Understanding The Class II Underground Injection Control Application Process In Colorado To Comply Cost-Effectively

Transcription

1 Understanding The Class II Underground Injection Control Application Process In Colorado To Comply Cost-Effectively Denise M. Onyskiw, P.E. Underground Injection Control Program Supervisor Colorado Oil and Gas Conservation Commission Tight Oil Water Management 2012 October 30, 2012

2 Class II waste Applicable regulations Federal regulations Colorado Oil and Gas Conservation Commission (COGCC) Regulations Underground Injection Control (UIC) application process Overview

3 Resource Conservation and Recovery Act (RCRA) Subpart C Exempt Waste Because the RCRA exempt status of an oilfield waste is based on the relationship of the waste to exploration and production (E&P) operations, and not on the chemical nature of the waste, it is possible for an exempt waste and a non-exempt hazardous waste to be chemically very similar. Definition of Class II Waste

4 Produced water Drilling fluids Spent well treatment or stimulation fluids Pigging wastes Gas plant wastes Amine Cooling tower blowdown Allowable Injection Fluids

5 Unused fracturing fluids or acids Painting wastes Refinery wastes Lubricating oils Sanitary wastes Radioactive tracer wastes Non-allowable Fluids

6 UIC program is part of the Safe Drinking Water Act administered by the Environmental Protection Agency (EPA) Colorado was given primacy for Class II injection wells in 1984 Applicable Regulations 40 CFR 144 through 147

7 Rule 324b addresses aquifer exemptions Rule 325 addresses underground disposal of water 400 Series Rules address enhanced recovery operations 1100 Series Rules address pipelines Applicable Regulations COGCC

8 Rule 324b addresses aquifer exemptions Testing of water quality of disposal formation is required. If total dissolved solids (TDS) < 10,000 ppm, an aquifer exemption is required. Aquifer exemptions are granted when: ú The formation is hydrocarbon producing ú The formation is too deep to be economically produced as a source of drinking water ú The water is so contaminated it would be economically impractical to treat it for human consumption Notice of the aquifer exemption request is published in the local newspaper for a 30-day comment period The notice is also forwarded to the EPA and Colorado Department of Public Health and Environment for their review Aquifer Exemptions (Rule 324b.)

9 1. COGCC Rule 325 outlines the application process for underground injection. 2. Injection Permit Application: Form 31 contains details of the type of injection, fluid type, geologic formation, injection rate and pressure. 3. Injection Well Permit Application : Form 33 describes the downhole geometry and perforations. 4. Source of Produced Water for Disposal: Form 26 provides a list of where the E&P waste is sourced. UIC Application Process (Rule 325)

10 Injection into the same formation production is taking place is enhanced recovery or water recycling. Unitization of field is necessary in order to protect correlative rights. Enhanced Recovery (400 Series Rules)

11 Form 2 Permit to Drill (submitted online) New wells Re-entry of plugged and abandoned wells Adding formations not permitted on a previously approved Form 2 Deepening an existing well Form 2A Oil and Gas Location Assessment (submitted online) Form 4 Sundry Notice to accompany a Form 2 that is not for a new well Forms to Submit

12 Form 31 Injection Permit Application Form 33 Injection Well Permit Application Form 26 Source of Produced Water Form 42 Notice of Notification (Notice of Hydraulic Fracturing) Form 5 Drilling Completion Report for new wells and those where additional cement is added (submitted online) Form 5A Completed Interval Report (submitted online) Forms to Submit

13 1. Proposed injection program brief narrative explaining program and including details not included on forms 2. Surface or salt water disposal agreement a) If surface is not owned by operator, the agreement must be signed by surface owner b) Redact any information related to financial arrangements c) Bureau of Land Management (BLM) land: a signed sundry from BLM instead of a surface use agreement d) Rights to dispose of water are not like mineral rights surface owner has the right to refuse 3. Notice to surface and mineral owners a letter sent certified or registered mail or hand delivered to all surface and mineral owners within a ¼-mile radius circle around intended injection well 4. Remedial correction plan for wells all wells within the ¼-mile area of review must have cement coverage to prevent water migrating vertically to another zone Form 31 Support Information

