionnaire, analysis and plat
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Injection Well Permitting
Attachments: Electric Log
• A complete electric log or similar log of the
proposed injection/disposal well
• If well log is not available for proposed well, a log
from a nearby well may be submitted.
• If multiple wells covered by one Form H-1, only
one representative well log is required.
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Injection Well Permitting
Attachments: “Water Board letter”
• RRC Groundwater Advisory Unit (GAU) formerly
TCEQ Surface Casing Unit.
• Commonly referred to as the “Water Board letter”,
“surface casing letter”, “No Harm letter”, “TCEQ
letter” and now “GAU letter”
• Two different types of depending of whether
application is H-1 or W-14
• http://www.rrc.state.tx.us/environmental/environ
support/gau/index.php
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Injection Well Permitting
Attachments: “Water Board letter”
• Form H-1: States the Base of Usable Quality Water
(BUQW – TDS 3,000 ppm) that must be protected.
May be for area well and no more than 5 years old.
• Form H-1 submitted for the purpose of disposal:
Must also include the depth to the Usable Source
of Drinking Water (USDW – TDS 10,000 ppm)
• Form W-14: Well specific and includes BUQW,
USDW and disposal interval.
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Injection Well Permitting
H-1 “Water Board” letter
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Injection Well Permitting
W-14 “no-harm letter”
Must cover proposed
injection interval
States BUQW and USDW
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Injection Well Permitting
Attachments: Area of Review (1/4-mile AOR)
• Provide the data of record for wells that penetrate
the proposed injection interval within one quarter
(1/4) mile. (expanded when appropriate).
• Confirm wells have been plugged (or cased and
cemented) in a manner that will prevent the
movement of fluids into strata other than the
authorized injection or disposal interval.
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Injection Well Permitting
Attachments: Area of Review (1/4-mile AOR)
Submit:
• Plot showing well location and operator of AOR
wells
• Tabulated data keyed to AOR plot:
- Lease name and number, well number, API number ,
total depth, date drilled, current status,
plug date (if applicable)
- Note: Providing copies of plugging reports may
expedite processing
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GIS Map
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(Insert Graph Here)
Delete if un-needed
Add API#
Then >
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Map Tools:
Select ¼ or ½ mile
Then click on well location
to generate AOR
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Injection and Disposal Well Permitting
Map tools:
Identify Wells
Then click on well
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Injection Well Permitting
Click link for wellbore record and current status
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Type Well = Status
Injection Well Permitting
“On Schedule” =
Producing, Injecting, ShutIn.
“Unknown Status”(maybe?)
= Dry, blank, Historic
If well status unknown, will
require either:
• plugging record;
• completion report
(W-2/G-1) to add well to
schedule;
• Pressure Front
Calculation
• Plug well before injection
.
Submit Summary Table and not this printout for every well!
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Injection Well Permitting
Attachments: Notice
• Mail or deliver a copy of the application form
(W-14 or H1/H-1A, front and back) to:
–
–
–
–
–
The surface owner
Adjoining surface owners (Commercial Disposal)
Operators of wells within a ½ - mile
The county clerk
The city clerk if well is located within corporate city
limits
• Recommend including a cover letter briefly
explaining the nature of the application.
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Injection Well Permitting
Attachments: Notice
Submit:
• Plot (½-mile AOR) showing well location & operator
• A table of the names and addresses of those parties
required to be notified along with a signed and
dated statement indicating the date that notice was
mailed or delivered.
• A plat showing clearly the owner of record of the
surface and adjoining surface tracts and tract
boundaries (Commercial Disposal)
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Injection Well Permitting
Example:
Adjoining or “offset”
surface owner plat
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Example:
Signed and dated notice
certification page
Offset operator and surface/
adjacent surface owner
names identified on AOR
plot/adjoining surface owner
plat must be consistent with
names on notice table
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Injection Well Permitting
Attachments: Publication
• Publish
- notice for one day in a newspaper with general
circulation in the county.
• Submit
- Notarized affidavit of publication
- Newspaper clipping
• Publication and affidavit shells available on
Injection/Disposal Well Permitting Manual
• 15 day waiting period after notice and publication
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Injection Well Permitting
Publication Guidelines
• The newspaper need not be in the same county as the
well, but must have general circulation in that county.
