Chairman Christi Craddick Commissioner Ryan Sitton Commissioner Wayne Christian May 2017

Groundwater Protection Oil and Gas Wells Groundwater Protection Who am I? I’m Sean Avitt. I’m the newest member of the Groundwater Advisory Unit, which some of you at TCEQ may remember as the Surface Casing Unit. The Groundwater Advisory Unit in its new location is at a unique resource called upon at various points along the regulatory path through the Railroad Commission. And that is why I’m giving this presentation today– to lend my perspective.

Table of Contents Railroad Commission – Oil and Gas Division Introduction Regulatory Identification Groundwater Advisory Unit Groundwater Determination Uses Injection Wells Environmental Permits Groundwater protection has some basic facets across all industries. Oil and gas is no different. We strive to prevent pollution before it happens with registration and permitting, reporting, and monitoring. And when pollution does occur, we have enforcement mechanisms for compliance, remediation and penalties.

Railroad Commission of Texas (RRC) Mission Statement: “Our mission is to serve Texas by our stewardship of natural resources and the environment, our concern for personal and community safety, and our support of enhanced development and economic vitality for the benefit of Texans.” 16 Tx. Admin. Code - Chapter 3 Oil and Gas Division “Statewide Rules” (SWR) As opposed to “Field Rules” Groundwater protection has some basic facets across all industries. Oil and gas is no different. We strive to prevent pollution before it happens with registration and permitting, reporting, and monitoring. And when pollution does occur, we have enforcement mechanisms for compliance, remediation and penalties.

Groundwater Protection, Generally Pollution Prevention Registration / Permitting Reporting Inspection Enforcement Compliance / Remediation Penalties Groundwater protection has some basic facets across all industries. Oil and gas is no different. We strive to prevent pollution before it happens with registration and permitting, reporting, and monitoring. And when pollution does occur, we have enforcement mechanisms for compliance, remediation and penalties.

Partial Oil and Gas Division Hierarchy Technical Permitting Environmental Permits Groundwater Advisory Unit Injection – Storage Permits Field Operations District Offices Oil and Gas This is not a complete hierarchy. This organization chart is just intended to demonstrate the relationships of the departments that most directly deal with groundwater. In the blue, we have the Permitting side and, in the light green, we have the Compliance and Enforcement side.

Communication Technical Permitting Environmental Permits Groundwater Advisory Unit Injection – Storage Permits Field Operations District Offices Oil and Gas GAU has a lot of communication with Injection dept and the District Offices

RRC Regulatory Steps & Forms Organization Report (Form P-5) Drilling Permit (Form W-1) Groundwater Determination (Form GW-1 & GW-2) Well Completion (Form G-1 & W-2) Injection Permit (Form H-1 & W-14) Well Plugging (Form W-3A & W-3)

Regulatory Identification Organization Report (SWR 1) Operator identifying information and officers Drilling Permit (SWR 5) Operator and location Registration with the Commission is the first and one of the most important steps. It’s importance could be easily over looked, but without a way to identify and locate all of our facilities we would have much more difficulty in regulating the Oil and Gas industry. Tell lightning story.

Lightning Strikes Company began accepting saltwater and storing in tanks District office becomes aware company is not an Operator nor permitted for disposal Site Remediation cleans up Saltwater haulers are fined

Groundwater Advisory Unit (GAU)

Groundwater Protection Determinations Identifies groundwater protection intervals for oil and gas activities Surface Casing depth for new wells Plugging depths for abandoning wells Provide base of Underground Sources of Drinking Water (USDW) for injection wells Provides determination on disposal well interval isolation from freshwater

GAU Freshwater Classifications Usable-quality water (UQW): < 3,000 ppm TDS May include more saline waters that are known to be used Underground Sources of Drinking Water (USDW): < 10,000 ppm TDS Protection may include parts of formations without UQW or USDW, but are not isolated from parts that do have UQW or USDW There are several classifications for groundwater quality. GAU employs these terms when talking about groundwater quality and regulatory requirements. USDW is a federal term. Generally, we try to keep all these different qualities of water separate to maintain their quality.

GAU Resources Well Logs Water Well Data Reports ArcGIS & Petra GAU log library Other agencies (TWDB, BEG, TCEQ, etc.) Oil & Gas Operators

Groundwater determination USES

Well Conveyance Oil & Gas wells are holes in the ground intended to convey hydrocarbons to the surface. But, wells can convey anything to any permeable formation (incl. freshwater aquifers) that the well intersects if not properly installed. Before we get to what GAU does, specifically. We need to address what were protecting groundwater from. Oil and gas wells are conveyances. They are intended to convey oil and gas to the surface, but they can convey anything that can fit in the hole if not properly installed. And, that means that they could potentially impact freshwater aquifers.

Well Completion Surface casing Production casing Cement Tubing Packer Perforations

Surface Casing and Cement Protects usable-quality water from drilling/completion process Extra protection against leaks during production Cement Prevents annular migration of fluids Prevents corrosion of casing Usable-quality water

SWR 13 - Groundwater SWR 13 requires that surface casing protect groundwater as stated in Groundwater Advisory Unit (GAU) letter (Form GW-2) Sets quality standards for cement and steel for well casing Surface casing must be pressure tested before drilling deeper Report well completion (Form W-2)

Plugging and Abandonment A well must be plugged when it is dry, no longer economically productive, or has ceased injection. Plugs prevent fluid migration Usable-quality water Producing Zone Note casing partially removed

SWR 14 - Groundwater SWR 14 requires that cement plugs isolate groundwater as stated in Groundwater Advisory Unit (GAU) letter (Form GW-2) Requires that a well be plugged within a year of inactivity Sets quality and quantity standards for cement Plugging procedure (Form W-3A) must be pre-approved by District Office and plugging report (Form W-3) submitted after Authorizes the RRC to plug a well if necessary

State-Funded Plugging Orphaned Wells Fiscal Year 2017 Goals: Plug 1,050 wells $14.4 million budget

Case of the Lost Fish 1 2 3

GAU & District Office District office notified of unplugged abandoned section of well GAU collaborated with the District office GAU tailored groundwater recommendation to the situation with help of Operator information District office denied request to leave hole open Operator plugged well in accordance with plan at significant cost

Producing Wells in Reverse Injection Wells

Why Inject Fluids Underground? Enhanced recovery Waste disposal Storage

SWR 9 & 46 - Groundwater Prohibits injection into freshwater (USDW) Requires letter from GAU ensuring no freshwater is endangered (Disposal Wells – SWR 9) Requires review of nearby wells to ensure no migration of fluids occurs through wellbores Authorizes modification, suspension, termination of permits by RRC Well constructed in compliance with SWR 13

Reporting and Monitoring Periodic well pressure test required RRC staff determines pass/fail Inspector may witness Operators required to report injection volumes and pressures

Environmental Permits & support

SWR 8 and Ch. 4 Subch. B Water Protection No pollution of surface or subsurface waters Authorizes Management of Wastes at Drill Sites Onsite Pits, Disposal, Non-Commercial Fluid Recycling Permitting of other Disposal & Recycling Methods Volume / Rate of Disposal Facility Construction Facility Operation Facility Monitoring Facility Closure

Thank You Sean Avitt sean.avitt@rrc.texas.gov