Sunday, June 22, 2008 7:35:08 PM
The Railroad Commission and Water Protection
(see 2004 to 2007 below)
The Texas Railroad Commission has rules in place to protect the state's ground and surface water - our rivers, lakes and aquifers.
Well construction guidelines require two layers of protection on wells that will produce oil or natural gas. The first layer is surface casing and cement, which acts as a protective sleeve through which deeper drilling will occur. The second layer is production casing and cement which is set and cemented to isolate the target formation.
Injection wells are required to have an additional layer of protection. This third layer consists of tubing and a packer through which the saltwater is pumped. Injection well permitting procedures are more stringent to promote the development of new disposal capacity in previously untapped interval below the Barnett Shale production zone. Injection is administratively restricted to not more than 25,000 barrels/day at an injection pressure of 0.5 psig. Shallow injection has more stringent requirements: the RRC has doubled the are of review aroudn proposed injection wells from 1/4 mile to 1/2 mile, reduced the maximum allowable injection pressure by 50% andlimited the maixmum injection rate for wells injecting in relative shallow intervals (approx. 4000' deep or less).
Injection wells are part of the RRC's UIC Program. Texas has the largest underground injection control (UIC) program in the U.S. By participating in this EPA program, Texas agrees to have requirements that are at least equal to the federal standards.
In addition to other testing required by the Commission, wells over 25 years old that have been inactive for a year or more are required to meet H-15 Testing Requirements before they can resume production.
The Commission's Statewide Rule (SWR) 8 outlines water protection requirements for oil and gas leases.
For instances when an incident may occur on a lease, statewide rule (SWR) 91 requires that the Total Petroleum Hydrocarbons (TPH) be cleaned up within one year. SWR 91 also allows for case-by-case handling of certain situtations.
When the time comes for a well to be plugged, the Commission requires through SWR 14 that tag plugs be set at the base of usable quality water.
Over the years, some wells have been abandoned and therefore become the state's responsibility to plug. The Oil Field Cleanup Fund (OFCUF) was established in 1983 to handle the expense of these pluggings and the Railroad Commission was designated to manage the program. From 1984 through February 2008, the Commission has plugged over 28,000 wells with over $146 million. The plugging efforts are expects to continue at a similar pace. Th program focuses on plugging orphaned wells that pose the greatest risk to public safety and the environment. These wells are identified the the High Risk Well Testing Program. From September 2001 through January 2008, over 18,000 wells were tested and evaluated. More emphasis has been placed on plugging orphaned bay and offshore wells. In FY 2007, approximately $4.2 million was spent plugging 18 wells in the Gulf of Mexico.
In addition to the above rules and regulations, the Commission has made efforts to reach out to Legislators, local governments and the general public. These outreach efforts include attendance at town halls and presentations at other community meetings by Commission Staff and/or Commissioners. The internet has allowed the Commission to broaden its outreach efforts by publishing a Barnett Shale web page, FAQ's for Saltwater Disposal Wells, information about NORM and posting other manuals and documents.
The Commission participates in several grant programs and other agencies' programs. These include the RRC-TCEQ Saltwater Minimization Projects, EPA Brownfields grant program, and EPA Non-Point Source grant program. The RRC also manages an Operator Clean-up Program and a Voluntary Cleanup Program.
The Recent History
2000
GRANTS AND FUNDING: Williams supports Texas Resource Preservation Fund (1/14/00)
2001
RULES: Commission revises well-plugging standards to place greater emphasis on wells threatening subsurface water (11/20/01)
2002
VOLUNTARY CLEANUP PROGRAM RULES: Effective June, 2002, the Commission adopted regulations relating to the Voluntary Cleanup Program. This program provides incentives to remediate Oil & Gas related pollution by participants as long as they did not cause or contribute to the contamination. Applicants to the program receive a release of liability to the state in exchange for a successful cleanup.
RULES: Williams calls for working group to examine SWR 8 and amendments (2/19/02)
BONDING: Bonding helps protect Texas water (8/1/02)
WATER RECYCLING: Williams partners with Texas A&M to increase state's water supply (9/13/02)
BONDING: Williams vows to continue protecting Texas water (10/16/02)
2003
SITE REMEDIATION: An interceptor trench located in Sinton, Texas, northwest of Corpus Christi, was installed Spring 2003 to capture crude oil seeping into Chiltipin Creek, which drains into Copano Bay. The trench has captured 956 bbl (40,152 gal) of crude oil since June 2003 and stopped the crude oil seep as designed.
