![[logo] US EPA](http://www.epa.gov/epafiles/images/logo_epaseal.gif){kind=logo}
National UIC Technical Workgroup Third Newsletter
National UIC Technical Workgroup
Third Newsletter
FINAL WORKGROUP PRODUCTS
The national UIC technical workgroup has finalized two more work products since the last issue (April 1998) of this newsletter. These work products are described below.
Naturally Occurring Radioactive Material (NORM) Waste
Author: Bill Mann
This work product is a reproduction of a large 1997 bibliography compiled by Argonne National Laboratory containing more than 20 pages of references to NORM waste and a reproduction of a 1995 paper prepared by the Cadmus Group which addresses potential issues related to NORM waste in Class II injection wells. These two references are helpful to anyone wishing to research the current regulatory or technical aspects associated with NORM waste.
Class V Study Direction
Author: Nathan Wiser
The workgroup has completed a review of three draft papers authored by the an EPA contractor. The papers were crafted as part of the national effort to better understand Class V wells across the country and to help determine if additional regulations are warranted. The three papers covered three different types of Class V wells: Solution Mining (Type 5X14), In-situ Fossil Fuel Recovery (Type 5X15) and Spent Brine Return Flow (Type 5X16).
The workgroup made a number of comments about each of the papers as authored. The recommended focus for each paper centered around a complete description of current regulatory controls imposed on each of these three well types. Also, the workgroup suggested an approach based on relative risk to the environment.
These two work product join the existing group of finished products: the Fracture Slurry Injection Paper and the Area of Review Summary.
NOTE: The Region 8 office serves as a repository for final workgroup products. Contact either Carol Bowden in Region 8 or the author to obtain a copy of a final workgroup product.
DRAFT WORKGROUP PRODUCTS
Fluids Acceptable for Injection into Class II Wells
Authors: Paul Osborne and Jonathan Williams
This position paper provides a detailed review of what waste fluids can be injected into Class II injection wells. The authors examined existing regulations and policies in order to compile a consensus opinion about waste fluids and how the RCRA Exploration and Production exemption (E&P exemption) relates to Class II wells. This position paper will be circulated to UIC State Programs for comment in the near future and should be finalized shortly thereafter.
Dual Completion Well (Class II) Mechanical Integrity Test Standards
Author: Nathan Wiser
A first draft describing conditions and thresholds for passing or failing a mechanical integrity test was created by the author. After internal review, the final workgroup product will take the form of a draft notice in the Federal Register taking comments on the proposed MIT method. After the close of the comment period, a final Federal Register notice will be issued, with the final MIT method published. The dual completion wells which are contemplated in the draft are restricted to those that simultaneously produce oil to the surface and inject water from the surface. There are wells of this type known to exist in Oklahoma, Kansas, Indiana, Michigan, and Wyoming. The workgroup welcomes information on such wells in other locations, as well. The test incorporates for two basic components: (1) observation of decline curves and (2) monitoring fluid level in the production annulus.
Class II Permit Boilerplate Comparison
Author: Bill Mann
A first draft was developed which compares the standard language (boilerplate) used in Class II permits issued in the Direct Implementation programs in Regions 3, 4, 5, and 8. Although each Region's format is somewhat different, there is considerable similarity in both general and specific requirements among the different permit boilerplates.
Cement Requirements for Class II Wells in Direct Implementation Programs
Author: Steve Platt
In Class II wells, cement records are allowed to serve as a demonstration of mechanical integrity in lieu of a direct confirmation of a lack of fluid movement behind casing (mechanical integrity Part II). The workgroup has developed a draft document which compares the cementing record standards prescribed by each Region's Class II Direct Implementation program to meet this requirement. The final work product on this issue should be finished sometime in October or November.
Use of Downhole Separators in Oil Production Wells
Author: Paul Osborne
The use of downhole oil/water separators in production wells is being advocated by a consortium including Mobil, BP, Texaco and Chevron (MoBPTeCh). A number of test wells in different settings around the North American continent have led to a general understanding that these devices enhance the recovery of oil and strongly reduce the amount of waste brine water produced to the surface with the oil. The workgroup has developed a draft position paper which advocates that these wells be regulated as Class II injection wells even though they don't actively inject fluids "brought to the surface" in connection with oil and gas production. Issues yet to be worked out include appropriate construction and mechanical integrity test standards.
Annulus Additives
Author: Harlan Gerrish
This draft paper addresses the use of annulus additives in wells which fail a standard annulus pressure test (SAPT) but can be temporarily "fixed" with a material which prevents or slows the leak rate enough to pass the test.
