Texas Underground Injection Control Program 2017 TCEQ Environmental Conference and Trade Fair May 17, 2017 Lorrie Council, P.G., Manager, UIC Permits Section Radioactive Materials Division Office of Waste Image Group is TCEQ Logo and Diagram of Class I Injection Wells Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Underground Injection Control (UIC) Program 2017 Presentation Content Organizational & Staff Updates UIC Well Inventory by Well Class Class I Injection Well Inventory & Highlights Class III Injection Well Inventory & Highlights Class V Injection Well Inventory & Highlights Aquifer Storage & Recovery Wells UIC Contact Information Image Group is TCEQ Logo and Diagram of Class I Injection Wells Image Group is TCEQ Logo and Diagram of Class  I Injection Wells

TCEQ UIC Organization UIC Program Implemented by: Office of Waste, Radioactive Materials Division (RMD): Permitting Office of Compliance & Enforcement: Workover Approvals, Routine Operations/Reporting, Compliance, Enforcement UIC Class I/III Permitting for In-Situ Uranium Facilities Conducted By RMD’s Radioactive Materials Section RMD’s UIC Permits Section Focus: Permits/Authorizations Evaluation & Processing for Class I & Class V Injection Wells, including Aquifer Storage & Recovery UIC Programmatic Reporting UIC Rulemaking & Legislative Bill Analysis UIC Program Coordination (internal & external to agency) Image Group is TCEQ Logo and Diagram of Class  I Injection Wells

TCEQ UIC Staff Updates The New Reality: Doing More with Less This means streamlining processes and prioritizing assignments UIC Permits Section Staffing Changes: Tom Ortiz, PhD, PE, UIC Engineer, joined June 2016 Kathryn Hoffman, PE, UIC Engineer, retired May 2017 Conrad Kuharic, PG, UIC Geologist, retired July 2016 Radioactive Materials Section Staffing Changes: Tony Gonzalez, Uranium Licensing & Permitting Work Lead, as of January 2017 Image reads "Standards + Tools = Streamlined Processes"

TCEQ UIC Inventory by Well Class Type of Injection Well Number of Facilities Permitted or Authorized Wells Active Permitted Wells Wells Temporarily Abandoned Other Wells (Plugged, Under Closure Review) I Hazardous Waste Disposal 23 80 52 3 2 Nonhazardous Waste Disposal 24 93 46 1 III In Situ Mining 9 NA 6,208 IV Prohibited (unless specifically authorized) 6 145 V Miscellaneous Wells (~21 subclasses) 2,475 48,732 Total No. Facilities and Wells (as reported to EPA 2/24/17) 2,537 49,050 6306 4 A table lists numbers of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2017, broken down by class of injection well A table lists numbers of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2017, broken down by class of injection well

UIC Class I Permit Applications & Permits Issued in 2016 Class I Applications Received Class I Permits Issued New Permit 8 Permit Renewal 11 12 Permit Renewal/Major Amend 1 3 Permit Renewal/Minor Amend Major Amendment Minor Amendment 9 7 Minor Modification 13 Endorsement Transfer 6 PIU Registration New/Renewal A table depicts Class 1 applications by type as compared to the Class 1 permits issued for that type, for 2015. A table depicts Class 1 applications by type as compared to the Class 1 permits issued for that type, for 2015.

Class I Highlights TCEQ received new Class I permit applications for two facilities: New industrial facility along the Texas Gulf Coast (two hazardous waste disposal wells); Commercial non-hazardous waste disposal well in North Texas currently permitted as a Class II oil & gas commercial disposal well. Several Class I renewal, amendment, & minor modification applications were completed in 2016 or are in process (several in final notice period). UIC Permits Staff conducted a review of geologic literature & records regarding induced seismicity from deep well injection (David Murry will be covering this in the following presentation) UIC Permits Staff also worked with permittees on reservoir pressure & operating pressure monitoring for atypical situations in E. Texas & the Texas Panhandle, including downhole injection pressure monitoring Image is a picture from an injection well site.

Class I Highlights, cont. Two new wells were installed recently but are currently addressing well construction issues & workovers for issues such as mechanical integrity or differing reservoir conditions than anticipated in the permits. One new well (non-hazardous waste) came on line in early 2017 to replace a well that had been in an over-pressured reservoir (E. Texas). This new well is completed in a lower, under-pressured formation and has downhole pressure monitoring instrumentation. The original well (hazardous waste) was successfully plugged & abandoned. Three additional hazardous waste disposal wells & two non-hazardous Class I wells were successfully plugged & abandoned in 2016. Image is a Diagram of Class I Injection Wells

UIC Class III Applications & Permits Issued in 2016 Class III Applications Received Class III Permits Issued New Area Permit 1 Area Permit Renewal Permit Renewal/Major Amend Major Amendment Permit or PAA Minor Amend 10 9 Permit or PAA Minor Mod 2 Endorsement 11 Transfer A table lists Class three applications by type compared to class three permits by each respective type. A table lists Class three applications by type compared to class three permits by each respective type.

