California's Division of Oil, Gas, and Geothermal Resources (DOGGR) yesterday announced that it will review the state's Underground Injection Control (UIC) program. The action came two weeks after DOGGR ordered seven Bakersfield area oil companies to immediately shut down 11 waste water disposal wells that were permitted under the existing UIC program.
DOGGR's action is meant to ensure that the state program complies with the federal Safe Drinking Water Act. The regulations dealing with the oil industry's UIC practices have been in place for about 30 years. They were designed to ensure that waste water generated from crude oil production operations is not injected into water aquifers suitable for human or agricultural use.
The review will be done in conjunction with the U.S. Environmental Protection Agency (EPA). In recent years, EPA has expressed concerns about California's program and whether it was adequately protecting groundwater supplies. DOGGR and EPA will be reviewing previously approved wells, current approval practices, and the UIC rules themselves to ensure that they comply with state and federal laws and regulations.
DOGGR expects that it will take 12 to 18 months for the review process to be completed. Revisions to the regulations may be considered as a result of the investigation.
For those who are unfamiliar with how crude oil is produced, fluids brought to the surface from wells do not just contain crude oil. Tremendous volumes of water are also brought to the surface along with the crude (and sometimes significant amounts of natural gas as well). The amount of water (called produced water) is sometimes an order of magnitude or more than the volume of crude produced, presenting a water disposal problem. Under the UIC program, this water, and other fluids brought to the surface with it, may be injected back underground, typically into the same oil bearing formation from which it came.
Recently, in response to environmental concerns raised by the practice of hydraulic fracturing, or fracking, California adopted a new law, SB 4, which addressed various forms of well stimulation techniques used in the oil industry. While reviewing documents generated as a result of that law, DOGGR ordered the shutdown of the aforementioned wells. DOGGR said the reason was that it appeared some of the wells were injecting fluids into protected groundwater.
“We shut these wells down and ordered the operators to provide information and conduct testing to ensure human and environmental health and safety are not at risk,” said Steve Bohlen, State Oil and Gas Supervisor and head of DOGGR.
After reviewing information related to the 11 wells, DOGGR has since allowed two of them to resume operations. DOGGR is also working closely with the State Water Resources Control Board, the California Environmental Protection Agency, and the Central Valley Water Quality Control Board to ensure that water wells are not contaminated.
“In response to ongoing conversations with U.S. EPA, we have committed to a review and revision of the UICprogram, as necessary,” said Jason Marshall, Chief Deputy Director of the California Department of Conservation, of which DOGGR is a part. “The UIC Primacy Agreement is now over 30 years old and there are many changes in industry practices and technology that merit inclusion in any revision of UIC regulations,” Marshall added.