CA State Oil and gas regulators seek comments on updated underground injection rules

With the publics attention on the Porter Ranch gas leak causing thousands to relocate the office responsible for regulating oil and gas activities in the state - The Division of Oil, Gas and Geothermal Resources (DOGGR) - announces the public comment period on the "discussion draft" of new regulations covering steam and water injection practices (for enhanced oil and gas production) as well as rules pertaining to the injection of gas for storage - like the situation in Porter Ranch. 

The four page discussion draft of proposed regulations can be viewed HERE. 

The public comment period on the discussion draft rules goes until February 19 and comments can be submitted by mail or email: "Written submissions may be provided to the Division by regular mail or email. The mailing address is: Department of Conservation, 801 K Street, MS 24-02, Sacramento, CA, 95814, attention UIC Discussion Draft. The email address is UIC.Regulations@conservation.ca.gov, attention UIC Discussion Draft."

Here is the full press release from DOGGR: 

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STATE SEEKS COMMENT ON AGGRESSIVE NEW RULES
CONTROLLING UNDERGROUND INJECTION OF WASTEWATER IN CALIFORNIA OIL AND GAS FIELDS
 
SACRAMENTO — The California Department of Conservation (DOC) seeks public comment on a package of draft rules proposed to control the use of water and steam in the production of oil and natural gas in California, and also the water generated as a byproduct of that process.  The proposed rules also would increase the safety of underground natural gas storage by requiring an additional layer of protection inside many wells.

“We are moving swiftly to enact regulations that further protect groundwater, including tougher wastewater disposal rules,” said State Oil & Gas Supervisor Ken Harris, who leads DOC’s Division of Oil, Gas, and Geothermal Resources. “These rules boost permitting and reporting requirements, further regulate how companies inject wastewater and natural gas, and impose new testing and monitoring mandates.”

The aggressive proposed rules follow DOC’s issuance last week of emergency regulations on underground natural gas storage facilities including the Aliso Canyon facility operated by the Southern California Gas Company in northern Los Angeles, where a well has been leaking gas since late October.  These emergency regulations on underground gas storage facilities, directed by Governor Brown in his January 6 emergency proclamation, are scheduled to take effect in early February.  While these emergency regulations are in effect over the next twelve months, an expedited rulemaking process will take place to update permanent regulations for underground gas storage facilities.  This permanent rulemaking for underground gas storage facilities will be separate from the process to modernize and improve requirements for all types of oil and gas injection activities regulated by the state’s underground injection program, which are reflected in the regulations proposed today.

Due to California’s geology, drilling for oil and gas yields far more water than oil.  In 2014, California produced 205.3 million barrels of oil.  Generation of that oil also produced more than 3.3 billion barrels of water, most of which is naturally brackish and unsuitable for human use unless it goes through a produced water treatment process approved by the Water Boards.  Typically, the produced water is injected back into the reservoir from which it was produced, either for enhanced oil recovery or to maintain reservoir pressure to prevent subsidence.  In California, certain kinds of injection wells – those that inject super-heated steam, water, or other fluids into formations to extract minerals – are regulated by the Division of Oil, Gas and Geothermal Resources (Division).  The Division’s program to regulate these injection wells is monitored by the U.S. Environmental Protection Agency (US EPA).

The draft rules released today are intended to address shortcomings in the state’s underground injection control program identified by the US EPA and also to modernize and improve the rules that protect public health and safety and the environment.

“Last October, the Division released a Renewal Plan to address a number of issues, including underground injection,” Harris said. “We committed to conducting a thorough review of all underground injection control projects in the state, to ensuring California is in full compliance with the Safe Drinking Water Act, and to reviewing and revising our regulations as necessary.  We are following through on those commitments while also working to strengthen regulations to improve safety.”
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The new “discussion draft” regulations include revisions to the existing underground injection control regulations to address the following issues:

♦ Clarifying and strengthening standards to ensure “zonal isolation” of injection projects – that is, making sure that what is injected goes into and stays in the proper geologic zone to protect groundwater.

♦ Strengthening and clarifying permitting and ongoing project data requirements for all underground injection control operations, including cyclic steam, in which a well is injected with steam to enhance oil production and then used to pump up oil.

♦ Strengthening and clarifying mechanical integrity testing requirements for all underground injection control operations, including cyclic steam.

♦ Establishing permitting and regulatory requirements for cyclic steam operations.

♦ Establishing a process and standards for determining maximum allowable surface pressure for injection operations.

♦ Expanding tubing and packer requirements to apply to cyclic steam wells and gas storage wells.  This would provide an additional layer of protection to the well casing and contain gases or liquids if an inner tubing is damaged.

♦ Defining key water quality protection criteria.

The public comment period on the “discussion draft” of regulations released today runs through February 19.  The comments received will be reviewed and considered as the Division prepares for formal rulemaking. Written submissions may be provided to the Division by regular mail or email. The mailing address is: Department of Conservation, 801 K Street, MS 24-02, Sacramento, CA, 95814, attention UIC Discussion Draft. The email address is UIC.Regulations@conservation.ca.gov, attention UIC Discussion Draft.
Updated draft regulations will be made public when the Division commences a formal rulemaking process. Public comment hearings and additional comment periods will be announced when the notice of the formal rulemaking process is issued to the public. To be on a mailing list for underground injection control-related rulemakings, please use the following link: http://www.conservation.ca.gov/index/Pages/MailingLists.aspx.