SWR 8: RRC issues fines for rules violations, including eleven for SWR 8 (5/6/03)
SWR 8: Six companies penzlized for violations of SWR 8 (5/20/03)
SWR 8: Three companies penalized for violations of SWR 8 (6/11/03)
SWR 8: Six companies penalized for violations of SWR 8 (6/25/03)
SWR 8: Seven companies penalized for violations of SWR 8 (7/9/03)
SWR 8: Four Companies penalized for violations of SWR 8 (7/22/03)
SWR 8: Mesquite Energy penalized for violation of SWR 8, other rules (8/5/03)
OFCU: 87 well plugging project helps protect Texas lakes, rivers and aquifers (8/25/03)
SWR 8: Commission penalizes ten companies for violations of SWR 8 (10/7/03)
SITE REMEDIATION: Commission funds Chocolate Bayou cleanup (10/8/03)
SWR 8: Two companies penalized for violation of SWR 8 (10/21/03)
RECOGNITION: The State Review of Oil and Natural Gas Environmental Regulations (STRONGER) Board gives high marks to RRC for environmental response programs (10/27/03)
SWR 8: Five companies penalized for violations of SWR 8 (11/13/03)
OFCU: Commission approves well pluggings (11/25/03)
OFCU: RRC approves funding for multiple well-plugging projects across the state (12/30/03)
2004
BRINE MINING PROGRAM: On February 9, 2004, the U.S. Environmental Protection Agency (EPA) approved the RRC’s application for delegation of the UIC Class III Brine Mining Well program of the federal Safe Drinking Water Act. The approval give the RRC primacy in the program.
Bonding: The "universal bonding" and "bay and offshore bonding" rules went into effect on 9/1/2004.
o Universal bonding involved the transition of all Oil & Gas Operators from a generally non-bonded status (paying cash fees in lieu of posting financial security), to bonded status by requiring the posting of bonds, letters of credit or cash deposits for most Oil & Gas regulated activities.
o Bay and Offshore bonding went beyond that for operators who had wells located in inland, bay or offshore water of the state, requiring them to post additional amounts in particular for non-producing wells.
o Under these two programs, current operators as of 1/29/08 have posted an aggregate total of $332.3 million in bonds, letters of credit and cash deposits that can be drawn on in the event of operator default.
o Commerical disposal wells are included in the facilities that are required to have financial assurance
o Note: Other than some tweaks and exemptions in the 2005 session, there haven't been any changes to the basic structure of P-5 bonding since then, although the situation continues to be monitored and further solutions explored.
SWR 8: Bad operator punished for violating SWR 8 (1/6/04)
SWR 8: Four operators penalized for violations of SWR 8 (1/27/04)
GRANTS AND FUNDING: RRC awards funding for Brownfields Assessment in Texas coastal bend (2/12/04)
GRANTS AND FUNDING : RRC pursues EPA grant to address impaired Texas waterways (2/24/04)
SITE REMEDIATION: Williams inspects state's largest candidate site for state-funded cleanup (3/5/04)
SWR 8: Three violators of SWR 8 penalized (3/11/04)
SITE REMEDIATION: RRC authorizes $2.8 million for cleanup of 1980's saltwater disposal facility (3/11/04)
SITE REMEDIATION: RRC asks industry to install water lines in Tomball after contamination from an unknown source impacts water quality (4/8/04)
WATER RECYCLING: Dan Meeker Management, Inc. (later, the Barnett Shale Water Conservation Co.) was granted authority on July 2, 2004, to dispose of produced water and drilling fluid into the City of For Worth’s wastewater facility provided the TCEQ and the facility owner or operator concur. The discharge of frac flow-back water into the City of Fort Worth sanitary sewer was initiated in October 2006. As of February 11, 2008, the pilot project was ended because it became too expensive for the operator - the fees for treatment to The Barnett Shale Water Conservation Company and to the City of Fort Worth were the same as hauling off for disposal.
