And Now for Something Completely Different: Unusual Class V Wells in Texas

Transcription

1 And Now for Something Completely Different: Unusual Class V Wells in Texas Presented at GWPC UIC Conference in Tulsa, OK on February 12, 2018 Lorrie Council, P.G., Texas Commission on Environmental Quality

2 Overview of Presentation Texas Commission on Environmental Quality (TCEQ) UIC Class V Program Case Study: Large Volume Disposal of Drinking Water Treatment Residuals Case Study: High Capacity Aquifer Storage and Recovery (ASR) Case Study: Long-Term ASR Using Surface Water Source Case Study: Experimentation on CO2 Sequestration Case Study: MITs on Disposal Well in Between Bankruptcy and New Operator Case Study: Experimental Well for Large Capacity Disposal of Drinking Water Treatment Residuals at Proposed Clean Energy Power Plant Facility Considerations for High-Volume, High-Tech, or Deep Class V Injection Wells

3 TCEQ UIC Class V Program Class V wells in Texas must first be authorized before wells can inject (except for closed loop heat pump wells) Application Review/Amend application as needed Authorization approval letter There are no application or periodic fees for Class V injection wells Most Class V wells in Texas are associated with Aquifer remediation Closed-loop heat pumps Sanitary wastewater disposal Stormwater drainage Most of the Class V injection wells in Texas are low-tech The running inventory of Class V wells in Texas is 50,646 (2017)

4 Inventory of Class V Wells in Texas Well Codes Class V Well Type # Wells Permits/Program 5A07 A/C Return Flow Wells 5A19 Industrial Cooling Water Return Flow 5D02, 5D04, 5F01 Drainage: Stormwater; Industrial; Agricultural 710 5R21 Aquifer Recharge; Aquifer Storage/Recovery 110 5W09, 5W10 Untreated Sewage; Large Capacity Cesspools 33 5W11 WWTP Disposal; Septic System Drainfield 5W12, 5W32 Large Capacity Septic Systems 54 MW Discharge Permit Required 5W20 Industrial Process Waste Disposal 26 Ind W Discharge Permit Required 5X25 Experimental (Pilot Tests, Tracer Studies, etc) 5X26 Aquifer Remediation 5X27 Other Wells 5X28 Motor Vehicle Waste Disposal Wells Running Inventory 12/31/17 (not all well types listed above) 12,868 From Water Well Driller Reports MW Discharge Permit Required 2,118 33,970 Superfund, DCR, VCP, LPST Related Effectively Banned/Permit Required 50,646 (includes closed wells)

5 Case Study: Large Volume Disposal of Drinking Water Treatment Residuals (DWTR) El Paso Water Utilities (EPWU): Disposal of DWTR from large reverse osmosis (RO) water treatment plant, initially authorized July 13, 2005 (amended multiple times since then) Authorized: 4 injection wells (3 installed) built to Class I Standards; injectate piped to tanks/wells ~22 miles from RO Plant; gravity flow Injection Zone: ~1,000 feet to 4,000 feet below ground surface (BGS) Injection Zone: USDW with ~8,800 mg/l Total Dissolved Solids Authorized Volume:3,360 Acre-Feet/Year (1,094,867,095 gal/year) Annual MITs Required (APT, RATS) and After Workovers (several to-date) Special Consideration: EPA Required Aquifer Exemption ~114 square miles

6 Case Study: EPWU Large Volume Disposal of Drinking Water Treatment Residuals, cont.

7 Case Study: High Capacity Aquifer Storage and Recovery (ASR) San Antonio Water System (SAWS) ASR - stores water from the Edwards Aquifer in the Carrizo Aquifer, initially authorized October 9, SAWS Twin Oaks Facility is situated on ~3,200 acres Injectate: Edwards Aquifer water produced far from ASR facility, transported by 2-way pipeline Authorized: 34 injection wells (29 installed over two phases of construction) Injection Zone: Carrizo Aquifer approximately 400 feet to 780 feet BGS Storage/Recovery Capacity: 64 MGD SAWS ASR system surpassed 100,000 AF (33 Billion Gallons) of water in storage April 2014

8 Case Study: SAWS HIGH CAPACITY ASR, cont.

9 Case Study: Long-Term ASR Using Surface Water Source City of Kerrville: ASR - storage and recovery of treated water from the Guadalupe River, Class V authorization issued September 11, At that time, a demonstration project permit from TCEQ Office of Water was also required since the water was state appropriated water (water rights) Authorized: 5 injection wells (2 constructed and in use; 1 well replaced) Injection Zone: Lower Trinity Aquifer, 495 feet to 819 feet BGS Authorized Volume: 4,760 AF/yr (1.55 Billion Gallons/yr or 4.25 MGD)

