Tennessee Underground Injection Control Program Overview

Tennessee Underground Injection Control Program Overview

Mission of the UIC Program The UIC program s mission is to protect underground sources of drinking water from contamination by regulating the construction and operation of injection wells.

Mission of the UIC Program TDEC is authorized to inspect any facility subject to the UIC program Types of inspections vary, based on status of wells and facility

State UIC Program Working With Various Partners Tennessee Department Of Transportation Ground Water Protection Municipal governments Multi-Section Separate Storm Sewer Program Cities Wellhead Protection Programs Remediation Drycleaner Program Underground Storage Tanks Department of Defense Department of Energy Oversight Tennessee Board of Regents Department of Education Office of Surface Mining Tennessee Road Builders Tennessee Home Builders Tennessee Chamber of Commerce Tennessee Association of Utility Districts Tennessee Valley Authority Tennessee Oil and Gas Association

History of Tennessee UIC Primacy August 9, 1985 Original UIC regulations promulgated in Tennessee May 21, 1997 Tennessee started with the first MOA July 31, 2000 Made first regulation changes to receive primacy June 29, 2006 Tennessee final Application package January 19, 2010 Second regulation change May 3, 2012 Federal Register published proposed rules for Tennessee Public Hearing June 7, 2012 Public hearing at L&C Tower March 30, 2015 Primacy signed and public noticed June 6, 2015 Tennessee takes over program

2000 Definition of Injection Well "Injection well" means a well or other injection point structure or device which is used for the emplacement of fluids into a subsurface stratum including, but not limited to: (a) (b) (c) (d) a "well" used for the emplacement of fluids; a "subsurface fluid distribution system; an "improved sinkhole"; or any other device designed, constructed constructed or used to emplace fluids into the subsurface, except as provided in rule 1200-4-6-.03(3).

Historical uses of injection wells in Tennessee 1966 Dupont chemical New Johnsonville 6 wells drilled injection depth from 3650 to 7000 feet all closed by 1998 1969 Stauffer Chemical (ICI, Zeneca) Mount Pleasant 4 wells drilled injection depth from 3000 to 6500 feet all closed by 1997 1979 Mobil Chemical (Rhone-Poulenc Chemical) Mount Pleasant 1 well drilled injection depth from 4583 to 6413 ft closed 1990 Currently there are no Class I injection wells in Tennessee

Types of UIC Wells Class I Wells used to inject hazardous wastes or dispose of industrial and municipal fluids beneath the lowermost Underground Source of Drinking Water (USDW). Class II Wells used to inject fluids associated with production of oil and natural gas Class III Wells which inject fluids for extraction of minerals

Types of UIC Wells cont. Class IV Wells which dispose of hazardous or radioactive wastes into or above a USDW (banned except for certain remediation systems) Class V Wells not included in the other classes, injecting into or above a USDW Class VI Wells used for the geo-sequestration of carbon dioxide

Class I wells Extensive permitting requirements No-migration demonstration for hazardous wells Continuous annulus monitoring Internal MIT every year (every five years for most Class I-non-hazardous) Frequent reporting

Class I wells Approximate base of USDW Gauge measuring Injection pressure Waste influent Gauge measuring Annulus pressure Conductor casing Surface casing Cement Confining Zone Cement Protection casing Confining Zone Injection Zone Injection tubing Fluid-filled pressurized area Perforations

Class II wells May have multi-well area permits Existing enhanced recovery wells (i.e., drilled before State program approved) may be authorized by rule for the life of the well Must demonstrate mechanical integrity at least every 5 years Monthly monitoring of injection pressure, flow rate, and volume

Class II wells WELLHEAD Injection pressure gauge Injected fluid Valves Annulus pressure gauge Annular access Base of protected water Bottom of surface casing Drilling mud Annular space Confining Zone Tubing Packing Perforations Bottom of casing

Class III wells Used for solution mining minerals, such as salt, sulphur, uranium and copper Inject chemical solutions, super-hot steam, or water into mineral formations Hot injectate dissolves and mixes with minerals underground; mineral-saturated solution pumped to surface for mineral extraction Injected fluids are frequently reused after some treatment

Class III wells Solution Mining Well Wellhead In Situ Leaching Well Wellhead Surface Casing Cement Casing Cement Production Casing Cement Centralizer Tubing Tubingcasing annulus Top of salt Slotted screen or pipe Mineralized zone Drill hole Cement basket Plug (drilled out after Cementing) Salt cavern Cap