• The affidavit must state that the newspaper is of general
circulation in the county where the proposed
injection/disposal well is to be located.
• The legal authority, notice of opportunity/instructions to
protest application, and RRC contact information must be
included in publication.
• The newspaper publication must state that the application
is for a “commercial” disposal well.
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Injection Well Permitting
Attachments: Fresh Water Injection
• If application to inject fresh water, the following
attachments are required:
– Fresh water questionnaire
– Form H-7
• Required unless fresh water is purchased
commercially
• Include plat of fresh water rights
– Chemical analysis of the fresh water
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Injection Well Permitting
Permit Amendments
• Filing requirements vary with type and
magnitude of amendment.
• Filing fee (per well) is required in all cases.
• Well log, groundwater letter, AOR map and table
are usually required when amending injection
interval up-hole or permits issued prior to April
1982.
• Refer to Guidelines for Permit Amendments in
the Injection/Disposal Well Permitting Manual.
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Injection Well Permitting
Technical Review: Surface Casing
• Commercial and new injection wells must set and
cement surface casing through the BUQW
• Applications for wells with “short surface casing”
converted from production to lease injection/disposal
are reviewed on a case by case basis. If permitted,
requires more frequent testing and monitoring (annual
mechanical integrity (MIT) testing and weekly tubingcasing annulus monitoring (TCAM) vs. 5-year MIT and
monthly TCAM if well is constructed to current
standards.
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Injection Well Permitting
Technical Review: Casing Cement
•
Cement must be adequate to confine fluids to the
injection interval
•
Top of Cement (TOC) Requirements:
- At least 600 feet if TOC is based on volume calc
- 250 feet if TOC is determined by temperature
survey run at time of cementing
- 100 feet if TOC is determined by cement bond log
•
RRC rules have required 600 feet of cement above
casing shoe, or shallowest productive interval since
1932
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Injection Well Permitting
Technical Review: Geological Requirements
• Proposed injection interval must be isolated from
overlying usable quality water by a sufficient
thickness of relatively impermeable strata
(accumulative total of at least 250 feet of clay or
shale).
• Verify that the proposed injection zone is
adequately isolated by relatively impermeable
strata to confine injected fluids to the proposed
injection interval.
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Injection Well Permitting
Technical Review: Area of Review
• Amendments to SWR 13(a)(4)(C) effective 1-14-2014: Casing
of AOR wells must be cemented across and above all
formations permitted under SWR 9 or cemented
immediately above all formations permitted for injection
under SWR46
• All abandoned wells within the ¼ - mile AOR must be
adequately plugged (cement plug between top injection
formation and BUQW). (May add as condition of permit).
• Pressure Front Calculation (PFC): The applicant may
calculate the actual affected radius to justify a lesser radius
than ¼ -mile. PFC must be prepared by a Texas Registered
Professional Engineer.
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Injection Well Permitting
Technical Review: Packer setting depth
• Rule 9:
– The packer must be set within 100 feet
• Rule 46:
– While Rule 46 allows for flexibility in the packer setting
depth (150 feet below deepest groundwater and 200
feet below TOC), staff recommends the packer be set
within 100 feet of the permitted zone
– There may be no potential injection/disposal zones
between the packer and the top of the permitted zone
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Injection Well Permitting
Technical Review: Injection Pressures
• The maximum injection pressure limited to 0.5
psi/ft.
• In some areas injection pressure is limited to ¼
psi/ft (ex: shallow coastal wells, Barnett Shale).
• Applicant may perform a fracture step-rate test to
measure the actual fracture pressure and to
justify a higher permit pressure.
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Injection Well Permitting
Technical Review: Injected Fluids
• Limited to the injection of produced salt water
unless other fluids are specified
• Injection of Hydrogen Sulfide (H2S) requires “wellspecific” authority. Contact the H2S Statewide
Coordinator in Midland or San Antonio District
Offices (SWR 36)
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Injection Well Permitting
Technical Review: Commercial Facilities
• Surface facility requirements are added to deal
with spill prevention, containment, pit
permitting and security issues
• A well is commercial if:
– Salt water or waste is partially or wholly trucked
in, or
– A fee or other compensation is charge for
disposal
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COMMERCIAL DISPOSAL
SURFACE FACILITY REQUIREMENTS
•
•
•
•
•
•
All collecting pits, skimming pits, or washout pits must be permitted under the
requirements of Statewide Rule 8.
