Tennessee Underground Injection Control Program...

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.

•TDEC is authorized to inspect any facility subject to the UIC program

•Types of inspections vary, based on status of wells and facility

Mission of the UIC Program

State UIC Program Working With Various Partners

•Tennessee Department Of Transportation •Ground Water Protection•Municipal governments•Multi-Section SeparateStorm 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

"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) a "well" used for the emplacement of fluids;

(b) a "subsurface fluid distribution system;

(c) an "improved sinkhole"; or

(d) any other device designed, constructed constructed or used to emplace fluids intothe subsurface, except as provided in rule1200-4-6-.03(3).

2000 Definition of Injection Well

Historical uses of injection wells in Tennessee

• 1966 Dupont chemical –New Johnsonville 6 wells drilledinjection 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 ftclosed 1990

• Currently there are no Class I injection wells in Tennessee

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

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

Types of UIC Wells cont.

•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

Gauge measuringInjection pressureWaste influent

Gauge measuringAnnulus pressureConductor casingSurface casingCement

Protection casing

Injection tubingFluid-filled pressurized area

Perforations

Cement

Approximatebase of USDW

Confining Zone

Confining Zone

Injection Zone

Class I 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

WELLHEADInjection pressure gauge

Injected fluid

Annular access

Base of protected water

Drilling mud

Bottom of surface casing

TubingPackingPerforationsBottom of casing

Annular space

Annulus pressure gaugeValves

Confining Zone

Class II 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

Cement

WellheadWellhead

Centralizer

Casing

Drill holeCementbasket

Plug (drilled out after Cementing)

Cap

Slotted screen or pipe

Mineralized zone

Cement

Cement

SurfaceCasing

Tubing-casingannulus

Top of salt

ProductionCasing

Tubing

Salt cavern

In Situ Leaching WellClass III 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 IV 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

Class V wells

•Industrial/commercial waste and cooling waters into wells, septic systems or sinkholes (e.g., industrial facilities,car washes, funeral homes, ect.)

•Storm water discharges via wells or improved sinkholes (modified) sinkholes

•Floor drains at commercial and industrial facilities that discharge to subsurface fluid distribution systems

•Geothermal heat pump wells for commercial facilities

•Mine backfill via wells

•Large capacity septic systems

•Aquifer recharge wells

Different Types of Class V Systems

•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

Class VI wells

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 Standards0400-45-06-.06 Classification of Injection Wells0400-45-06-.07 Permit Required0400-45-06-.08 Authorization by Permit For Injection Wells Not

Authorized By Rule

0400-45-06-.09 General Standards and Methods0400-45-06-.10 Class I Wells0400-45-06-.11 Class II Wells0400-45-06-.12 Class III Wells0400-45-06-.13 Class IV Wells0400-45-06-.14 Class V Wells0400-45-06-.15 Fees for Class I Injection Wells0400-45-06-.16 Fees For Class II Injection Wells0400-45-06-.17 Fees For Class III Injection Wells0400-45-06-.18 Fees For Class V Injection Wells0400-45-06-.19 Bonds Required for Permitted WellsAppendix A

Tennessee UIC Regulations Cont.


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 undergroundsource of drinking water indicates the movement of any contaminant into theunderground source of drinking water, except as authorized under this rule, theCommissioner shall prescribe such additional requirements for construction, correctiveaction, operation, monitoring, or reporting (including closure of the injection well) asare necessary to prevent such movement. In the case of wells authorized by permit, theCommissioner may impose additional requirements by modifying the permit inaccordance with Rule paragraph (8) of Rule 0400-45-06-.08 or may terminate thepermit in accordance with paragraph (9) of Rule 0400-45-06-.08. Additionally, theCommissioner may assess civil penalties for all permit or rule violations in accordancewith T.C.A § 69-3-115.


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 parameterssuch as permeability and porosity shall be considered by the Commissioner, to the extent such information is available.


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.


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 withinsix (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.


0400-45-06-.08 AUTHORIZATION BY PERMIT1) Permit Application 2) Permit Application Processing3) Duration of Permit

Permits for Class II and III wells may be issued for a period upto the operating life of the facility. Each Class II or III wellpermit shall be reviewed at least once every five (5) years todetermine whether it should be modified, revoked and reissued,or revoked as provided in paragraphs (7) and (8) of this rule.

4) Schedules of Compliance5) Effect of a Permit6) Transfer of Permit


0400-45-06-.08 AUTHORIZATION BY PERMIT (cont.)7) Public Notice and Public Comment 8) Modification or Revocation and Reissuance of Permits9) Revocation of Permits or Denial of Renewal Application10) Minor Modifications11) Confidentiality of Information12) Signatories to Applications and Reports13) Permit Requirements

(o)(2) Class II wells shall have a surety bond or cash bond for atotal of $4,000 per well. If there is an existing $2,000bond with the Tennessee Oil and Gas Board, the bondunder this rule shall be $2,000. If no bond currentlyexists, the bond shall be for $4,000.


0400-45-06-.09 GENERAL STANDARDS AND METHODS1) Applicability 2) Supervisory Standards3) Area of Review (fixed is 1 mile or use calculated zone of endangering influence)4) Mechanical Integrity Standards5) Corrective Action Standards

(a)(1) Applicants for injection well permits shall identify the location of allknown wells within the area of review which penetrate the injection zone, orin the case of Class II wells operating over the fracture pressure of theinjection formation, all known wells within the area of review penetratingformations affected by the increase in pressure. For such wells which areimproperly sealed, completed or abandoned, the applicant shall also submit aplan consisting of such steps or modifications as are necessary to preventmovement of fluids into USDWs.

6) Plugging and Abandonment Standards


0400-45-06-.09 GENERAL STANDARDS AND METHODS Cont.7. Placement of Sealing Materials8. Special Conditions9. Verification of Procedures10. Evidence of Financial Responsibility11. Power of Commissioner12. Deed notification13. Address requirements


0400-45-06-.11 CLASS II WELLS1. Permit Applications2. Construction of Class II Wells3. Casings4. Cementing5. Testing For Class II Wells6. Monitoring Requirements7. Commencement, Discontinuance, &Abandonment of Injection Wells8. Reporting Requirements9. Removal of Produced Water from Leases and Field Facilities10. Disposition of Transported Produced Water11. Existing Class II Enhanced Recovery Wells & Hydrocarbon Storage


0400-45-06-.16 FEES FOR CLASS II INJECTION WELLS

Application Review Fee $2,500.00 **Permit Renewal Fee (Every Five Years) $1,000.00Annual Maintenance Fee $500.00Permit Modification and Reissuance Fee $250.00

0400-45-06.19 BONDS REQUIRED FOR PERMITTED WELLS

Tennessee UIC RegulationsNext Steps

Tennessee will have the program June 6th

We are developing a schedule with EPA for reviews18 EPA permits for 26 wells5 wells are due a MIT by December4 wells EPA permit but not converted3 wells EPA permit but not drilled

Tennessee will review the files from EPAContact the owner operator inspect the well and review paperwork from the operator.Will require the operator to submit information on Tennessee formswith next renewal or monitoring period

Tennessee UIC RegulationsNext Steps

InspectionsAll well drilled for Class II disposal, well workovers, mechanical integrity tests and plugging and abandonmentswill be witnessed.

Questions?

Scotty D. Sorrells P.G.Groundwater Management SectionDivision of Water ResourcesDrinking Water Unit11th Floor William R. Snodgrass-Tennessee Tower312 Rosa L. Parks AvenueNashville, Tennessee 37243-11021-888-891-TDEC (8332) or (615)532-9224E-mail [email protected]

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