2005
WATER RECYCLING: On January 25, 2005, the Commissioners authorized Fountain Quail Water Management to conduct a five-well recycling pilot project to treat fracture flow-back fluids by distillation for re-use in fracturing additional wells.
VOLUNTARY CLEANUP PROGRAM: ABANDONDED WASTE DISPOSAL SITE TO BE PART OF FUTURE ANDREWS BIRD OBSERVATORY & CITY PARK SYSTEM (5/23/05)
BONDING: Requiring adequate financial assurance is essential to protecting water (6/21/05)
WATER RECYCLING: On September 7, 2005, the Commissioners authorized Scott Environmental Services, Inc. to treat and re-use fresh water based drilling mud and cuttings. Documents indicate the trial run was successfully completed and analytical results indicate technical and environmental tests are satisfied.
2006
WATER RECYCLING: On April 18, 2006, the Commissioners authorized A N.E.W. Rock Company to treat and re-use water based drilling mud and cuttings and oil based drilling mud and cuttings. The permit expires April 11, 2011.
COMMERCIAL RECYCLING RULES : In December of 2006, the Commission adopted rules regarding minimum permitting and operating standards and requirements for mobile and stationary commercial facilities that recycle oil and gas wastes under the jurisdiction of the Commission.
SITE REMEDIATION: RRC begins $700,000 project to identify source of salt seep in Petronila Creek watershed (3/7/06)
WATER RECYCLING: On April 18, 2006, the Commissioners authorized DTE Gas Resources to perform a pilot project to treat and re-use fracture flow-back fluid at two Barnett Shale gas well drill sites in Tarrant and/or Jack Counties using on-site separation and filtration. The permit expires on April 18, 2008.
VOLUNTARY CLEANUP PROGRAM: RRC's VCP HELPS CORPUS CHRISTI COMPANY PREPARE FORMER OILFIELD SITE FOR VETERAN’S CEMETERY (10/26/06)
WATER RECYCLING: On October 30, 2006, the Commissioners authorized Fountain Quail on a permanent basis to treat fracture flow-back fluid from the Barnett Shale for re-use using mobile distillation units.
2007
UNDERGROUND HYDROCARBON STORAGE REGULATIONS: In order to reduce the possibility of explosion and fire at such facilities and enhance the safety of these facilities, the RRC adopted new rules effective January 30, 2007 regarding the creation, operation, and maintenance of underground hydrocarbon storage facilities. The amendments incorporated new requirements for integrity management of surface piping, location of emergency shutdown valves, fire suppression capabilities, data acquisition, and record retention.
STUDIES: Coordinated with the Texas Water Development Board in the 2007 Northern Trinity Aquifer study.
WATER RECYCLING: On May 10, 2007, the Commissioners amended authority for Scott Environmental to store, handle, treat and re-use fresh water base and oil base drilling mud and cuttings generated in the State of Texas for re-use for the following load-bearing structures in the State of Texas: lease roads, drilling pads, tank batteries, compressor station pads, and county roads. The permit expires on September 7, 2010.
WATER RECYCLING: On July 31, 2007, Devon has requested renewal of a previous authorization for a pilot project to treat and reuse fracture flow-back fluid using similar technologies, but with a different company than originally authorized. On September 21, 2007, the Commissioners renewed and amended authorization for Devon to perform a pilot project to store, handle, treat and re-use fracture flow-back fluid from ten to fifteen Barnett Shale gas well drill sites. The effective date of the permit is September 11, 2007. The permit expires on March 9, 2008.
H-10 online filing: in September of 2007, the RRC implemented H-10 online filing which includes automated identification of operating violations so problems can be addressed before they become pollution problems.
INSPECTIONS: An increased emphasis has been placed on inspecting and witnessing activities that pose the greatest risk to pubic safety and the environment. In FY 2007 new records were set in the following areas: (1) Inspection of Disposal and Injection Wells/Facilities – 8,195 inspections; (2) Witnessing mechanical–integrity tests of disposal and injection wells – 10,635 tests witnessed; (3) Witnessing surface casing jobs – 2,753 jobs witnessed. Other activities that were performed at a high level include inspection of commercial injection and disposal facilities, drilling rig inspections, and witnessing operator well plugging jobs.
2008
SITE REMEDIATION: A recovery trench was installed spring of 2008 to remove an estimated 40-80 barrels a day of saline water coming from the West O'Daniel Seep.
