Department of Conservation Division of Oil, Gas, and Geothermal Resources Bill Bartling Inland District Deputy

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1 Department of Conservation Division of Oil, Gas, and Geothermal Resources Bill Bartling Inland District Deputy PROCESS, STATUS AND NEXT STEPS FOR AQUIFER EXEMPTION AUGUST 2016 CALIFORNIA STATE UNIVERSITY, BAKERSFIELD CALIFORNIA

2 DOGGR mission All three elements form the foundation for the Aquifer Exemption application technical analysis with an emphasis on water. Beneficial uses of water include: Municipal drinking water Residential use Agriculture and livestock Industrial Enhanced oil recovery The Division supervises the drilling, operation, maintenance, and P&A of oil, gas, and geothermal wells, to prevent damage to: 1. life, health, property, and natural resources; 2. underground and surface waters suitable for irrigation or domestic use; 3. oil, gas, and geothermal reservoirs.

3 Oil in California The Inland District is responsible for 80+% of California oil and gas activities, comprising ~135,000 active wells: Producing Injecting Idle Orphan Aquifer Exemption locations marked by red stars.

4 waters of the san joaquin valley Waters are fresh on the east, saline on the west. This is due to: fresh water recharge from the Sierra Nevada range via the Kern River and other waterways sparse rainfall in the west to dilute saline formation waters deeper formations deposited in marine environments in the central and western areas saltier Fresher beneficial uses Figure from: Gillespie, Kong and Anderson CSUB 2016

5 aquifer exemption process

6 aquifer exemption process Construction of technical application Sign off by District Delivery to HQ and SWB SWB Review DOGGR District Operators Draft delivery to EPA Concurrence Letter / Start of Public Comment Review and decision Formal Delivery to EPA

7 inland district aquifer exemption portfolio 20 applications to be submitted to DOGGR Headquarters, State and Regional Water Quality Control Boards, the public and the US Environmental Protection Agency. After reviewing the technical documentation and public comments, the US EPA will determine if it will grant an exemption this determination is part of the US Safe Drinking Water Act. in public comment stage Round Mountain Fruitvale Tejon DOGGR proposal complete Cymric McKittrick Elk Hills Phase 1 Elk Hills Phase 2 MidwaySunset Mt. Poso Kern River South Belridge Kern Front proposals scheduled to be complete by the end of the month Poso Creek Lost Hills Edison NE Edison Jasmine Jacalitos/Coalinga N. Belridge Kettleman Hills To be delivered on Monday

8 inland district aquifer exemption historical and planned timeline

9 federal exemption criteria Exemption criteria as specified in 40 CFR a) The aquifer does not currently serve as a source of drinking water b) The aquifer cannot now, and will not in the future, serve as a source of drinking water because: 1) It is mineral, hydrocarbon, or geothermal energy producing, or can be demonstrated by a permit application for a Class II operation to contain hydrocarbons that considering their quantity and location are expected to be commercially producible OR 2) The aquifer is situated at a depth or location that makes the recovery of water for drinking water purposes economically or technologically impractical OR 3) The aquifer is so contaminated that it would be economically or technologically impractical to render that water fit for human consumption OR c) TDS is more than 3,000 and less than 10,000 and it is not reasonably expected to supply a public water system.

10 state exemption criteria Exemption criteria as specified in PRC 3131(a) 1. Criteria set forth in Section of Title 40 of the Code of Federal Regulations 2. The injection of fluids will not affect the quality of water that is, or may reasonably be, used for any beneficial use 3. The injected fluid will remain in the aquifer or portion of the aquifer that would be exempted

11 vertical stratigraphic containment It must be demonstrated that zones proposed for exemption are stratigraphically isolated from actual or potential zones with waters with beneficial use.

12 lateral extents and thickness of vertical confining layers The distribution and thickness of stratigraphic confining layers are defined and mapped from well data

13 vertical and lateral confinement Vertical and lateral isolation of the proposed exempted zone from water wells with beneficial use must be demonstrated.

14 hydrocarbon producing Demonstration of hydrocarbon presence from producing wells, subsurface samples and well logs

15 mapping water wells All water wells which produce for beneficial use within and for an effective distance beyond the proposed exemption are mapped and analyzed.

16 isolation of water wells from exemption zone It must be demonstrated that the proposed exempted zones have containment boundaries, such as impermeable shales, faults or stratigraphic pinchouts to ensure that injected fluids remain in the exempted zone. This diagram shows the proposed exempted zone and water wells in the area, several thousand feet separated from the proposed exempted zone.

17 water chemistry Typical water chemistry analysis including drinking water standards, proposed exempted aquifer chemistry and proposed injectate water chemistry. Note that in this case, the quality of the injectate is higher than the native formation waters.

18 exemption criteria inland district all aquifer exemption applications in the inland district have hydrocarbon bearing as their primary criteria for some or all of the proposed exempted area. many aquifers have high TDS many aquifers are very deep with better quality water available much shallower Field hydrocarbons present high TDS Cymric X X Elk Hills X X McKittrick X X Edison X Edison NE X Fruitvale X Kern Bluff X Jasmin X Kern Front X Kern River X Mt. Poso X Poso Creek X Round Mountain X X Tejon X S. Belridge X X Lost Hills X X Jacalitos/Coalinga X X Midway Sunset X X N. Belridge X X Kettleman Hills X X

19 next steps completion of aquifer exemption proposals this month submission to DOGGR HQ for review and comment submission to State Water Boards for review and comment public comment periods, draft submission to US EPA, public hearings respond to comments formal submission to US EPA prioritize and initiate UIC project reviews for exempted aquifers

20 Department of Conservation Division of Oil, Gas, and Geothermal Resources Bill Bartling Inland District Deputy PROCESS, STATUS AND NEXT STEPS FOR AQUIFER EXEMPTION AUGUST 2016 CALIFORNIA STATE UNIVERSITY, BAKERSFIELD CALIFORNIA

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