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