(see 2004 to 2007 below)
The Texas Railroad Commission has rules in place to protect the state's ground and surface water - our rivers, lakes and aquifers.
Well construction guidelines require two layers of protection on wells that will produce oil or natural gas. The first layer is surface casing and cement, which acts as a protective sleeve through which deeper drilling will occur. The second layer is production casing and cement which is set and cemented to isolate the target formation.
Injection wells are required to have an additional layer of protection. This third layer consists of tubing and a packer through which the saltwater is pumped. Injection well permitting procedures are more stringent to promote the development of new disposal capacity in previously untapped interval below the Barnett Shale production zone. Injection is administratively restricted to not more than 25,000 barrels/day at an injection pressure of 0.5 psig. Shallow injection has more stringent requirements: the RRC has doubled the are of review aroudn proposed injection wells from 1/4 mile to 1/2 mile, reduced the maximum allowable injection pressure by 50% andlimited the maixmum injection rate for wells injecting in relative shallow intervals (approx. 4000' deep or less).
Injection wells are part of the RRC's UIC Program. Texas has the largest underground injection control (UIC) program in the U.S. By participating in this EPA program, Texas agrees to have requirements that are at least equal to the federal standards.
In addition to other testing required by the Commission, wells over 25 years old that have been inactive for a year or more are required to meet H-15 Testing Requirements before they can resume production.
The Commission's Statewide Rule (SWR) 8 outlines water protection requirements for oil and gas leases.
For instances when an incident may occur on a lease, statewide rule (SWR) 91 requires that the Total Petroleum Hydrocarbons (TPH) be cleaned up within one year. SWR 91 also allows for case-by-case handling of certain situtations.
When the time comes for a well to be plugged, the Commission requires through SWR 14 that tag plugs be set at the base of usable quality water.
Over the years, some wells have been abandoned and therefore become the state's responsibility to plug. The Oil Field Cleanup Fund (OFCUF) was established in 1983 to handle the expense of these pluggings and the Railroad Commission was designated to manage the program. From 1984 through February 2008, the Commission has plugged over 28,000 wells with over $146 million. The plugging efforts are expects to continue at a similar pace. Th program focuses on plugging orphaned wells that pose the greatest risk to public safety and the environment. These wells are identified the the High Risk Well Testing Program. From September 2001 through January 2008, over 18,000 wells were tested and evaluated. More emphasis has been placed on plugging orphaned bay and offshore wells. In FY 2007, approximately $4.2 million was spent plugging 18 wells in the Gulf of Mexico.
In addition to the above rules and regulations, the Commission has made efforts to reach out to Legislators, local governments and the general public. These outreach efforts include attendance at town halls and presentations at other community meetings by Commission Staff and/or Commissioners. The internet has allowed the Commission to broaden its outreach efforts by publishing a Barnett Shale web page, FAQ's for Saltwater Disposal Wells, information about NORM and posting other manuals and documents.
The Commission participates in several grant programs and other agencies' programs. These include the RRC-TCEQ Saltwater Minimization Projects, EPA Brownfields grant program, and EPA Non-Point Source grant program. The RRC also manages an Operator Clean-up Program and a Voluntary Cleanup Program.
The Recent History
2000
GRANTS AND FUNDING: Williams supports Texas Resource Preservation Fund (1/14/00)
2001
RULES: Commission revises well-plugging standards to place greater emphasis on wells threatening subsurface water (11/20/01)
2002
VOLUNTARY CLEANUP PROGRAM RULES: Effective June, 2002, the Commission adopted regulations relating to the Voluntary Cleanup Program. This program provides incentives to remediate Oil & Gas related pollution by participants as long as they did not cause or contribute to the contamination. Applicants to the program receive a release of liability to the state in exchange for a successful cleanup.
RULES: Williams calls for working group to examine SWR 8 and amendments (2/19/02)
BONDING: Bonding helps protect Texas water (8/1/02)
WATER RECYCLING: Williams partners with Texas A&M to increase state's water supply (9/13/02)
BONDING: Williams vows to continue protecting Texas water (10/16/02)
2003
SITE REMEDIATION: An interceptor trench located in Sinton, Texas, northwest of Corpus Christi, was installed Spring 2003 to capture crude oil seeping into Chiltipin Creek, which drains into Copano Bay. The trench has captured 956 bbl (40,152 gal) of crude oil since June 2003 and stopped the crude oil seep as designed.
