Louisiana Underground Injection Control Program Workshop Introduction

Louisiana Underground Injection Control Program Workshop Introduction Joseph S. Ball, Jr.

Underground Injection Control (UIC) Program March 23, 1982 ― Under provisions of the Safe Drinking Water Act of 1974, the U.S. Environmental Protection Agency (USEPA) delegated Louisiana with full permitting and enforcement authority (primacy) of the state’s UIC Program. Semi-annual USEPA oversight. Goal is to protect Underground Sources of Drinking Water (USDW) and other state natural resources from endangerment by regulating the subsurface emplacement of fluids through the use of well injection by: Processing applications for various subsurface injection projects. Conduct field surveillance and enforcement at injection well sites and facilities. Test injection wells for mechanical integrity. Monitor injection well operations (cradle-to-grave).

Underground Source of Drinking Water An Underground Source of Drinking Water is defined by the United States Environmental Protection Agency as: 1. an aquifer or its portion which supplies any public water system; or 2. an aquifer or its portion which contains a sufficient quantity of ground water to supply a public water system; and a. currently supplies drinking water for human consumption; or b. contains fewer than 10,000 mg/l total dissolved solids and which is not an exempted aquifer.

Regulatory Classes of Injection Wells Class I Industrial (hazardous or nonhazardous) or Municipal Waste Class II Oil and Gas Waste, Enhanced Recovery of Hydrocarbons, or Hydrocarbon Storage in a Salt Cavern Class III Mineral Solution Mining (salt, sulfur, etc.) Class IV Wells injecting Hazardous or Radioactive Waste into or above a USDW. Banned unless authorized as a RCRA or CERCLA cleanup. Class V Class VI Wells not covered under any other Class (e.g., aquifer remediation, heat pump/ac return flow well, etc.) Carbon Dioxide (CO2 ) Sequestration

Injection & Mining Division - Regulations The basic regulations of the Office of Conservation are a series of documents called Statewide Orders. These Orders form the backbone of the regulatory scheme and provide structure for operational requirements. The regulations are lawfully codified in the Louisiana Administrative Code and are prefixed by the letters LAC. Louisiana Administrative Code Statewide Order Subject of Regulation LAC 43:XIX.Chapter 3 Statewide Order No. 29-B, Chapter 3 Onsite storage, treatment and disposal of oilfield waste. Primarily oilfield pit regulations, but also has some general requirements for Class II disposal wells LAC 43:XIX.Chapter 4 Statewide Order No. 29-B, Chapter 4 General regulations for a Class II produced fluids disposal well LAC 43:XIX.Chapter 5 Statewide Order No. 29-B, Chapter 5 Regulations specific to commercial oilfield waste facilities LAC 43:XVII.Chapter 1 Statewide Order No. 29-N-1 Class I Nonhazardous Industrial Waste, Class III Mineral Solution Mining, Class IV, Class V, Class VI LAC 43:XVII.Chapter 2 Statewide Order No. 29-N-2 Class I Hazardous Industrial Waste LAC 43:XVII.Chapter 3 Statewide Order No. 29-M Class II Hydrocarbon Storage in Salt Dome Caverns LAC 43:XVII.Chapter 31 Statewide Order No. 29-M-2 Class II Disposal of Oilfield Waste in Solution-Mined Salt Caverns

Fee Schedule at LAC 43:XIX.Chapter 7 (including application fees) Commercial Class I 1,264 Commercial Class II 631 Noncommercial Injection Well 252 Amend Permit to Drill (amend, alter, or change a permit after its issuance) Well Workovers 126 FREE

Two-Part Permitting Process Part I: Permit-to-Construct: Public Notice of Application. Usually a Notice of Intent to file. Public hearing is not generally required, but will be held if requested. Administrative Review (properly completed forms, required documents, compliance history, financial responsibility, etc.) Technical Review to assure that well constructed to prevent movement of fluids into USDW’s. (hydrology, geology, well construction and operation, area-of-review, corrective action, etc.). Notice of Application Deficiency if additional data needed. Permit-to-Construct issued when the application is administratively complete

APPLICANT PREPARES & SUBMITS APPLICATION TO IMD IMD ENTERS APPL. INTO SONRIS, ASSIGNS APPL. NO., & SENDS RECEIPT LETTER CONDUCT AREA OF REVIEW SEARCH SUBMISSION COMPLETE? NO Regulatory & Technical Review Phase of Injection Well Application Process YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES GEOLOGY REVIEW COMPLETE? NO YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES ENGINEERING REVIEW COMPLETE? NO YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES SEND ADMINISTRATIVE NOTICE OF DEFICIENCIES TO APPLICANT SEND GEOLOGICAL’S NOTICE OF DEFICIENCIES TO APPLICANT SEND ENGINEERING’S NOTICE OF DEFICIENCIES TO APPLICANT UNABLE TO ADDRESS NOD DENY APPLICATION UNABLE TO ADDRESS NOD DENY APPLICATION UNABLE TO ADDRESS NOD DENY APPLICATION

