Groundwater Monitoring for Oil and Gas Well Stimulation; and Activities Associated with Underground Injection Control (UIC)
Notice of Public Comment Hearing: Proposed Aquifer Exemption
On August 20, 2015 the California Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR), in consultation with the State Water Resources Control Board and the Central Coast Regional Water Quality Control Board, sent notice regarding a proposal to expand the current aquifer exemption designation for the Dollie sands of the Pismo formation in the Arroyo Grande oil field (in unincorporated San Luis Obispo county near the intersection of Ormonde Road and Price Canyon Road). Subject to approval by the United States Environmental Protection Agency, the proposed aquifer exemption would allow the State, in compliance with the federal Safe Drinking Water Act, to approve Class II injection into the identified area, either for enhanced oil recovery or for injection disposal of fluids associated with oil and gas production.
San Luis Obispo September 21, 2015 4pm-7pm
1605 Calle Joaquin Road
San Luis Obispo, CA 93405
Documents related to the Aquifer Exemption proposal, and information regarding how to submit comments can be found on DOGGR's website.
- Developing Model Criteria for Groundwater Monitoring (Model Criteria)
- Fact Sheets
- Well Operator Groundwater Monitoring Plans & Request for Exemption from Groundwater Monitoring
- Electronic Submittal of Water Quality Data for Oil & Gas Groundwater Monitoring
- Property Owner Water Sampling & Designated Contractors
- Water Board Requirements Under SB4
- Underground Injection Control (UIC)
- Aquifer Exemption Review
- Useful Links
- More Information
Subscribe to our Oil and Gas Groundwater Monitoring (SB4) email list, located in the "Water Quality" section.
GROUNDWATER MONITORING FOR OIL AND GAS WELL STIMULATION
Senate Bill 4 (SB 4) requires the State Water Board to develop model criteria for groundwater monitoring (model criteria). The model criteria are to:
- Outline appropriate groundwater monitoring in areas of oil and gas well stimulation treatment
- Protect all waters designated for beneficial uses
- Prioritize monitoring that is or has the potential to be a source of drinking water
- Be developed by July 2015
- A regional groundwater monitoring program is to be implemented by January, 2016
- Public Participation and Communication Plan
WELL OPERATOR GROUNDWATER MONITORING PLANS & REQUESTS FOR EXEMPTION FROM GROUNDWATER MONITORING
DOGGR interim well stimulation regulations require well operators to submit a groundwater monitoring plan as part of their well stimulation treatment notices. A well operator may alternatively request an exclusion from the requirement to submit a groundwater monitoring plan if the absence of protected water can be demonstrated. If protected water is shown to be absent, the Water Boards will issue a letter of written concurrence to the well operator. The written concurrence letter is to be submitted by the well operator in their well stimulation treatment notice. Supporting documentation provided by the well operators to the Water Boards is available on the DOGGR Well Stimulation webpage.
ELECTRONIC SUBMITTAL OF WATER QUALITY DATA FOR OIL & GAS GROUNDWATER MONITORING
Data collected as part of groundwater monitoring in the vicinity of a well subject to stimulation is required to be submitted in an electronic format compatible with the State Water Board’s GeoTracker database, following the guidelines detailed in Chapter 30 (commencing with Section 3890) of Division 3 of Title 23 of the California Code of Regulations.
Information regarding the electronic submittal of water quality data related to groundwater monitoring is included in our Getting Started guide.
Please contact the GeoTracker help desk at Geotracker@waterboards.ca.gov or (866) 480-1028 for technical questions and support.
PROPERTY OWNER REQUESTED WATER SAMPLING & DESIGNATED CONTRACTORS
SB 4 requires copies of DOGGR-approved well stimulation treatment permits and information on available water sampling and testing to be provided to every owner or tenant whose property line location is:
- Located within 1,500 feet of the well that is to undergo well stimulation treatment, or
- Within 500 feet from the horizontal projection of all subsurface portions of the designated well to the surface.
In accordance with Public Resources Code (Pub. Resources Code), the notified party may request water quality sampling and testing on any water well or surface water suitable for drinking or irrigation, paid for by the owner/operator of the oil or gas well. Water samples can be collected for baseline measurements prior to the start of the well stimulation treatment (Pub. Resources Code, § 3160, subd. (d)(7)(A)).
Follow-up measurements (after well treatment stimulation) shall be on the same schedule as any pressure testing of the treated well's casing. If the operator does not conduct a pressure test on the treated well casing following well stimulation treatment, a follow-up water sample shall be made available at least once. This sampling and testing program is subject to audit and review by the State Water Board.
All water quality data collected as part of the property owner requested water sampling will be submitted to the State Water Board in an electronic format that is compatible with the State Water Board GeoTracker information system.
The State Water Board is required to designate one or more qualified independent third-party contractors to perform property owner requested water quality sampling and testing (Pub. Resources Code, § 3160, subd. (d)(7)(B)). If you have been contacted by a well operator and would like to have your water sampled by a designated contractor, please visit our List of Designated Contractors for Water Sampling.
To apply to become a designated contractor for water sampling, or if you are interested in learning more details, please visit: How to Become a Designated Contractor for Water Sampling
Information regarding the electronic submittal of water quality data related to property owner requested water sampling is included in our Getting Started guide.
WATER BOARD REQUIREMENTS UNDER SB4
SB 4 requires the Water Board(s) to:
- Consult with DOGGR during DOGGR’s development of regulations for well stimulation treatments.