Catch basin(s) catch oil and gas waste which may spill as a result of
connecting and disconnecting hoses or other apparatus while transferring oil
and gas waste from tank trucks.
Waste storage and pretreatment facilities (tanks, separators, or flow lines)
shall be constructed of steel, concrete, fiberglass, maintained so as to prevent
discharges.
Dikes shall be placed around all waste storage, pretreatment, or disposal
facilities. The dikes shall be designed so as to be able to contain a volume
equal to the maximum holding capacity of all such facilities. Any liquids or
wastes that do accumulate in the containment area shall be removed within 24
hours and disposed of in an authorized disposal facility.
Must have security to prevent unauthorized access. Access shall be secured
by a 24-hour attendant, a fence and locked gate when unattended, or a keycontrolled access system. For a facility without a 24-hour attendant, fencing
shall be required unless terrain or vegetation prevents truck access except
through entrances with lockable gates.
Storage tank(s) equipped with a device (visual gauge or alarm) to alert drivers
when each tank is within 130 barrels from being full.
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Injection Well Permitting
Permit Processing
Permit Denials
• Application is still incomplete after two additional filings
• Denial based on unsatisfactory completion or operating
proposal
– The applicant may modify the application to allow for
administrative approval, or
– Request a hearing before the Commission. The
application must be administratively complete before a
hearing date can be set.
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Injection Well Permitting
Protested Applications
• Staff may administratively issue a permit only in
the absence of a protest
• A protest may be filed anytime before a permit is
issued
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Injection Well Permitting
Protested Applications
Who can protest?
• Affected parties
– Operators of wells within ½ mile
– Surface owner of record
– Adjoining surface owners for commercial well
• Local government (such as city or water district)
• Other parties must demonstrate that they will be affected
reviewed on a case-by case basis
– Offset surface or mineral owners
– Other government agencies
– Members of the general public
• Staff does not evaluate the validity of the protest
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Injection Well Permitting
Protested Applications
Options for applicant:
• Withdraw the application
• Obtain a letter from the protestant withdrawing the
protest
• Request a hearing
– The application must be administratively complete
before a hearing may be scheduled
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Injection Well Permitting
Post Permitting - MIT
• A mechanical integrity test (MIT) must be
performed before any fluids are injected into the
well.
• Once the well is converted to injection, an MIT
must be performed periodically (1 or 5 year test
schedule), after workover, or whenever
mechanical integrity is in doubt.
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Injection Well Permitting
Post Permitting – Completion Report (W2/G-1)
• File a completion report (Form W-2/G-1) within 30
days (SWR 16) to reflect the actual completion of
the well.
• Filing a completion report on-line greatly reduces
processing time.
• Lease numbers for new leases (Form P-4) are
assigned after final processing/approval of
completion report.
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Injection Well Permitting
Application vs. Construction
• The well must be constructed and operated as
proposed in the application and permit
• Permit required remedial action (i.e., permit
special conditions) must be done before
injection begins.
• Operation not in accordance with the
application and the permit may result in permit
modification, suspension or revocation
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Injection/Disposal
Permit Query
Imaged Records:
W-14, H-1/H-1A:
EDMS – Search all
Permit Apps since
9/2000
H-10 Query
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Injection/
Disposal
Permits
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Enter:
Tracking# or
Oper#
County
Date range
Doc type
(W-14/H-1)
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Injection Permitting Technical Staff:
Section
Dave Hill, Manager
David.Hill@rrc.state.tx.us
Jim Moore
Jim.Moore@rrc.state.tx.us
Robert (Bob) Freymuller
Robert.Freymuller@rrc.state.tx.us
Nagi Mabruk
Nagi.Mabruk@rrc.state.tx.us
Jim Davis
Jim.Davis@rrc.state.tx.us
Cheryl Burns
Cheryl.Burns@rrc.state.tx.us
Ashley Johnston
Ashkey.Johnston@rrc.state.tx.us
463-6792
463-3011
463-6443
936-0981
475-4655
463-6453
463-6454
463-6778
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THE END