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RAILROAD COMMISSION OF TEXAS

CO2 Storage

Dave Hill

History• The Railroad Commission (RRC) has regulated the

Oil and Gas Industry in Texas since the early 1900’s. • We don’t do railroads.• The Texas oil industry began injecting fluids into

productive formations (EOR) in the 1930’s, and the RRC regulated this activity from the start.

• In the late 1960’s injection of gas for EOR was tested in Texas, and expanded in the early 1970’s under the RRC.

• In the early 1980’s Texas was granted primacy by EPA for Class II injection.

• CCS / GS : Carbon capture and storage, OR Geologic Storage• UIC: Underground Injection Control.

This is a common designation for the program that regulates disposal and EOR wells.

• EOR: Enhanced Oil Recovery • USDW: Underground Source of Drinking Water Federal and

State Term (10,000 ppm) • AOR: Area of Review. This is done to ascertain the status of

nearby wells. For most Class II sites, this is a 1/4 mile radius around the subject well.

• MIT: Mechanical Integrity Testing (of a well)

Acronyms

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The Various Means of CCS

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Federal Overview• Class I wells are wells into which hazardous wastes and non-

hazardous industrial or municipal wastes are injected beneath the lowermost underground source of drinking water (USDW).

• Class II wells include enhanced oil recovery (EOR) injection wells and injection wells for the disposal of oil and gas wastes.

• Class III wells are associated with solution mining.• Class IV wells are wells used for the shallow injection of

hazardous wastes and have been banned except when used as part of authorized groundwater remediation projects.

• Class V wells include shallow injection of non-hazardous fluids not covered by Class I wells, and, in some cases, experimental wells.

• Class VI wells are recently created by EPA and are wells associated with CO2 capture and storage (CCS) activities.

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Senate Bill 1387 (SB 1387)

• SB1387: In 2009, the Texas Legislature passed, and the governor signed a bill, “relating to the capture, injection, sequestration, or geologic storage of carbon dioxide”. This was in response to a federal draft rule creating a new class of injection wells, known as Class VI wells under the Underground Injection Control (UIC) part of the Safe Drinking Water Act (SDWA). Other well classes remained unchanged.

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Anthropogenic Carbon Dioxide

• SB 1387 in large measure deals with anthropogenic CO2 which is “ carbon dioxide that would otherwise be released to the atmosphere…”. This includes CO2 that has been stripped from another fluid stream (ex: gas processing plant), or captured from an emissions source. This does not include naturally occurring CO2 recaptured, recycled, or reinjected as part of enhanced oil recovery (EOR) operations.

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16 TAC Chapter 5: RRC CO2 GS REGS

Site characterization AOR and corrective action Well construction/Plugging Mechanical integrity/Monitoring Emergency response Financial Security Post-injection facility care

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Plans Required

§5.203 (f): Logging and Sampling Before Injection §5.203 (h) Mechanical Integrity Testing §5.203 (i) Facility operating plan. §5.203 (j) Monitoring, Sampling & Testing After Initiating Operations §5.203 (k) P & A of Injection and Monitoring Wells. §5.203 (l) Emergency and Remedial response. §5.203 (m) Post Injection Care and Closure

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Notice and Hearing

• §5.204 includes notice and hearing requirements. This includes notice by local publication, placing a copy of the application in a public place in the nearest city, criteria for a list of persons to be notified, and requirements for a hearing.

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Fees, Financial Responsibility, and Financial Assurance• §5.205 includes description of Fees,

Financial Responsibility, and Financial Assurance requirements. This includes fees to be paid for permit applications, reporting requirements to verify financial responsibility, and criteria to be met for financial assurance regarding various operations and phases of the facility.

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Permit Standards

• §5.206 states RRC may issue a permit if:No endangerment/injury to oil, gas, other

minerals,Water protected from CO2 migration or displaced

fluids,No endangerment/injury to human health/safety,Reservoir suitable for preventing CO2

escape/migration,Applicant meets statutory and regulatory

requirements.