10 Case Study: Long-Term ASR Using Surface Water Source, Kerrville ASR, cont.

11 Case Study: Experimental Well for CO2 Geologic Sequestration University of Texas, Bureau of Economic Geology (BEG), working under a DOE grant, conducted a CO2 sequestration pilot test using a deep Class V well built to Class I well standards; authorization included typical Class I permit provisions Authorization: one well, issued February 5, 2004, closed October 6, 2009 Injection Zone: Frio Formation, from 4,900 feet to 5,200 feet (well log depths) Injectate: Food-grade CO2, non-hazardous brine, tracers Authorized Volume: 4,000 tons CO MG/year Authorized Pressures: MASIP <2,500 psig for fluids and <1,200 psig for CO2 Mechanical Integrity Tests (MIT): Required prior to injection and at closure Financial Assurance: Well closure cost estimate required, but no security required

12 Case Study: BEG Experimental Well for CO2 Geologic Sequestration, cont.

13 Case Study: MITs on Class I Well As a Class V Experimental Well Former Class I Well - Original operator declared bankruptcy; new operator required to do well workover and MIT prior to TCEQ issuing new Class I well permit; Class V authorization included typical Class I permit provisions Class V authorization needed for well tests because associated Class I well permit was contested; Class I well permit subject of litigation since issuance in June 2011 Authorization: one well issued July 23, 2009, closed July 8, 2011 Injection Zone: 5,134 feet to 6,390 feet (well log depths) Injectate: solutions used for testing, cleaning, servicing, closing the well Authorized Pressures: MASIP <1,250 psig; Injection Rate: <350 gpm Financial Assurance: security required (amount of est. well closure costs)

14 Case Study: MITs on Class I Well As a Class V Experimental Well, cont.

15 Case Study: Experimental Well Evaluate Large Volume Disposal of DWTR at Proposed Alternative Power Plant Limited liability corporation (LLC) obtained DOE grant to plan and install a clean energy coal-fired power plant. Purpose of Class V experimental well was to collect reservoir data and conduct injectivity testing, then evaluate potential for disposal of DWTR from an RO at proposed clean coal power plant Authorization: one well, issued Sept. 23, 2011, built to Class I well standards Injection Zone: 3,000 feet to 7,500 feet BGS, testing Queen, Clear Fork, and Wichita formations (actual completion depth 7,350 ) Injectate: solution of fresh water with potassium chloride Closure Plan: required in application; closure to Class I standards Financial Assurance: Security mechanism required for well closure costs (increased for inflation annually)

16 Case Study: Experimental Well Evaluate Large Volume Disposal of DWTR at Proposed Alternative Power Plant Well installed in 2012, testing conducted, completion report submitted and accepted in 2013 DOE suspended grant funding to company in February 2016 No communication from LLC since 2013 until bankruptcy notice in October 2017 LLC land lease reverted back to property owner, a municipal economic development corporation December 31, 2017 TCEQ Site Inspection November 3, 2017: Well is currently not plugged and wellhead has no gauges; original mud pits from well construction still in place Texas Attorney General s Office representing TCEQ in Chapter 7 bankruptcy court Desired Outcome: Properly plug and abandon well using financial assurance bond

17 Case Study: Experimental Well Evaluate Large Volume DWTR Disposal at Proposed Alternative Power Plant, cont.

18 Case Study: Experimental Well Evaluate Large Volume DWTR Disposal at Proposed Alternative Power Plant, cont.

19 Considerations for High-Volume, High-Tech or Deep Class V Wells Well Construction Standards: commensurate with intended use and completion depth and reservoir conditions may need to be Class I well standards Financial Assurance: may be important for authorization even though rules don t require FA - agency may need to rely on security mechanism to plug wells itself Mechanical Integrity Requirements: well use and construction may dictate the need to require annual MITs Monitoring and Reporting: high-volume and/or high-tech wells should have periodic monitoring and reporting requirements; agency should evaluate reports and make adjustments to authorizations if warranted Inspections and Compliance: agency compliance staff not routinely engaged for Class V well oversight and permitting staff are responsible for oversight; may need to make arrangements for agency compliance staff to conduct routine inspections (like Class I)

20 Questions? Contact Info: Lorrie Council, P.G. UIC Permits Section Manager Texas Commission on Environmental Quality Park 35 Circle (MC233) Austin, TX (512)