ISSUES ON WHICH WORK HAS BEGUN
The workgroup has begun work on the following topics, but documents for review have yet to be developed.
Mechanical Integrity Test Standards
Author: Harlan Gerrish
A draft paper will result from a survey of each Region and/or State. The MIT pass/fail criteria will be described for various tests, along with which test methods are used across the nation.
Falloff Testing Technical Assistance Document
Author: Joe Kordzi
This technical assistance document will provide injection well operators and contractors with a concise description of modern falloff testing procedures and analysis techniques.
Feasibility of Aquifer Exemptions in Non-Injection Zones
Author: Bruce Kobelski
This paper will address the issue of exempting aquifers into which no injection occurs and how this would be possible within the existing regulatory scheme.
OTHER ISSUES ON OUR PLATE
The workgroup also has several remaining topics for which we have yet to develop draft documents. In the future, the workgroup expects to consider these issues either as lead or in a support capacity to assist others to develop quality work products. These topics follow:
Financial Responsibility
Injection Fluid Analysis
Continuous Cement
Plugging Procedures
Temporarily Abandoned Wells
COMMUNICATION
The national UIC technical workgroup reiterates its commitment to open dialogue with any and all interested persons. There are a number of ways interested persons may become involved in the activities in the workgroup.
- Call or email any of the workgroup members. The telephone numbers and email addresses are listed in this newsletter.
- Visit websites that have information about the workgroup
activities. The GWPC website will
soon post these newsletters on its new homepage:
Ground Water Protection Council
In addition, the workgroup is exploring the option of establishing workgroup information on a website to be developed to provide information about the Office of Groundwater and Drinking Water. This website is:
Also, Region 10 has constructed a quality webpage with information relevant to the work of the national UIC technical workgroup. This address is:
www.epa.gov/r10earth/offices/water/uic.htm [Note: this link is no longer active.]
- Become a direct recipient of this electronic newsletter by
contacting Nathan Wiser in Region
5. See the member list in this newsletter for his number and
email address.
The workgroup provides updates at national meetings, and considers ideas and issues brought forth from States, industry, and others.
LAST MEETING
The national UIC technical workgroup met in Denver, Colorado during July 14-16, 1998. The meeting was largely regarded as a success. During the meeting, we listened to presentations on downhole oil/water separators from both CH2M Hill and Texaco. Much of the momentum from that meeting spilled over to the ensuing months, with work progressing on a multitude of different fronts.
MEMBERSHIP
The Workgroup consists of 19 Federal employees from nine EPA Regions and EPA Headquarters. These members are listed below.
| Headquarters | ||
| Bruce Kobelski | kobelski.bruce@epa.gov | (202) 260-7275 |
| Robert Smith | smith.roberteu@epa.gov | (202) 260-5559 |
| Region 2 | ||
| Charles Hillenbrand | hillenbrand.charles@epa.gov | (212) 637-4226 |
| Region 3 | ||
| Mark Nelson | nelson.mark@epa.gov | (215) 566-5461 |
| Steve Platt | platt.steve@epa.gov | (215) 566-5464 |
| Region 4 | ||
| Bill Mann | mann.bill@epa.gov | (404) 562-9452 |
| Region 5 | ||
| Harlan Gerrish | gerrish.harlan@epa.gov | (312) 886-2939 |
| Allen Melcer | melcer.allen@epa.gov | (312) 886-1498 |
| Nathan Wiser | wiser.nathan@epa.gov | (312) 353-9569 |
| Region 6 | ||
| Brian Graves | graves.brian@epa.gov | (214) 665-7193 |
| Joe Kordzi | kordzi.joe@epa.gov | (214) 665-7186 |
| Region 7 | ||
| Ted Fritz | fritz.theodore@epa.gov | (913) 551-7412 |
| Kurt Hildebrandt | hildebrandt.kurt@epa.gov | (913) 551-7413 |
| Region 8 | ||
| Carol Bowden | bowden.carol@epa.gov | (303) 312-6485 |
| Paul Osborne | osborne.paul@epa.gov | (303) 312-6125 |
| Region 9 | ||
| Gregg Olson | olson.gregg@epa.gov | (415) 744-1828 |
| George Robin | robin.george@epa.gov | (415) 744-1819 |
| Jim Walker | walker.jim@epa.gov | (415) 744-1833 |
| Region 10 | ||
| Jonathan Williams | williams.jonathan@epa.gov | (206) 553-1369 |