Texas Underground Injection Control (UIC) Program Overview

Presented to Texas Alliance of Groundwater DistrictsOctober 30, 2014

Lorrie Council, PGManager, UIC Permits Section

Radioactive Materials Division, Office of WasteTexas Commission on Environmental Quality

UIC Program Basics• Underground Injection Control (UIC) is a federal regulatory

program administered by Environmental Protection Agency (EPA)• EPA has designated six classes of injection wells in the UIC program• In 1982, EPA delegated UIC authority to Texas. Texas jurisdiction for

UIC is split between Texas Commission on Environmental Quality (TCEQ) and Texas Railroad Commission (TRC), based on well type

• The state’s UIC Program regulates injection in order to protect fresh water and Underground Sources of Drinking Water (USDWs)

• Statutes provide the basis for the UIC Program:– Texas Injection Well Act (Chapter 27 of Texas Water Code)– Federal Safe Drinking Water Act– Federal Resource Conservation and Recovery Act (hazardous waste)

• Rules provide the regulatory framework for UIC Program:– Title 30, Texas Administrative Code, Chapter 331 (TCEQ UIC)– Title 40, Code of Federal Regulations, Parts 144-147

UIC Program Basics

• Underground injection wells used for decades to dispose of waste: – 1930s: oil companies began injecting wastes into depleted reservoirs through

converted oil production wells– 1950s: injection of hazardous chemicals and steel industry wastes began– 1960: use of injection wells for waste disposal rose sharply as manufacturing of

chemicals increased

• Important UIC program definitions:– Well: A bored, drilled, or driven shaft, or a dug hole where the depth is greater

than the largest surface dimension– Underground Injection: Subsurface emplacement of fluids through a well– Aquifer: Geologic formation that is capable of yielding a significant amount of

water to a well or spring– Underground Source of Drinking Water (USDW): An aquifer or portion of an

aquifer that:• Supplies any public water system or contains a sufficient quantity of

groundwater to supply a public water system, and• Currently supplies drinking water for human consumption, or• Contains < 10,000 mg/L total dissolved solids & is not an exempted aquifer

WATER TABLE

Brine - Salt Water (>10,000 TDS)

DR

Y

WE

T -

AQ

UIF

ER

US

DW

BR

INE

And

Useable Quality Water (3,000-10,000 TDS)

Underground Source of Drinking Water Include: Drinkable Quality Water (<3,000 TDS)

UIC Deep Well Features

Surface Casing & Cement

Long String Casing & Cement

Tubing , Packer, Wellhead Controls

Typical of Class I and II Injection Wells

UIC Program Basics – Class I WellsClass I: industrial and municipal waste disposal wells that inject beneath the lowermost USDW (non-hazardous, hazardous and radioactive wastes) – TCEQ regulates

Desalination Concentrate Disposal Well (San Antonio Water System)

Class I Industrial Disposal Well

UIC Program Basics – Class II WellsClass II: oil and gas related injection wells used to dispose of salt water produced with oil or natural gas, to inject fluids for enhanced recovery, or to store hydrocarbons – TRC regulates (over 54,000 Class II wells in Texas as of 12/31/13)

Well Head – Class II Injection Well

Class II Salt Water Disposal Site Near Dallas (Chesapeake Energy photo)

UIC Program Basics – Class III WellsClass III: wells used for solution mining of minerals such as a) uranium, sulfur and sodium sulfate – TCEQ regulates and, b) for solution mining for salt (brine mining) – TRC regulates

Block diagram of in-situ recovery uranium mining operations

UIC Program Basics – Class IV WellsClass IV: wells that inject hazardous or radioactive fluids into or above a USDW – TCEQ regulates (prohibited except where authorized for use in Superfund or RCRA cleanups)

Class IV injection well discovered during site visit and later closed as part of a site cleanup

UIC Program Basics – Class V WellsClass V: miscellaneous types of injection wells that are not included in other well classes that generally inject into or above USDWs - TCEQ regulates

EPA schematic showing some Class V injection well types

Aquifer Storage and Recovery Well Diagram

UIC Program BasicsClass VI Wells

Class VI (new well class): injects carbon dioxide gases below USDWs for geologic sequestration - EPA has program primacy (none in TX)

TCEQ 2013 Well Inventory by Class

Well Class

Type of Injection Well Number of Facilities

Active Wells

Wells Temp. Abandoned

I Hazardous Waste Disposal

24 60 7

I Nonhazardous Waste Disposal

26 48 2

III In Situ Mining 7 6,880 0

IV Prohibited (unless specifically authorized)

6 113 0

V Miscellaneous Wells (~21 subclasses)

2,386 40,871 0

Total No. Facilities and Wells(as reported to EPA in February 2014) 2,449 47,972 9

