1. Chairman Christi Craddick
Commissioner Ryan Sitton
Commissioner Wayne Christian
May 2017

2. 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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

8. 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)

9. 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.

10. 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

11. Groundwater Advisory Unit (GAU)

12. 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

13. 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.

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

16. Groundwater determination USES

17. 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.

18. Well Completion Surface casing Production casing Cement Tubing Packer
Perforations

19. 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

20. 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)

21. 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

22. 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

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

24. Case of the Lost Fish 1 2 3

25. 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

26. Producing Wells in Reverse
Injection Wells

27. Why Inject Fluids Underground?
Enhanced recovery
Waste disposal
Storage

28. 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

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

31. Environmental Permits & support

32. 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

33. Thank You
Sean Avitt