Department of ConservationDivision of Oil, Gas, and Geothermal ResourcesBill Bartling – Inland District Deputy
PROCESS, STATUS AND NEXT STEPS FOR AQUIFER EXEMPTION
AUGUST 2016 CALIFORNIA STATE UNIVERSITY, BAKERSFIELD CALIFORNIA
DOGGR mission
The Division supervises the drilling, operation, maintenance, and P&A of oil, gas, and geothermal wells, to prevent damage to:
1. life, health, property, and natural resources;
2. underground and surface waters suitable for irrigation or domestic use;
3. oil, gas, and geothermal reservoirs.
All three elements form the foundation for the Aquifer Exemption application technical analysis with an emphasis on water. Beneficial uses of water include:
Municipal drinking water
Residential use
Agriculture and livestock
Industrial
Enhanced oil recovery
Oil in CaliforniaThe Inland District is responsible for 80+% of California oil and gas activities, comprising ~135,000 active wells:
• Producing
• Injecting
• Idle
• Orphan
Aquifer Exemption locations marked by red stars.
waters of the san joaquin valleyWaters are fresh on the east, saline on the west.
This is due to:fresh water recharge from the Sierra Nevada range via the Kern River and other waterways
sparse rainfall in the west to dilute saline formation waters
deeper formations deposited in marine environments in the central and western areas
Figure from:Gillespie, Kong and Anderson –CSUB 2016
Fresher –beneficial uses
saltier
aquifer exemption process
aquifer exemption process
Construction of technical
application
DOGGR District
Operators
Sign off by District
Delivery to HQ and SWB
SWB Review
Concurrence Letter / Start of Public Comment
Formal Delivery to EPA
Review and decision
Draft delivery to EPA
inland district aquifer exemption portfolio
in public comment stage Round Mountain
Fruitvale
Tejon
DOGGR proposal complete Cymric
McKittrick
Elk Hills Phase 1
Elk Hills Phase 2
MidwaySunset
Mt. Poso
Kern River
South Belridge
Kern Front
20 applications to be submitted to DOGGR Headquarters, State and Regional Water Quality Control Boards, the public and the US Environmental Protection Agency.
After reviewing the technical documentation and public comments, the US EPA will determine if it will grant an exemption – this determination is part of the US Safe Drinking Water Act.
proposals scheduled to be complete by the end of the month Poso Creek
Lost Hills
Edison
NE Edison
Jasmine
Jacalitos/Coalinga
N. Belridge
Kettleman Hills
To be deliveredon Monday
inland district aquifer exemption historical and planned timeline
federal exemption criteria
Exemption criteria as specified in 40 CFR 146.4
a) The aquifer does not currently serve as a source of drinking water
b) The aquifer cannot now, and will not in the future, serve as a source of drinking water because:
1) It is mineral, hydrocarbon, or geothermal energy producing, or can be demonstrated by a permit application for a Class II operation to contain hydrocarbons that considering their quantity and location are expected to be commercially producible
OR2) The aquifer is situated at a depth or location that makes the recovery of water for drinking water purposes economically or technologically impractical
OR3) The aquifer is so contaminated that it would be economically or technologically impractical to render that water fit for human consumption
OR
c) TDS is more than 3,000 and less than 10,000 and it is not reasonably expected to supply a public water system.
stateexemption criteria
Exemption criteria as specified in PRC 3131(a)
1. Criteria set forth in Section 146.4 of Title 40 of the Code of Federal Regulations
2. The injection of fluids will not affect the quality of water that is, or may reasonably be, used for any beneficial use
3. The injected fluid will remain in the aquifer or portion of the aquifer that would be exempted
vertical stratigraphiccontainmentIt must be demonstrated that zones proposed for exemption are stratigraphically isolated from actual or potential zones with waters with beneficial use.
lateral extents and thickness of vertical confining layersThe distribution and thickness of stratigraphic confining layers are defined and mapped from well data
vertical and lateral confinement
Vertical and lateral isolation of the proposed exempted zone from water wells with beneficial use must be demonstrated.
hydrocarbon producingDemonstration of hydrocarbon presence from producing wells, subsurface samples and well logs
mappingwater wellsAll water wells which produce for beneficial use within and for an effective distance beyond the proposed exemption are mapped and analyzed.
isolation of water wellsfrom exemption zoneIt must be demonstrated that the proposed exempted zones have containment boundaries, such as impermeable shales, faults or stratigraphic pinchouts to ensure that injected fluids remain in the exempted zone.
This diagram shows the proposed exempted zone and water wells in the area, several thousand feet separated from the proposed exempted zone.
water chemistryTypical water chemistry analysis including drinking water standards, proposed exempted aquifer chemistry and proposed injectate water chemistry.
Note that in this case, the quality of the injectate is higher than the native formation waters.
exemption criteria – inland district all aquifer exemption applications
in the inland district have “hydrocarbon bearing” as their primary criteria for some or all of the proposed exempted area.
many aquifers have high TDS
many aquifers are very deep with better quality water available much shallower
Field hydrocarbons present high TDS
Cymric X X
Elk Hills X X
McKittrick X X
Edison X
Edison NE X
Fruitvale X
Kern Bluff X
Jasmin X
Kern Front X
Kern River X
Mt. Poso X
Poso Creek X
Round Mountain X X
Tejon X
S. Belridge X X
Lost Hills X X
Jacalitos/Coalinga X X
Midway Sunset X X
N. Belridge X X
Kettleman Hills X X
next steps
completion of aquifer exemption proposals this month
submission to DOGGR HQ for review and comment
submission to State Water Boards for review and comment
public comment periods, draft submission to US EPA, public hearings
respond to comments
formal submission to US EPA
prioritize and initiate UIC project reviews for exempted aquifers
Department of ConservationDivision of Oil, Gas, and Geothermal ResourcesBill Bartling – Inland District Deputy
PROCESS, STATUS AND NEXT STEPS FOR AQUIFER EXEMPTION
AUGUST 2016 CALIFORNIA STATE UNIVERSITY, BAKERSFIELD CALIFORNIA