And Now for Something Completely Different:

Unusual Class V Wells in Texas

Presented at GWPC UIC Conference in Tulsa, OK on February 12, 2018Lorrie Council, P.G., Texas Commission on Environmental Quality

Overview of Presentation

▪ Texas Commission on Environmental Quality (TCEQ) UIC Class V Program

▪ Case Study: Large Volume Disposal of Drinking Water Treatment Residuals

▪ Case Study: High Capacity Aquifer Storage and Recovery (ASR)

▪ Case Study: Long-Term ASR Using Surface Water Source

▪ Case Study: Experimentation on CO2 Sequestration

▪ Case Study: MITs on Disposal Well in Between Bankruptcy and New Operator

▪ Case Study: Experimental Well for Large Capacity Disposal of Drinking Water Treatment Residuals at Proposed Clean Energy Power Plant Facility

▪ Considerations for High-Volume , High-Tech, or Deep Class V Injection Wells

TCEQ UIC Class V Program

▪ Class V wells in Texas must first be authorized before wells can inject (except for closed loop heat pump wells)▪ Application▪ Review/Amend application as needed▪ Authorization approval letter

▪ There are no application or periodic fees for Class V injection wells

▪ Most Class V wells in Texas are associated with ▪ Aquifer remediation ▪ Closed-loop heat pumps ▪ Sanitary wastewater disposal▪ Stormwater drainage

▪ Most of the Class V injection wells in Texas are “low-tech”

▪ The running inventory of Class V wells in Texas is 50,646 (2017)

Inventory of Class V Wells in Texas

Well Codes Class V Well Type # Wells Permits/Program

5A07 A/C Return Flow Wells 12,868 From Water Well Driller Reports

5A19 Industrial Cooling Water Return Flow 5

5D02, 5D04, 5F01 Drainage: Stormwater; Industrial; Agricultural 710

5R21 Aquifer Recharge; Aquifer Storage/Recovery 110

5W09, 5W10 Untreated Sewage; Large Capacity Cesspools 33

5W11 WWTP Disposal; Septic System Drainfield 498 MW Discharge Permit Required

5W12, 5W32 Large Capacity Septic Systems 54 MW Discharge Permit Required

5W20 Industrial Process Waste Disposal 26 Ind W Discharge Permit Required

5X25 Experimental (Pilot Tests, Tracer Studies, etc) 2,118

5X26 Aquifer Remediation 33,970 Superfund, DCR, VCP, LPST Related

5X27 “Other” Wells 171

5X28 Motor Vehicle Waste Disposal Wells 5 Effectively Banned/Permit Required

Running Inventory 12/31/17 (not all well types listed above) 50,646 (includes closed wells)

Case Study: Large Volume Disposal of Drinking Water Treatment Residuals (DWTR)

▪ El Paso Water Utilities (EPWU): Disposal of DWTR from large reverse osmosis (RO) water treatment plant, initially authorized July 13, 2005 (amended multiple times since then)

▪ Authorized: 4 injection wells (3 installed) built to Class I Standards; injectate piped to tanks/wells ~22 miles from RO Plant; gravity flow

▪ Injection Zone: ~1,000 feet to 4,000 feet below ground surface (BGS)

▪ Injection Zone: USDW with ~8,800 mg/L Total Dissolved Solids

▪ Authorized Volume:3,360 Acre-Feet/Year (1,094,867,095 gal/year)

▪ Annual MITs Required (APT, RATS) and After Workovers (several to-date)

▪ Special Consideration: EPA Required Aquifer Exemption ~114 square miles

Case Study: EPWU Large Volume Disposal of Drinking Water Treatment Residuals, cont.

Case Study: High Capacity Aquifer Storage and Recovery (ASR)

▪ San Antonio Water System (SAWS) ASR - stores water from the Edwards Aquifer in the Carrizo Aquifer, initially authorized October 9, 2001. SAWS Twin Oaks Facility is situated on ~3,200 acres

▪ Injectate: Edwards Aquifer water produced far from ASR facility, transported by 2-way pipeline

▪ Authorized: 34 injection wells (29 installed over two phases of construction)

▪ Injection Zone: Carrizo Aquifer approximately 400 feet to 780 feet BGS

▪ Storage/Recovery Capacity: 64 MGD

▪ SAWS ASR system surpassed 100,000 AF (33 Billion Gallons) of water in storage April 2014

Case Study: SAWS HIGH CAPACITY ASR, cont.

Case Study: Long-Term ASR Using Surface Water Source

▪ City of Kerrville: ASR - storage and recovery of treated water from the Guadalupe River , Class V authorization issued September 11, 1996. At that time, a demonstration project permit from TCEQ Office of Water was also required since the water was state appropriated water (water rights)

▪ Authorized: 5 injection wells (2 constructed and in use; 1 well replaced)

▪ Injection Zone: Lower Trinity Aquifer, 495 feet to 819 feet BGS

▪ Authorized Volume: 4,760 AF/yr (1.55 Billion Gallons/yr or 4.25 MGD)

Case Study: Long-Term ASR Using Surface Water Source, Kerrville ASR, cont.