SWR 8: RRC issues fines for rules violations, including eleven for SWR 8 (5/6/03)
SWR 8: Six companies penzlized for violations of SWR 8 (5/20/03)
SWR 8: Three companies penalized for violations of SWR 8 (6/11/03)
SWR 8: Six companies penalized for violations of SWR 8 (6/25/03)
SWR 8: Seven companies penalized for violations of SWR 8 (7/9/03)
SWR 8: Four Companies penalized for violations of SWR 8 (7/22/03)
SWR 8: Mesquite Energy penalized for violation of SWR 8, other rules (8/5/03)
OFCU: 87 well plugging project helps protect Texas lakes, rivers and aquifers (8/25/03)
SWR 8: Commission penalizes ten companies for violations of SWR 8 (10/7/03)
SITE REMEDIATION: Commission funds Chocolate Bayou cleanup (10/8/03)
SWR 8: Two companies penalized for violation of SWR 8 (10/21/03)
RECOGNITION: The State Review of Oil and Natural Gas Environmental Regulations (STRONGER) Board gives high marks to RRC for environmental response programs (10/27/03)
SWR 8: Five companies penalized for violations of SWR 8 (11/13/03)
OFCU: Commission approves well pluggings (11/25/03)
OFCU: RRC approves funding for multiple well-plugging projects across the state (12/30/03)
2004
BRINE MINING PROGRAM: On February 9, 2004, the U.S. Environmental Protection Agency (EPA) approved the RRC’s application for delegation of the UIC Class III Brine Mining Well program of the federal Safe Drinking Water Act. The approval give the RRC primacy in the program.
Bonding: The "universal bonding" and "bay and offshore bonding" rules went into effect on 9/1/2004.
o Universal bonding involved the transition of all Oil & Gas Operators from a generally non-bonded status (paying cash fees in lieu of posting financial security), to bonded status by requiring the posting of bonds, letters of credit or cash deposits for most Oil & Gas regulated activities.
o Bay and Offshore bonding went beyond that for operators who had wells located in inland, bay or offshore water of the state, requiring them to post additional amounts in particular for non-producing wells.
o Under these two programs, current operators as of 1/29/08 have posted an aggregate total of $332.3 million in bonds, letters of credit and cash deposits that can be drawn on in the event of operator default.
o Commerical disposal wells are included in the facilities that are required to have financial assurance
o Note: Other than some tweaks and exemptions in the 2005 session, there haven't been any changes to the basic structure of P-5 bonding since then, although the situation continues to be monitored and further solutions explored.
SWR 8: Bad operator punished for violating SWR 8 (1/6/04)
SWR 8: Four operators penalized for violations of SWR 8 (1/27/04)
GRANTS AND FUNDING: RRC awards funding for Brownfields Assessment in Texas coastal bend (2/12/04)
GRANTS AND FUNDING : RRC pursues EPA grant to address impaired Texas waterways (2/24/04)
SITE REMEDIATION: Williams inspects state's largest candidate site for state-funded cleanup (3/5/04)
SWR 8: Three violators of SWR 8 penalized (3/11/04)
SITE REMEDIATION: RRC authorizes $2.8 million for cleanup of 1980's saltwater disposal facility (3/11/04)
SITE REMEDIATION: RRC asks industry to install water lines in Tomball after contamination from an unknown source impacts water quality (4/8/04)
WATER RECYCLING: Dan Meeker Management, Inc. (later, the Barnett Shale Water Conservation Co.) was granted authority on July 2, 2004, to dispose of produced water and drilling fluid into the City of For Worth’s wastewater facility provided the TCEQ and the facility owner or operator concur. The discharge of frac flow-back water into the City of Fort Worth sanitary sewer was initiated in October 2006. As of February 11, 2008, the pilot project was ended because it became too expensive for the operator - the fees for treatment to The Barnett Shale Water Conservation Company and to the City of Fort Worth were the same as hauling off for disposal.
2005
WATER RECYCLING: On January 25, 2005, the Commissioners authorized Fountain Quail Water Management to conduct a five-well recycling pilot project to treat fracture flow-back fluids by distillation for re-use in fracturing additional wells.