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Permit Standards• §5.206 states RRC may issue a permit if:

No endangerment/injury to oil, gas, other minerals,

Water protected from CO2 migration or displaced fluids,

No endangerment/injury to human health/safety,

Reservoir suitable for preventing CO2 escape/migration,

Applicant meets statutory and regulatory requirements.

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Permit Standards

• §5.206 also includes Implementation of plans modified or

approved in the application process. This includes plans for operations, sampling and monitoring, MIT, corrective action, well plugging, and emergency response.

Requirement of a Letter from RRC Groundwater Advisory Unit stating that the facility will not injure USDW’s.

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Reporting and Record Keeping

• §5.207 includes reporting and record keeping requirements. This includes test records and operating reports. Depending on the information reported, reporting frequency may be within 24 hours, or at other intervals such as monthly, semi-annual, or annual.

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Chapter 5: NEWEST REGULATIONSAssociated with EOR/EGR

PURPOSE: Provide for certification of GS of CO2 incidental to enhanced recovery operations for which:

there is a reasonable expectation of more than insignificant future production volumes or rates as a result of the injection of anthropogenic CO2 ; and

operating pressures no higher than reasonably necessary for enhanced recovery

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Chapter 5: NEWEST REGULATIONSAssociated with EOR/EGR

Registration for Certification

Requires registration of enhanced recovery facility for which the operator proposes to document GS of anthropogenic CO2

incidental to enhanced recovery

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Chapter 5: NEWEST REGULATIONSAssociated with EOR/EGR

Monitoring, Sampling and Testing Plan:

This is required for determination of the quantities of anthropogenic CO2 permanently stored within

the enhanced recovery reservoir. For this, there are two options.

§5.305 (2) is one of them. This includes “mass balancing or actual system modeling”

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Chapter 5: NEWEST REGULATIONSAssociated with EOR/EGR

Monitoring, Sampling and Testing Plan:

§5.305 (3) is the other option. The owner / operator may submit to RRC, a copy of the same information submitted to EPA under Subparts RR or UU of 40 CFR Part 98, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide.

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Federal Overview• Class I wells are wells into which hazardous wastes and non-

hazardous industrial or municipal wastes are injected beneath the lowermost underground source of drinking water (USDW).

• Class II wells include enhanced oil recovery (EOR) injection wells and injection wells for the disposal of oil and gas wastes.

• Class III wells are associated with solution mining.• Class IV wells are wells used for the shallow injection of

hazardous wastes and have been banned except when used as part of authorized groundwater remediation projects.

• Class V wells include shallow injection of non-hazardous fluids not covered by Class I wells, and, in some cases, experimental wells.

• Class VI wells are recently created by EPA and are wells associated with CO2 capture and storage (CCS) activities.

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Sources of CO2 and Users

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CO2 EOR Sources

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SACROC – Eastern Edge of Permian BasinScurry Area Canyon Reef Operators Committee (SACROC) unitized oil field

• Ongoing CO2 injection since 1972• Combined enhanced oil recovery (EOR) with CO2 sequestration• Depth to Pennsylvanian- Permian reservoir ~6,500 ft • Approximately 3900 miles of CO2 pipelines (Dooley et al)

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SACROC Well Map

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SACROC Previous CO2 Injection

KM currently operates SACROC and is providing much assistance with the project

3 trillion standard cubic feet (TCF) or 150 million metric tons (MMt) CO2 injected for enhanced oil recovery (EOR) since 1972 by multiple field operators (BEG, 1984; KM, 2008)

1.5 TCF (75 MMt) CO2 recovered as of October 1, 2008 (KM, 2008)

Southwest Partnership (SWP) researchers are among first to test if this CO2 is trapped in reservoir zones or if it has leaked into overlying strata

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BEG and TWDB Water Well Data at SACROCSurface geology from BEG Big Spring and Lubbock GAT sheetsGeologic units

