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Underground Injection Control Program
National Technical Work Group
Summary of July 2003 Meeting
Call to Order (George Robin, Chair)Each Representative took 3 minutes to comment on the year in review and future issues for the year to come. Done. Numerous problems, successes, challenges identified by each.
Mike Frazier, Region 6 and Tom Maunder, Alaska: Annular Disposal
of RCRA exempt wastes into oil and gas exploration and production
(E&P) wells within the regulatory scope of the UIC program?
Approved NTW Project Topic #1
Mike provided a CD containing scanned reference documents related
to annular injection and area of review topics. Discussion led to
the question whether this might lead to developing a Guidance Document.
Conflicting documents, and memos will need resolution. The Workgroup
will search for more related documents and send to Mike. Some of the
technical considerations that came out of the discussion were that the
base of the USDW is not always known; toxicity of fluids; and limits
of fracture control in these situations. It will be helpful if the
GWPC would assist in conducting a survey of the states where this
practice is allowed. GWPC later concurred and will work with us.
Paul Osborne and Region 8 Reps: UIC Record Library (keeper of the knowledge)
This idea is worthwhile as a source of reference and background for
technical issues. It is intended to help provide technical insight
to reasons why decisions were made by various regions and states, to
help support consistency in application to various situations, etc.
This will serve to save much time and help to focus collaborative efforts,
which are the norm for resolving many UIC technical issues. Paul is
heading up most of this effort, which includes augmenting previous
efforts made by Mario Salazar, Steve Platt, and others. Workgroup
will send documents to Paul, as well as suggestions of what format
is best to apply to this collection. The ultimate goal is to have
the collection in a non-corruptible, text format. Examples of topics
are Well Classification, Salt Caverns, Guidance Documents, Aquifer
Exemptions, Court Cases, Existing Permits.
Harlan Gerrish, Region 5: Standard Operating Procedures (SOPs)
Harlan recapped these proposed Work Products and their status.
SOPs serve as a roadmap for performing selected operations and a
record of their performance. Without such a record, there is probably
no evidence that an operation was performed or that it met professional
standards. They may be an important protocol for inspection efforts,
and are meant to augment professional experience and judgement. They
are intended as a source reference for reviewing and interpreting
results of the various operations. Draft SOPs are due by the end of
this summer, FY03. At that time they will be distributed within the
workgroup for peer review. These SOPs should be ready for distribution
to the state agencies and industry for their review at the GWPC Policy
Meeting in March of 2004. Assigned topics are Falloff Testing, Temperature
Logging, Maximum Injection Pressure Calculation, Area of Review, and
Radioactive Tracer Testing (Steve Roy at Region 5 has begun this SOP).
Harlan Gerrish, Region 5: "Review of Injection Reservoir Information
in Relation to Earthquakes in Ashtabula, Ohio"
Good presentation and very interesting. Comments were submitted to
Harlan relating to his presentation, its clarity, format, etc. to help
make it most understandable and convincing. He will be presenting this
paper at the UIC Science and Technology Symposium hosted by Lawrence
Berkeley Lab this October.
Tom Maunder, Alaska and Thor Cutler, Region 10: Logging Techniques,
Borax Logs
Tom and Thor provided a discussion and explanation of this well-established
technique, and which events and situations make it most applicable.
They will distribute various published technical papers and information
to the Workgroup. This logging method shows great promise as a MIT technique.
It needs formal approval to be used in MI Testing of injection wells.
There is an EPA Guidance which outlines this process. The Workgroup
will assist.
Mike Frazier, Region 6: Training: Basic Area of Review Considerations
Time did not allow the presentation of the Region 6 power point presentation
on the "Ideal AOR."
Mike Frazier, Region 6
Should a UIC program Director be required under 40 CFR 144.12 to expand
the Area of Review (AOR) for Corrective Action when the calculated pressure
influence is greater than the standard fixed-radius AOR? (Approved UIC
Technical Workgroup Project Topic #2) Mike provided a CD containing FR
preambles, House Reports, and other published papers, documents, reports
and the entire Class II Summit Paper on Permit Evaluation prepared by Ken
Johnson and Suzie Lopez, Region 6. This CD, very much in keeping with
the goals of the UIC Library, will provide the workgroup with the historical
development of the current AOR requirements. Roadblocks include possible
economic impact to operators (large and small companies), documentation
of threats to USDWs and known cases of contamination.
Nathan Wiser and Carol Bowden, Region 8: Financial Responsibility
(FR) Workgroup
The Workgroup focused on developing a checklist of variable situations
which range widely. Discussions also on the adequacy of a financial
mechanism; suggested we incorporate case histories to examine actual
costs versus available money; setting minimum amounts to be required.
Bob Smith, HQ: Identifying New Challenges
Bob pointed out that the products are high priority and urged we use
discretion in assigning and implementing. New projects should be
regarded in the Class V area - where we can provide technical help,
especially in reviewing permits, Rule Authorization, inspection,
inventory, Best Management Practices, handheld PDA development, etc.
Technical Contract Support from HQ will be especially helpful to the
Workgroup and requests should be submitted early.
The UIC Technical Work group is contributing to the Second International
Symposium on Underground Injection Science and Technology, sponsored by
Lawrence Berkeley National Laboratory, California. The Symposium will
be held on October 22-25, 2003 (also see
http://www.lbl.gov/Conferences/UIST).
Work group participation includes Bob Smith, Bruce Kobelski and George
Robin helping with advisory committee and preparation; 3 technical papers
will be presented by authors Harlan Gerrish, Thor Cutler and Steve Platt.
Attendance:
Mike Frazier, Reg. 6
Russ Land, Nevada DEP
Tom Maunder, Alaska Oil and Gas
George Robin, Reg. 9
Larry Cole, Reg. 4
Paul Osborne, Reg. 8
Harlan Gerrish, Reg. 5
Nathan Wiser, Reg. 8
Dan Jackson, Reg. 8
Thor Cutler, Reg. 10
Rob Ferri, Reg. 2
Carol Bowden, Reg. 8
Kurt Hildebrandt, Reg. 7
Robert E. Smith, HQ
Underground
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