Case Study: Experimental Well for CO2 Geologic Sequestration

▪ University of Texas, Bureau of Economic Geology (BEG), working under a DOE grant, conducted a CO2 sequestration pilot test using a deep Class V well built to Class I well standards; authorization included typical Class I permit provisions

▪ Authorization: one well, issued February 5, 2004, closed October 6, 2009

▪ Injection Zone: Frio Formation, from 4,900 feet to 5,200 feet (well log depths)

▪ Injectate: Food-grade CO2, non-hazardous brine, tracers

▪ Authorized Volume: 4,000 tons CO2 + 1.09 MG/year

▪ Authorized Pressures: MASIP <2,500 psig for fluids and <1,200 psig for CO2

▪ Mechanical Integrity Tests (MIT): Required prior to injection and at closure

▪ Financial Assurance: Well closure cost estimate required, but no security required

Case Study: BEG Experimental Well for CO2 Geologic Sequestration, cont.

Case Study: MITs on Class I Well As a Class V Experimental Well

▪ Former Class I Well - Original operator declared bankruptcy; new operator required to do well workover and MIT prior to TCEQ issuing new Class I well permit; Class V authorization included typical Class I permit provisions

▪ Class V authorization needed for well tests because associated Class I well permit was contested; Class I well permit subject of litigation since issuance in June 2011

▪ Authorization: one well issued July 23, 2009, closed July 8, 2011

▪ Injection Zone: 5,134 feet to 6,390 feet (well log depths)

▪ Injectate: solutions used for testing, cleaning, servicing, closing the well

▪ Authorized Pressures: MASIP <1,250 psig; Injection Rate: <350 gpm

▪ Financial Assurance: security required (amount of est. well closure costs)

Case Study: MITs on Class I Well As a Class V Experimental Well, cont.

Case Study: Experimental Well – Evaluate Large Volume Disposal of DWTR at Proposed Alternative Power Plant

▪ Limited liability corporation (LLC) obtained DOE grant to plan and install a clean energy coal-fired power plant. Purpose of Class V experimental well was to collect reservoir data and conduct injectivity testing, then evaluate potential for disposal of DWTR from an RO at proposed clean coal power plant

▪ Authorization: one well, issued Sept. 23, 2011, built to Class I well standards

▪ Injection Zone: 3,000 feet to 7,500 feet BGS, testing Queen, Clear Fork, and Wichita formations (actual completion depth 7,350’)

▪ Injectate: solution of fresh water with potassium chloride

▪ Closure Plan: required in application; closure to Class I standards

▪ Financial Assurance: Security mechanism required for well closure costs (increased for inflation annually)

Case Study: Experimental Well – Evaluate Large Volume Disposal of DWTR at Proposed Alternative Power Plant

▪ Well installed in 2012, testing conducted, completion report submitted and accepted in 2013

▪ DOE suspended grant funding to company in February 2016

▪ No communication from LLC since 2013 until bankruptcy notice in October 2017

▪ LLC land lease reverted back to property owner, a municipal economic development corporation December 31, 2017

▪ TCEQ Site Inspection November 3, 2017: Well is currently not plugged and wellhead has no gauges; original mud pits from well construction still in place

▪ Texas Attorney General’s Office representing TCEQ in Chapter 7 bankruptcy court

▪ Desired Outcome: Properly plug and abandon well using financial assurance bond

Case Study: Experimental Well – Evaluate Large Volume DWTR Disposal at Proposed Alternative Power Plant, cont.

Case Study: Experimental Well – Evaluate Large Volume DWTR Disposal at Proposed Alternative Power Plant, cont.

Considerations for High-Volume, High-Tech or Deep Class V Wells

▪ Well Construction Standards: commensurate with intended use and completion depth and reservoir conditions – may need to be Class I well standards

▪ Financial Assurance: may be important for authorization even though rules don’t require FA - agency may need to rely on security mechanism to plug wells itself

▪ Mechanical Integrity Requirements: well use and construction may dictate the need to require annual MITs

▪ Monitoring and Reporting: high-volume and/or high-tech wells should have periodic monitoring and reporting requirements; agency should evaluate reports and make adjustments to authorizations if warranted

▪ Inspections and Compliance: agency compliance staff not routinely engaged for Class V well oversight and permitting staff are responsible for oversight; may need to make arrangements for agency compliance staff to conduct routine inspections (like Class I)

Questions?

Contact Info:

Lorrie Council, P.G.

UIC Permits Section Manager

Texas Commission on Environmental Quality

12100 Park 35 Circle (MC233)

Austin, TX 78753

(512) 239-6461 lorrie.council@tceq.texas.gov

https://www.tceq.texas.gov/permitting/waste_permits/uic_permits/uic.html