USDW Protection Standard

• The standard of protection for USDWs applies to all injection wells, with varying requirements by well class

• Texas rules addressing this standard are found in:30TAC§331.5 Prevention of Pollution(a) No permit or authorization by rule shall be allowed where an injection well causes or allows the movement of fluid that would result in the pollution of an underground source of drinking water. A permit or authorization by rule shall include terms and conditions reasonably necessary to protect fresh water from pollution

• Federal Rules addressing this standard are found in 40 CFR §144.12 Prohibition of Movement of Fluid Into Underground Sources of Drinking Water, stating that movement of fluid containing any contaminant into a USDW is prohibited if the presence of that contaminant may cause a violation of a primary drinking water standard or otherwise adversely affect the health of persons.

TCEQ UIC Program Elements

• Well Permitting and Authorization• Participation in hearings• Compliance monitoring and enforcement• Participation in the Legislative Process, Rulemaking,

Program Development, and Program Revision• Programmatic interface and reporting to EPA• Provision of UIC Program materials to the public and

regulated community• Participation in Ground Water Protection Council• Response to Public Inquiries

TCEQ UIC Program Information

• TCEQ maintains UIC Program information on the Internet:http://www.tceq.texas.gov/permitting/waste_permits/uic_permits/uic.html– information and requirements by well class– application forms– rules, fee requirements, financial assurance, QAPP– program contacts– brief list of wells regulated by TRC– link to UIC permit application database search

• UIC Program content on the Internet is updated on a regular basis – it is the best place to obtain current application forms

Timelines for TCEQ UIC Permits & Authorizations

• Class I Individual Permits: new permits, renewals, amendments, pre-injection unit registrations (390 days if no public comment)

• Class I General Permit: For injection of nonhazardous desalination concentrate and drinking water treatment residuals (~90 days)

• Class III: In situ uranium mining area permits and production area authorizations (PAAs) (390 days if no public comment)

• Class V: authorizations for most require submittal of data and written approval of authorization before construction and operation (~60 days) – some types of wells may require more information and take longer to authorize (e.g., high-volume discharges, desalination concentrate disposal, aquifer recharge)

TCEQ UIC Program General Permit

• The UIC General Permit – developed specifically for disposal of nonhazardous drinking water treatment residuals (DWTRs) including DWTRs containing naturally occurring radioactive material.

• Changes in 2013 to the General Permit:– Rule Revision (allowing DWTR disposal in bedded salt caverns)

became effective August 16, 2013– Amendment of General Permit (allowing disposal in bedded or

non-domal salt caverns) adopted by TCEQ November 19, 2013 - permit term is 10 years

• San Antonio Water System registered five wells under the General Permit and has installed one DWTR disposal well to-date (the additional wells will be installed as phases of their Reverse Osmosis Plant come online)

TCEQ UIC ProgramFuture Anticipated Trends

• Drought conditions in Texas coupled with increasing population projections have resulted in water-supply related concerns

• 2012 Texas Water Plan issued by Texas Water Development Board identified strategies for increasing water supplies including:– Increased use of aquifer recharge or aquifer storage and recovery projects,

some using injection wells – this could increase the number of Class V injection wells – depending on the quality of injected water, supplemental information may be warranted as part of the Class V authorization application

– Increased use of brackish groundwater coupled with desalination treatment plants – this could result in additional permits for concentrate disposal using Class I wells or under the General Permit (e.g., San Antonio Water System) or Class V wells coupled with an aquifer exemption (e.g., El Paso Water Utilities) – or it might include dually-permitting a Class II injection well as a Class I injection well

UIC Program Summary

• Texas has authority for the UIC Program, with split jurisdiction between TCEQ and TRC, based on well type

• TCEQ’s UIC Program has permitted, authorized, or inventoried ~48,000 wells located at over 2,400 facilities statewide – Classes I, III, IV, and V wells

• TRC’s UIC Program has issued permits for over 54,000 Class II wells and 107 Class III brine mining wells

• TCEQ’s UIC program continues to update its applications and procedures to reflect both streamlining efforts and updates based on statutory or rule revisions – the updated applications are posted on TCEQ’s Internet site

• Increasing population and continuing drought conditions in Texas are likely to result in greater need for certain types of injection wells and an increasing inventory of injection wells

Questions???

UIC Program Contact Information

Lorrie Council, PG, ManagerUIC Permits SectionRadioactive Materials Division, Office of WastePhone: 512-239-6461, Fax: 512-239-6464Email: lorrie.council@tceq.texas.gov

Main TCEQ UIC Phone Line: 512-239-6466 TCEQ Internet: http://www.tceq.texas.govTCEQ UIC Program Internet: http://www.tceq.texas.gov/permitting/waste_permits/uic_permits/uic.html