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15 5. Maps and lists a. Map of all wells (oil and gas and water) within ¼ mile of injection well b. Map of all producing wells within ½ mile of injection well c. Maps and lists of all surface and mineral owners within ¼ mile of injection well d. Unit area plat (required for enhanced recovery) 6. Surface facility diagram 7. If commercial facility, description of operations and area served Form 31 Support Information

16 8. Resistivity or induction log this can also come from a well within one mile but must include the injection formations 9. Cement bond log (can be uploaded with Form 5) 10. Water analysis for injection zone (total dissolved solids) must be from intended injection well or nearby well (same section) and same injection formation 11. Contact person should be who to call with questions about well completion not necessarily the consultant who prepared the application Form 31 Support Information

17 Current wellbore diagram Proposed wellbore diagram Form 33 Support Information

18 Chemical analysis of fluids If more than six source wells, attach a table Form 26 Support Information

19 Pre-drilling 1. Forms 31, 33, 26, and, if applicable, Forms 2, 2A, and 4 are submitted at once Forms 2 and 2A are submitted online 2. Missing attachments to Forms 31, 33, and 26 may be added later if not immediately available 3. Public notice will be posted once surface use agreement or BLM sundry is received 4. Memos are sent by COGCC to the Colorado Division of Water Resources and the Colorado Geological Survey for evaluation of groundwater protection and seismic activity, respectively UIC Application Process

20 Post drilling 1. Well is completed or re-completed by operator and Forms 5 and 5A submitted online, if applicable 2. MIT is performed a) Witnessed by state inspector who must receive ten days advanced written notice b) Test must be performed to maximum requested injection pressure: [Fracture gradient (psi/ft) psi/ft] x top perforation (feet) = maximum surface injection pressure (psi) c) Form 21 submitted with inspector s signature 3. Maximum injection volume is calculated using neutron density and density porosity logs and geometry of ¼ mile radius cylinder of sandstone injection formation 4. Permit to inject is issued AFTER MIT UIC Application Process

21 A step rate test may be performed by the operator to determine the fracture gradient of the injection formation. Step rate tests must be performed on new wells, once injection has begun the pore pressure increases and makes this data invalid. Default fracture gradient is 0.6 psi/ft. Step rate tests

22 Submit data to COGCC for analysis Data logger data is not necessary Submit pairs of flow rate vs. pressure reading Indicate if pressures are bottom hole or surface Step rate tests (cont.)

23 Bottom Hole Pressure (PSI) Fracture Pressure = 3300 psi BHP psi/ft gradient at 5970' Rate in Bbls/min Injection Rate Surface Pressure Hydrostatic Friction Loss Calculated BHP BPM PSI Pressure PSI PSI PSI Allowable injection pressure = (0.55 psi/ft psi/ft) x 5,970 = 716 psi surface injection pressure

24 1. Contact the county government some have lengthy processes 2. Do not start your project without including a geologist on your team 3. Fill well 24 hours before MIT this allows equilibrium of temperature and eliminates false pressure fluctuations 4. Address all correspondence concerning injection wells to Denise Onyskiw 5. When submitting forms online (Forms 2, 5, and 5A) document number to Denise Onyskiw 6. Be patient! Applications are issued within 30 days of completion of process Tricks to Make Things Faster!

25 1. Not talking to protestants COGCC also guards correlative rights and takes mineral owner protests seriously 2. Attempting to circumvent rules: Enhanced recovery fields must be unitized any disposal well being injected in the same formation nearby wells are producing out of must be in a unitized field 3. Volunteering cost information of how expensive it is to ship water somewhere else Tricks That Will Not Work

26 Questions Denise M. Onyskiw, P.E. Colorado Oil and Gas Conservation Commission ext