APPLICANT PREPARES & SUBMITS APPLICATION TO IMD IMD ENTERS APPL. INTO SONRIS, ASSIGNS APPL. NO., & SENDS RECEIPT LETTER SUBMISSION COMPLETE? NO Regulatory & Technical Review Phase of Injection Well Application Process CONDUCT AREA OF REVIEW SEARCH YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES GEOLOGY REVIEW COMPLETE? NO YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES ENGINEERING REVIEW COMPLETE? NO Public Review Phase of Injection Well Application Process YES APPLICANT RESPONDS TO NOTICE OF DEFICIENCIES SEND ADMINISTRATIVE NOTICE OF DEFICIENCIES TO APPLICANT SEND GEOLOGICAL’S NOTICE OF DEFICIENCIES TO APPLICANT SEND ENGINEERING’S NOTICE OF DEFICIENCIES TO APPLICANT UNABLE TO ADDRESS NOD DENY APPLICATION UNABLE TO ADDRESS NOD DENY APPLICATION UNABLE TO ADDRESS NOD DENY APPLICATION PUBLIC HEARING? NO YES GIVE PUBLIC NOTICE AND HOLD PUBLIC HEARING PERMITTABLE CONSIDERING PUBLIC COMMENTS? YES NO DENY APPLCATION ISSUE APPROVAL-TOCONSTRUCT

Two-Part Permitting Process Part II: Permit-to-Inject: Technical evaluation of well construction and completion report. Was the well completed as permitted? Well or reservoir tests. Field inspection reports, well mechanical integrity tests. If needed, well operator performs corrective action. Permit-to-Inject issued with operational restrictions as Maximum Authorized Surface Injection Pressure (MASIP), injection rate/volume, frequency for well or reservoir testing, etc.

When to Publish a Public Notice Well Type Timing of Public Notice Class I Noncommercial Injection and Mining Division (IMD) publishes after application deemed complete Class II Saltwater Disposal for oil and gas operations Applicant publishes Notice of Intent at least 15 days prior to filing application Class II Saltwater Disposal for salt cavern operations Applicant publishes notice of application filing within 30 days from the date of receipt of the application by IMD (after receipt of application number) Public notice not required. Public hearing is required Class II Enhanced Recovery for Office of Conservation’s approval of an enhanced recovery project. Only approves project, not UIC well.

When to Publish a Public Notice Well Type Timing of Public Notice Class II Commercial Exploration & Production Waste New Facility: Notice of Intent at least 30 days prior to filing the application Refer to LAC 43:XIX.519.B and 529.B for details Existing Facility: Notice of Intent at least 15 days prior to filing an application Class II Hydrocarbon Storage in Salt Dome Applicant publishes Notice of Intent at least 30 days but no more than 180 days before filing application Class III Solution Mining Applicant publishes Notice of Intent at least 30 days but no more than 180 days before filing application Class V Not required Class VI CO2 Sequestration Injection and Mining Division publishes after application deemed complete

UIC Well Application Forms Well Type UIC Form Class I UIC-1 UIC-2 SWD Conversion CLASS II Saltwater Disposal UIC-2 SWD New Drill UIC-2 SWD Re-Entry UIC-2 ER Conversion Class II Enhanced Recovery UIC-2 ER New Drill UIC-2 ER Re-Entry Class II Commercial Injection Well UIC-2 COM Class II Hydrocarbon Storage UIC-2 HSW Class II Slurry Fracture Injection UIC-2 SFI Class II Annular UIC-9 Class II Change of Zone UIC-32 Class II E&P Waste Disposal in a Cavern UIC-43 Class III Solution Mining UIC-3 BR Class V UIC-25

WHERE CAN I FIND UIC-RELATED FORMS?

Step 1: Go to the DNR Homepage at http://dnr.louisiana.gov/ and Click on the Conservation option

Step 2: Click on Forms

Step 3: Under Forms, Reports & Documents, Click Injection & Mining

List of Forms Used by the Injection and Mining Division

How Do I Check the Status of an Application

Step 1: Go To DNR Homepage & Click within the Orange SONRIS Rectangle

Step 2: Click DATA ACCESS

Step 3: Under Java Based, Click CONSERVATION

This Page is Similar in Java-Based or Lite

Step 4: Scroll to Injection Information, click UIC WELL APPLICATIONS

Step 5: Click QUERY or Hit Function 7 Key

Step 6: Click ENTER

Step 7: Enter APPLICATION NUMBER

Step 8: Click QUERY, then Click EXECUTE. As an alternate, Hit Function 8 Key

View Application Details Using Application Number

Step 7 alternate: Enter EXISTING WELL SERIAL NUMBER

View Application Details using Well Serial Number

Upcoming Changes UIC application forms are being revised. There will be new forms created for each well type; i.e. UIC-2 SWD Conversion, UIC-2 SWD New Drill, UIC-2 SWD Re-entry. Check the Injection & Mining Division’s forms page for up-to-date forms. There will be changes common to all application forms. Do not submit a copy of the instructions with the application. The Form MD-10-R (yellow card) is no longer required with a UIC application. The Form MD-10-R-A (pink card) will still be required to amend permits. New Form UIC-WH-1 replaces the Form WH-1 for injection wells only.

The following section is included on all the revised forms. By checking each item, the applicant is attesting that each item has been included with the application.

Things to Remember You are responsible. Respond to all correspondences before the specified due date. If an extension of the expiration date for a Permit-to-Construct is needed, submit a written request and a 126 Amend Permit-toDrill fee to the Injection and Mining Division before the permit expiration date. All matters regarding injection wells are administered by the Injection and Mining Division in Baton Rouge. Do Not Contact A Conservation District Office.

Injection & Mining Division Contact Information Telephone: 225-342-5515 Fax: 225-342-3094, or 225-242-3441 Email:[email protected]

Websites of Interest Louisiana Department of Natural Resources: www.dnr.louisiana.gov/ Louisiana Office of the State Register: www.doa.louisiana.gov/osr/osr.htm United States Environmental Protection Agency: www.epa.gov www.epa.gov/region6/water www.epa.gov/region6/water/swp/uic/index.htm