- Enter into a formal agreement with DOGGR regarding roles and responsibilities in the regulation of well stimulation treatments.
- Designate one or more qualified third-party contractors that adhere to board-specified standards and protocols to perform property owner requested water quality sampling and testing.
- Audit and review sampling and testing conducted by the third-party contractor(s).
- Develop model groundwater monitoring model criteria by July 1, 2015, in consultation with DOGGR and other stakeholders that outline the approach to be implemented for either well-by-well or regional scale groundwater monitoring.
- Begin implementation of a regional groundwater monitoring program by January 1, 2016.
UNDERGROUND INJECTION CONTROL (UIC)
Injection wells, which carry and permanently place fluids underground, are a potential ground water contamination source if not properly sited, constructed and maintained. Injection wells are regulated by the United States Environmental Protection Agency (US EPA) under the authority of the Underground Injection Control (UIC) Program.
The UIC program defines six classes of wells according to the type of fluid they inject and where the fluid is injected. This categorization ensures that wells with common design and operating techniques are required to meet appropriate performance criteria for protecting underground sources of drinking water.
In California, wells that inject fluids associated with oil and natural gas production operations (Class II injection wells) are regulated by the Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR) Underground Injection Control (UIC) Program.
A 1988 Memorandum of Agreement between DOGGR and the State Water Resource Control Board (State Water Board) called for DOGGR to consult with the State Water Board during its consideration of UIC project permitting so that the State Water Board could assist with the protection of water resources. The 1988 MOA defined the following:
- DOGGR lead agency for Class II UIC Program oversight (enhanced oil recovery (EOR) wells, waste disposal wells, aquifer exemptions)
- DOGGR to consult with the Water Boards during its consideration of UIC project permitting so that the State Water Board could assist with the protection of water resources.
- Regional Water Boards lead agency for surface discharges (produced water disposal ponds)
The Governor’s Office has directed the State Water Board to assist DOGGR in the review of aquifer exemptions and other issues related to oil and gas wastewater disposal activities. In a February 6, 2015 letter to US EPA, DOGGR and State Water Board identified the approach to work together for more integrated oversight of the UIC program, including:
- Ensure that aquifers to be used for wastewater disposal are properly exempted
- Review proposed UIC project proposals submitted by well operators to ensure the protection of groundwater beneficial uses
- Review existing UIC injection wells that may be injecting into aquifers that may not have been properly exempted
On March 9, 2015, US EPA forwarded a letter to DOGGR and State Water Board outlining agreed upon deadlines and milestones for implementing the February 6, 2015 DOGGR and Water Board plan.
AQUIFER EXEMPTION REVIEW
DOGGR will forward to State Water Board aquifer exemption application along with DOGGR’s review recommendations for the application. The State Water Board, in consultation with the appropriate Regional Water Quality Control Board, will review the aquifer exemption application using the evaluation criteria outlined below. The State Water Board and DOGGR will work towards reaching a consensus to determine if the aquifer exemption application contains sufficient documented evidence to meet the criteria for an aquifer exemption.
- A review of current and future beneficial sources of water (e.g. domestic, municipal, irrigation, industrial)
- Pertinent elements of Regional Water Board Basin Plan(s)
- Technical demonstration by operator that the waste will remain in the exempted portion of the aquifer(s)
- Identification of underground sources of drinking water and exempted aquifers (Code of Federal Regulations, Title 40, Section 144.7)
- U.S. Environmental Protection Agency (US EPA) Guidance for Review and Approval of State Underground Injection Control (UIC) Programs and Revisions to Approved State Programs
- US EPA Aquifer Exemption Checklist
- Department of Conservation, Division of Oil, Gas and Geothermal Resources (DOGGR) oversees the drilling, operation, maintenance, and plugging and abandonment of oil, natural gas, and geothermal wells in California.
- FracFocus is a national hydraulic fracturing registry that is primarily concerned with groundwater protection. FracFocus also provides information on hydraulic fracking regulations in all 50 states.
- Environmental Protection Agency (US EPA) provides information about hydraulic fracturing and its environmental impacts. In addition, the EPA is currently studying the effects of hydraulic fracturing on drinking water resources. While the draft report is expected in 2014, a progress report outlining initial findings was released in December 2012.
- United States Geological Survey (USGS) provides information about the process of hydraulic fracturing and impacts of the use of hydraulic fracturing.
- Maps Depicting the Base of Fresh Water produced by the U.S. Geological Survey (USGS) for the Southern San Joaquin Valley and for the Sacramento Valley.
- USGS reports on Geology of the Fresh Ground-Water Basin of the Central Valley, California, with Texture Maps and Sections and Geologic Features and Ground-Water Storage Capacity of the Sacramento Valley California, respectively.
- Department of Conservation report on The Effects of Oilfield Operations on Underground Sources of Drinking Water in Kern County.
- Central Valley Regional Water Quality Control Board information on Oil Field issues
- Maximum Contaminant Level in drinking water
- Department of Water Resources well log permission form
FOR MORE INFORMATION
Receive updates by email on well stimulation treatment related activities. Subscribe to our Oil and Gas Groundwater Monitoring (SB4) email list, located in the "Water Quality Topics" category.
Questions or Comments? Please contact us at OilandGas@waterboards.ca.gov or (916) 323-1308.