Voluntary Compliance: Overcoming Permit Protests of Salt Water Disposal Wells

Voluntary Compliance: Overcoming Permit Protests of SWD Wells

Underground Injection Issues                                                                                           December 30, 2012

Disposal Well Protests:
Injection wells, especially those associated with the Shale-Gas play, appear like a drum-beat in the national news media. Injection wells have lately drawn local and national protests from citizens fearing environmental impacts. Disposal well operators and investors need to be aware of public attitudes and perceptions and especially how these perceptions can be mediated by actions of operators. One operator’s responses in particular are perhaps an indication of the changes in public opinion.

Joint venture operating partners received a permit for a commercial Class II disposal well in Oklahoma, one of a few states who distinguish commercial and private disposal wells in the oil and gas Underground Injection Control (UIC) sector. A private well can only accept waste from the operator’s producing wells while the commercial well can accept waste water from any oil and/or gas well. The proposed commercial well specified in the permit, having received no protests from industry nor public, was not drilled prior to the permit expiration. This operating partner recently filed for a new permit but the new application received over 1,300 protests, mostly in the form of petitions initiated by residents. We have written about the nature of the protests that center around lack of knowledge and lack of public trust in industry and regulators. Partly in answer to the protests, the operator has adopted a variety of additional, voluntary compliance measures. A prospective Class II UIC permittee might also consider these voluntary measures to satisfy protests and whether they pass the cost – reward test:

 

Waste-Water Monitoring:  Protestants fear hazardous or even radioactive components being put into the proposed disposal well. In order to allay those fears, the operator will install automatic liquid monitoring sensors to measure and record conductivity and specific gravity of the liquid being delivered. Conductivity is directly relatable to salinity; if the conductivity is too low, the liquid is likely not produced water but another waste that might be non-exempt. If specific gravity is too high, the liquid might be used drilling mud that would be eligible but might foul the perforated injection zone. At the same time, the sensors record the date and time, the truck bringing the waste, and the origin of the waste. All of this information is automatically up-loaded to a proprietary website. The data stream on the website can then be shared with the relevant regulatory agency or even to the public; increased transparency is a good way to build trust for the operator, the industry, and the associated regulators.  This technology is off-the-shelf but expensive and maintenance is also an added expense.

Closed Tanks to Replace Open Pits:  Disposal wells can accept a variety of oilfield wastes including spent acids and treatment fluids; some of these wastes have strong odors unlike the usual crude oil smell associated with produced water. Strong, unfamiliar noxious odors can trigger fear and anger among neighbors and citizens. An open pit used to receive trucked in wastes will liberate greater volumes of noxious odors than will a closed steel tank.  Depending upon the proximity of neighbors and the protesting community, the disposal well operator may want to consider the installation of closed tanks instead of pits. While steel tanks will be expensive to install, if they are used in lieu of pits on a new facility, the costs will be similar.

3-D Seismic Survey:  Earthquakes at injection wellsites have been linked to the presence of significant, existing faults. Several wells within a mile of the proposed location of the disposal well should be examined to check for signs of medium-sized normal faults on wire-line logs. Approximately 1.5 sq mi of 3-D seismic may be shot and processed to look for detailed stratigraphy and faulting in the geologic column. The operator will use that data to avoid faults that cut the injection zone and may contribute to induced seismicity. The decision to make all or part of the 3D survey public will depend upon the setting and the operator. Obviously the seismic will add to the CAPEX of the facility but it will give citizens and regulators a measure to confidence in the operator.

Seismic Sensors:  Some protestors are concerned about induced earthquakes; as a way to avoid such quakes a small network of seismic sensors can be installed near the well to record earth tremors in the area. The sensors ought to be sensitive enough to detect the very small (magnitude 1.0 or less) tremors that are the rule in most geographical regions. In the case of the commercial operator, local seismic monitoring data is to be transmitted in real-time to the Oklahoma Geological Survey (OGS) to correlate with seismic data from their own seismic network. Data analysis will detect any possible, shallow events that might be connected with disposal activity. Experts can then follow the timing of these shallow tremors to determine if they are growing in intensity and the operator can curtail injection to avoid the larger, more serious events. Seismic detectors are common in some states and may be required in the future.  
 

Injection Statistics:  Many commercial injection wells automatically tabulate injection rate and well-head pressure at short intervals. Such injection statistics would be ideal for determining connection to small, shallow seismic events and continuously checking the status of the injection zone. Known shallow events derived from OGS staff are to be related to injection statistics to determine a correlation. The well operator can then use this information to determine injection parameters in the future to avoid larger induced seismic events. The operator can also utilize injection statistics to determine injection rate-versus pressure to track injectibility data for the injection zone. If the well begins to show less injection rate per psi, the operator may be alerted to the possibility of the well needing remedial work. Whether or not any of this data will be shared outside the operator’s office and on what schedule can be decided by the operator in discussions with the regulatory community. Added costs for this extra compliance may partly be offset by the extra information about the injection well and the injection zone.

Site Perimeter Berms:  The disposal well’s tank battery will of course be contained within a berm to capture accidental spills, as required by regulation. A protested facility may additionally be bermed in its entirety to contain any possible storm-water runoff or catastrophic tank-truck failure. This extra compliance is not unheard of and may be more valuable in certain geographical settings.    

Sound-walls:  Off-the-shelf sound walls are available and are used by oil and gas operators who have wells in urban settings. The disposal well operator may well consider the installation of a sound wall even in a rural setting if there is a neighbor in close proximity. Sound walls are expensive and are likely not required unless a neighbor is unusually closeby.

Air-Quality Monitors:  In some locations, produced water and other eligible wastes  may contain CO₂ or H₂S in toxic amounts. Regulations will often require placards warning of these toxic gases but these placards can be more alarming than anything.  In those settings, the operator may be best served by installing perimeter monitors with alarm horns. While many jurisdictions require alarms when residences are nearby, the prudent operator will install these alarms even when only livestock is endangered.

 

Summary – The Value of Voluntary Compliance:  Compliance at Class II disposal well sites must be evaluated by the individual operator on a case-by-case basis. At issue are the added capital costs, the added operating costs, and the potential good-will and public trust accrued by the facility. Operators and investors will need to consider all the aspects of extra compliance.      

The Authors:

Marian M. Smith, Ph.D., University of South Carolina (Geology) is a partner in Odin Oil and Gas, LLC, in Oklahoma City, OK. Dr. Smith has expertise in reservoir geology and image analysis. For most of her career she was an educator at all levels from graduate school geology courses at Michigan Technological University to the teaching of science in middle school in South Carolina. At present she is combining her background in research and teaching to work as a consultant with Dr. Langhus at Odin Oil and Gas, LLC.

Bruce G. Langhus, Ph.D., is a petroleum geologist with over 45 years' experience in oil and gas business including water-flood design and operation; Class I, II, and III disposal well location, permitting and operation; and injection well remediation.Dr. Langhus has been the Class II Program Manager in Oklahoma, the second largest UIC program in the country.He was a founding partner of ALL Consulting, a successful geotechnical consultancy in Tulsa, OK.Dr. Langhus is now part of Amerex Resources, operators of disposal facilities in Texas, Oklahoma, Montana, and North Dakota.