EPA DRAFTS TOUGHER INJECTION WELL RULES

Regulations under development by the U.S. Environmental Protection Agency would hit oil and gas producers with new, costly requirements for wells that inject produced brines and fluids for enhanced oil recovery. If implemented, they would certainly discourage EOR activity and encourage shut-in of producing wells. Those effects should alarm not only producers but also the Department of Energy, which is studying ways to increase domestic production.

June 14, 1993

3 min read

This is not a case of regulatory extremism. Industry representatives sat on the federal advisory committee that helped write the proposed underground injection control (UIC) regulations, which EPA might formally propose by yearend. Comments in the draft itself, now in the hands of committee members, show that EPA often rejected steps that it deemed excessive or unnecessary.

THE PROPOSALS

Still, the draft proposals are tough:

All new oil field injection wells would have to have three layers of protection. That means 1) surface casing deep enough to protect underground sources of water with 3,000 mg/l. of total dissolved solids or less; 2) a long casing string cemented through the injection interval; and 3) tubing set on a packer. EPA says 40% of existing injection wells fail this test.
Existing injection wells with only one layer of protection would have to undergo mechanical integrity testing every year. Wells with two such layers would be tested every 3 years. Other wells would be tested every 5 years, as all wells are now.
UIC "area of review" regulations would apply to all injection wells, not just new wells as at present, and would require immediate corrective action for problem wells.

The proposed construction and testing requirements would certainly add to costs of operations. But the area of review proposals may represent the biggest headache for industry. They would require study of the records for all wells within 1/4 mile of any injection well to identify those that might provide a vertical route for injection fluids to an underground source of drinking water. Abandoned wells providing such a conduit would have to be reentered and replugged. Producing wells would require squeeze jobs to cement off the injection interval. Problems will arise in cases where the injection well operator does not also operate the well in need of repairs. Few operators will shut in wells so outsiders can work them over.

Variances and exemptions provided in the draft regulations afford little consolation. Requests to depart from the UIC regulations would be subject to public comment proceedings, which would give environmental alarmists a sounding board.

What should industry do?

Maybe nothing. Maybe current oil field practices do pose a widespread threat to underground drinking water supplies. Producers should know. Those who suspect that a serious problem exists should not resist tougher regulation, so long as it is fair.

PROBLEMS SEEM ISOLATED

If there is no general problem, however, industry should fight the regulations for going too far. In 1987, EPA cited eight cases in five states of groundwater having been damaged from oil field wastes, all involving abandoned wells. Two years later, a General Accounting Office study found 23 cases of confirmed aquifer contamination. American Petroleum Institute said only four of them resulted from injection activities.

The U.S. has 170,000 active injection wells and 2.2 million abandoned or inactive wells. Against those numbers, 23 cases of aquifer damage look like isolated problems. And isolated problems make current UIC regulation and legal remedies look sufficient.