Class IV wells Used to dispose of hazardous or radioactive waste into or above a formation which contains a USDW within 1/4 mile of the well Prohibited One exception: wells that reinject into same formation treated ground water pursuant to approved CERCLA or RCRA clean-ups Voluntary site clean-ups not subject to exception

Class V wells Class V: All injection wells that do not meet the definitions of Classes I, II, III, IV or VI Most are shallow and low-tech Most inject into or above USDWs Operators must submit inventory information Must not endanger USDWs

Different Types of Class V Systems Aquifer recharge wells Large capacity septic systems Mine backfill via wells Floor drains at commercial and industrial facilities that discharge to subsurface fluid distribution systems Geothermal heat pump wells for commercial facilities Storm water discharges via wells or improved sinkholes (modified) sinkholes Industrial/commercial waste and cooling waters into wells, septic systems or sinkholes (e.g., industrial facilities, car washes, funeral homes, ect.)

Class VI wells Class VI: Wells used for the geo-sequestration of carbon dioxide Extensive permitting requirements No-migration demonstration for hazardous wells Continuous annulus monitoring Internal MIT every year (every five years for most Class I-non-hazardous) Frequent reporting

Tennessee UIC Regulations 0400-45-06 Table of contents 0400-45-06-.01 Authority and Purpose 0400-45-06-.02 General 0400-45-06-.03 Injection Prohibited 0400-45-06-.04 Prevention of Pollution of Ground Water And Identification of Underground Sources of Drinking Water and Exempted Aquifers 0400-45-06-.05 Injected Fluid Standards 0400-45-06-.06 Classification of Injection Wells 0400-45-06-.07 Permit Required 0400-45-06-.08 Authorization by Permit For Injection Wells Not Authorized By Rule

Tennessee UIC Regulations Cont. 0400-45-06-.09 General Standards and Methods 0400-45-06-.10 Class I Wells 0400-45-06-.11 Class II Wells 0400-45-06-.12 Class III Wells 0400-45-06-.13 Class IV Wells 0400-45-06-.14 Class V Wells 0400-45-06-.15 Fees for Class I Injection Wells 0400-45-06-.16 Fees For Class II Injection Wells 0400-45-06-.17 Fees For Class III Injection Wells 0400-45-06-.18 Fees For Class V Injection Wells 0400-45-06-.19 Bonds Required for Permitted Wells Appendix A

Tennessee UIC Regulations 0400-45-06-.04 Prevention of Pollution of Ground Water And Identification of Underground Sources of Drinking Water and Exempted Aquifers (2) For Class I, II and III wells, if any water quality monitoring of an underground source of drinking water indicates the movement of any contaminant into the underground source of drinking water, except as authorized under this rule, the Commissioner shall prescribe such additional requirements for construction, corrective action, operation, monitoring, or reporting (including closure of the injection well) as are necessary to prevent such movement. In the case of wells authorized by permit, the Commissioner may impose additional requirements by modifying the permit in accordance with Rule paragraph (8) of Rule 0400-45-06-.08 or may terminate the permit in accordance with paragraph (9) of Rule 0400-45-06-.08. Additionally, the Commissioner may assess civil penalties for all permit or rule violations in accordance with T.C.A 69-3-115.

Tennessee UIC Regulations 0400-45-06-.04 (6)(c)(2) Identification of Underground Sources of Drinking Water For Class II wells, a demonstration of commercial producibility shall be made as follows: (i) For a Class II well to be used for enhanced oil recovery processes in a field or project containing aquifers from which hydrocarbons were previously produced, commercial producibility shall be presumed by the Commissioner upon a demonstration by the applicant of historical production having occurred in the project area or field; and (ii) For Class II wells not located in a field or project containing aquifers from which hydrocarbons were previously produced, information such as logs, core data, formation description, formation depth, formation thickness and formation parameters such as permeability and porosity shall be considered by the Commissioner, to the extent such information is available.

Tennessee UIC Regulations 0400-45-06-.06 (2) Classification of Injection Wells (2) Class II Wells that inject fluids: (a) Which are brought to the surface in connection with conventional oil or natural gas production and may be commingled with waste waters from gas plants which are an integral part of production operations, unless those waters are classified as a hazardous waste at the time of injection; (b) For enhanced recovery of oil or natural gas; and (c) For storage of hydrocarbons which are liquid at standard temperature and pressure.