Class III Highlights The low pricing of uranium yellow cake continues to affect the uranium industry & TCEQ’s permitting workload for in-situ uranium mines mirrors the industry slowdown. TCEQ’s UIC Program continued coordinating more closely with EPA Region 6 to facilitate EPA’s review/approval of UIC Program revision requests related to Aquifer Exemptions at Class III in-situ uranium mines. EPA Region 6 approved one aquifer exemption related UIC Program revision request in March 2017 for the proposed Burke Hollow in-situ uranium mine in Bee County. TCEQ’s formal request for the program revision had been sent to EPA in December 2016. Image is a photo of uranium yellow cake

UIC Class V Authorizations 2016 Class V Well Type Number of Authorizations or Amendments Issued Number of Associated Wells Stormwater Drainage Wells 5D02 1 Aquifer Recharge Wells 5R21 (includes ASR Wells) 2 Septic System/Drain Field Disposal Method 5W32 Aquifer Remediation 5X26 75 3,625 (includes temporary injection points) Experimental Wells 5X25 Total 80 3,631 A table lists the number of Authorizations and Amendments along with the number of associated wells for each type of class five well. A table lists the number of Authorizations and Amendments along with the number of associated wells for each type of class five well.

Class V Highlights TCEQ adopted revised rules in response to HB655 on Aquifer Storage & Recovery (ASR) Wells, 30 Texas Administrative Code (TAC), eff. May 19, 2016 Chapter 39 (Public Notice) Chapters 295 & 297 (Water Rights) Chapter 331 (UIC) TCEQ adopted revised rules in response to HB2230 which authorizes Class V permitting of RRC-permitted Class II disposal wells to authorize disposal of non-hazardous drinking water residuals (DWTR) & desalination concentrates. Rules (30 TAC 331) became effective December 29, 2016. Link to New Class V ASR & DWTR disposal well authorization application forms are located online As of April 20, 2017, TCEQ received two applications for ASR experimental wells. TCEQ issued one authorization & is processing the other application. No applications have been received for DWTR disposal using a dually-permitted Class V-Class II injection well.

Aquifer Storage & Recovery (ASR) ASR projects may be authorized by individual permit, general permit, or by rule; public notice required for individual ASR permit. TCEQ notifies groundwater conservation/other special purpose districts with authority to regulate groundwater withdrawal of applications received for authorization by rule. Rules no longer require a 2-stage authorization process (i.e., pilot project no longer required) Removed requirement for injectate to meet the drinking water standards found in 30 TAC Chapter 290. Specified injected water must meet requirements of federal SDWA Section 1421 (d)(2) Image Group is Diagram of ASR Wells Image Group is Diagram of ASR Wells

Aquifer Storage & Recovery Requires all wells for a single ASR project to be located within a contiguous boundary of one parcel of land or two/more adjacent parcels under common ownership, lease, agreement or contract ASR projects in the jurisdiction of a groundwater conservation or special purpose district with authority to regulate groundwater withdrawal are subject to the district’s rules for the volume of water produced that exceeds the recoverable volume Rules require TCEQ to make a determination on the volume of water that can be recovered as compared to the volume of water injected: Per 30 TAC 331.184 (g)(1): An authorization or permit issued … may not authorize a volume of water to be recovered that exceeds the volume of water that is injected or the volume of injected water that the commission determines can be recovered, whichever is less Image group is a photo of a barbed wire fence and a diagram of Texas divided by Groundwater Conservation Districts Image group is a photo of a barbed wire fence and a diagram of Texas divided by Groundwater Conservation Districts

Factors Considered in Determining ASR Recoverability Hydrogeologic Factors: Aquifer permeability Aquifer thickness Aquifer confinement Aquifer hydraulic gradient Geology - structural setting Geology – Aquifer formation, mineral content Ambient water quality Stratigraphic cross section of Permian strata exposed in the Apache Mountains

Factors Considered in Determining ASR Recoverability Design & Operational Factors: Size of project area & depth to injection zone Thickness & location of storage zone(s) w/in the aquifer Initial buffer-zone building phase & long-term maintenance of the buffer zone Volume of injected water for each cycle Duration/frequency of cycles & cycle storage periods Well design & performance/Well field & various configurations Quality of injected water & possible pre-treatment Image group is a satellite photo of a field with well configurations and a photo of 3 glass bottles containing liquid.

ASR Recoverability: What if I Don’t Have All the Info? Obtain a UIC Class V Experimental Well Authorization. Design & conduct a testing program, based on project needs, such as : Obtain additional hydrogeologic information Characterize injection water Characterize formation & ambient water quality Design & build injection/recovery test well(s) Conduct limited injection & recovery operations (e.g., cycle testing) Submit monitoring information & summary report If ASR Project is feasible, prepare & submit ASR application to TCEQ Image Group is Diagram of ASR wells and a Well cover. Image Group is Diagram of ASR wells and a Well cover.

TCEQ New ASR Authorization Application Form Required Elements: General Facility/Operator Information, Core Data Form, Legal Description, Signature Page, Notice Information ASR Project Area Area of Review & Artificial Penetrations Well Construction & Closure Injection Well Operation Project Geology, Hydrogeology, and Geochemistry (should have spatially complete actual data for project site such as core testing, well logging, chemistry of injected & aquifer waters to make evaluation of geochemical interactions, etc.) Demonstration of Recoverability (site specific analysis, may include groundwater modeling, cycle testing data, etc.) Image is a photo of a TCEQ application form.

Questions? Lorrie Council, P.G. Manager, UIC Permits Section Texas Commission on Environmental Quality lorrie.council@tceq.texas.gov (512) 239-6461 Main RMD/UIC Phone: 512-239-6466 TCEQ Main Web Page UIC Permits Webpage