VOLUNTARY CLEANUP PROGRAM: ABANDONDED WASTE DISPOSAL SITE TO BE PART OF FUTURE ANDREWS BIRD OBSERVATORY & CITY PARK SYSTEM (5/23/05)
BONDING: Requiring adequate financial assurance is essential to protecting water (6/21/05)
WATER RECYCLING: On September 7, 2005, the Commissioners authorized Scott Environmental Services, Inc. to treat and re-use fresh water based drilling mud and cuttings. Documents indicate the trial run was successfully completed and analytical results indicate technical and environmental tests are satisfied.
2006
WATER RECYCLING: On April 18, 2006, the Commissioners authorized A N.E.W. Rock Company to treat and re-use water based drilling mud and cuttings and oil based drilling mud and cuttings. The permit expires April 11, 2011.
COMMERCIAL RECYCLING RULES : In December of 2006, the Commission adopted rules regarding minimum permitting and operating standards and requirements for mobile and stationary commercial facilities that recycle oil and gas wastes under the jurisdiction of the Commission.
SITE REMEDIATION: RRC begins $700,000 project to identify source of salt seep in Petronila Creek watershed (3/7/06)
WATER RECYCLING: On April 18, 2006, the Commissioners authorized DTE Gas Resources to perform a pilot project to treat and re-use fracture flow-back fluid at two Barnett Shale gas well drill sites in Tarrant and/or Jack Counties using on-site separation and filtration. The permit expires on April 18, 2008.
VOLUNTARY CLEANUP PROGRAM: RRC's VCP HELPS CORPUS CHRISTI COMPANY PREPARE FORMER OILFIELD SITE FOR VETERAN’S CEMETERY (10/26/06)
WATER RECYCLING: On October 30, 2006, the Commissioners authorized Fountain Quail on a permanent basis to treat fracture flow-back fluid from the Barnett Shale for re-use using mobile distillation units.
2007
UNDERGROUND HYDROCARBON STORAGE REGULATIONS: In order to reduce the possibility of explosion and fire at such facilities and enhance the safety of these facilities, the RRC adopted new rules effective January 30, 2007 regarding the creation, operation, and maintenance of underground hydrocarbon storage facilities. The amendments incorporated new requirements for integrity management of surface piping, location of emergency shutdown valves, fire suppression capabilities, data acquisition, and record retention.
STUDIES: Coordinated with the Texas Water Development Board in the 2007 Northern Trinity Aquifer study.
WATER RECYCLING: On May 10, 2007, the Commissioners amended authority for Scott Environmental to store, handle, treat and re-use fresh water base and oil base drilling mud and cuttings generated in the State of Texas for re-use for the following load-bearing structures in the State of Texas: lease roads, drilling pads, tank batteries, compressor station pads, and county roads. The permit expires on September 7, 2010.
WATER RECYCLING: On July 31, 2007, Devon has requested renewal of a previous authorization for a pilot project to treat and reuse fracture flow-back fluid using similar technologies, but with a different company than originally authorized. On September 21, 2007, the Commissioners renewed and amended authorization for Devon to perform a pilot project to store, handle, treat and re-use fracture flow-back fluid from ten to fifteen Barnett Shale gas well drill sites. The effective date of the permit is September 11, 2007. The permit expires on March 9, 2008.
H-10 online filing: in September of 2007, the RRC implemented H-10 online filing which includes automated identification of operating violations so problems can be addressed before they become pollution problems.
INSPECTIONS: An increased emphasis has been placed on inspecting and witnessing activities that pose the greatest risk to pubic safety and the environment. In FY 2007 new records were set in the following areas: (1) Inspection of Disposal and Injection Wells/Facilities – 8,195 inspections; (2) Witnessing mechanical–integrity tests of disposal and injection wells – 10,635 tests witnessed; (3) Witnessing surface casing jobs – 2,753 jobs witnessed. Other activities that were performed at a high level include inspection of commercial injection and disposal facilities, drilling rig inspections, and witnessing operator well plugging jobs.
2008
SITE REMEDIATION: A recovery trench was installed spring of 2008 to remove an estimated 40-80 barrels a day of saline water coming from the West O'Daniel Seep.
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