Tennessee UIC Regulations 0400-45-06-.07 (3) PERMIT REQUIRED (3) The owner or operator of an existing Class II or III injection well shall complete, sign and submit to the Commissioner an application for permit in conformance with this Chapter within six (6) months from the date of approval of these rules. The owner or operator must demonstrate to the satisfaction of the Commissioner that the existing well complies with all applicable rules of this Chapter.

Tennessee UIC Regulations 0400-45-06-.08 AUTHORIZATION BY PERMIT 1) Permit Application 2) Permit Application Processing 3) Duration of Permit Permits for Class II and III wells may be issued for a period up to the operating life of the facility. Each Class II or III well permit shall be reviewed at least once every five (5) years to determine whether it should be modified, revoked and reissued, or revoked as provided in paragraphs (7) and (8) of this rule. 4) Schedules of Compliance 5) Effect of a Permit 6) Transfer of Permit

Tennessee UIC Regulations 0400-45-06-.08 AUTHORIZATION BY PERMIT (cont.) 7) Public Notice and Public Comment 8) Modification or Revocation and Reissuance of Permits 9) Revocation of Permits or Denial of Renewal Application 10) Minor Modifications 11) Confidentiality of Information 12) Signatories to Applications and Reports 13) Permit Requirements (o)(2) Class II wells shall have a surety bond or cash bond for a total of $4,000 per well. If there is an existing $2,000 bond with the Tennessee Oil and Gas Board, the bond under this rule shall be $2,000. If no bond currently exists, the bond shall be for $4,000.

Tennessee UIC Regulations 0400-45-06-.09 GENERAL STANDARDS AND METHODS 1) Applicability 2) Supervisory Standards 3) Area of Review (fixed is 1 mile or use calculated zone of endangering influence) 4) Mechanical Integrity Standards 5) Corrective Action Standards (a)(1) Applicants for injection well permits shall identify the location of all known wells within the area of review which penetrate the injection zone, or in the case of Class II wells operating over the fracture pressure of the injection formation, all known wells within the area of review penetrating formations affected by the increase in pressure. For such wells which are improperly sealed, completed or abandoned, the applicant shall also submit a plan consisting of such steps or modifications as are necessary to prevent movement of fluids into USDWs. 6) Plugging and Abandonment Standards

Tennessee UIC Regulations 0400-45-06-.09 GENERAL STANDARDS AND METHODS Cont. 7. Placement of Sealing Materials 8. Special Conditions 9. Verification of Procedures 10. Evidence of Financial Responsibility 11. Power of Commissioner 12. Deed notification 13. Address requirements

Tennessee UIC Regulations 0400-45-06-.11 CLASS II WELLS 1. Permit Applications 2. Construction of Class II Wells 3. Casings 4. Cementing 5. Testing For Class II Wells 6. Monitoring Requirements 7. Commencement, Discontinuance, &Abandonment of Injection Wells 8. Reporting Requirements 9. Removal of Produced Water from Leases and Field Facilities 10. Disposition of Transported Produced Water 11. Existing Class II Enhanced Recovery Wells & Hydrocarbon Storage

Tennessee UIC Regulations 0400-45-06-.16 FEES FOR CLASS II INJECTION WELLS Application Review Fee $2,500.00 ** Permit Renewal Fee (Every Five Years) $1,000.00 Annual Maintenance Fee $500.00 Permit Modification and Reissuance Fee $250.00 0400-45-06.19 BONDS REQUIRED FOR PERMITTED WELLS

Tennessee UIC Regulations Next Steps Tennessee will have the program June 6 th We are developing a schedule with EPA for reviews 18 EPA permits for 26 wells 5 wells are due a MIT by December 4 wells EPA permit but not converted 3 wells EPA permit but not drilled Tennessee will review the files from EPA Contact the owner operator inspect the well and review paperwork from the operator. Will require the operator to submit information on Tennessee forms with next renewal or monitoring period

Tennessee UIC Regulations Next Steps Inspections All well drilled for Class II disposal, well workovers, mechanical integrity tests and plugging and abandonments will be witnessed.

Questions?

Scotty D. Sorrells P.G. Groundwater Management Section Division of Water Resources Drinking Water Unit 11 th Floor William R. Snodgrass- Tennessee Tower 312 Rosa L. Parks Avenue Nashville, Tennessee 37243-1102 1-888-891-TDEC (8332) or (615)532-9224 E-mail scotty.sorrells@tn.gov