Q – Quaternary undifferentiated

P-Eog – Paleocene-Eocene Ogallala

TrD – Triassic Dockum

P – Permian undifferentiated

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Cross Section

(modified from Duffin and Benyon, 1992) Rebecca C. Smyth, Bureau of Economic Geology, Gulf Coast Carbon Center, Jackson School of Geosciences, The University of Texas at Austin

and Brian McPherson, New Mexico Tech and University of Utah

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Temporal Trends of all TWDB & BEG Data

1930 1940 1950 1960 1970 1980 1990 2000 201010.0

100.0

1000.0

10000.0Outside SACROC

Inside SACROC

yearcon

cnet

rati

on

(m

g/L

)

HCO3-

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Temporal Trends of all TWDB & BEG Data

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SACROC AREA WATER QUALITY 36 of 60 wells completed in both Ogallala and Dockum Santa Rosa water- bearing units; 17 wells inside and 19 wells outside SACROC; highest data

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Historic CO2 Sales

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

CO2

Sale

s (M

Mcf

pd)

Year

Average Daily CO2 Sales - North America

Other

Dakota Gasification

MS/Gulf Coast

Rockies

Permian Basin

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Current Situation – CO2 EOR ProjectsGROWTH OF WW, U.S. and PERMIAN BASIN

CO2 EOR PROJECTS1992 - 2012

0

20

40

60

80

100

120

140

160

1992

1994

1996

1998

2000

2002

2004

2006

2008

2010

2012

YEAR

NO

. OF

PR

OJ

EC

TS

Worldwide Projects

U.S. Projects

Permian Basin Projects

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Current Situation – CO2 EOR Production

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Injection/Disposal Well Permit Testing and Monitoring Seminar Manual

• http://www.rrc.state.tx.us/forms/publications/HTML/pmt-outl.php#techrev

• I. Administrative Review Discusses administrative check that verifies that all filing requirements are satisfied

• II. Attachments for new wells Discusses the required attachments for injection permit applications

• III. Transfer and Amendments Discusses the transfer of permits and subsequent changes to permit conditions

• IV. Technical Review Discusses the review of the proposed injection well for compliance with well construction, operation, and injected fluid confinement requirements

• V. Permit Processing Discusses the various stages of processing the permit application • VI. Protested Applications Discusses the processing of applications that are protested

by an affected party • VII. Post Permitting Discusses filing, testing, and monitoring requirements after the

injection permit is issued.

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Administrative Review – Basic Filing requirements

1. Application Forms. Forms H-1 , and H-1A. (Injection into a Reservoir Productive of Oil or Gas, Rule 46).

NOTE: A productive reservoir is a reservoir with past or current production within a 2-mile radius of the proposed injection well.

If any part of the proposed injection zone is or ever has been productive, then the permit application should be filed on Form H-1/H-1A.

Please use the current Forms. Using older forms may result in requests for addition information and corresponding delays in permitting

Form W-14 , (Injection into a Formation Not Productive of Oil or Gas, Rule 9).

2. Fees. These fees are non-refundable. a. $100 disposal permit application (Rule 9) filing fee (per wellbore). b. $500 injection permit application (Rule 46) filing fee (per wellbore). c. $375 (additional) for each exception request.

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Post Permitting

1. Annual Monitoring Report (Form H-10): Every well operator with a valid injection permit must file an annual monitoring report unless the well is actively producing and they file an annual production status report (Form W-10 or G-10) instead.

2. Mechanical integrity test (Form H-5): A mechanical integrity test (MIT) must be performed before any fluids are injected into the well. Once the well is converted to injection, an MIT must be performed periodically for the life of the permit.

3. Completion report (Form W-2 or G-1): File a completion report within 30 days of conversion to reflect the actual completion of the well. UIC staff will review the actual completion against the proposed completion in the permit application.

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Facilities and Water WellsYear Drilling

PermitsActive Wells Injection

WellsWater Well Complaints*

2002 11,434 246,000 30,500 69

2003 14,654 238,000 30,700 42

2004 16,912 242,000 30,900 44

2005 19,548 246,000 31,300 38

2006 22,328 249,000 30,600 61

2007 23,916 250,000 30,600 42

2008 28,786 263,000 30,600 48

2009 15,917 274,000 30,800 47

2010 22,535 281,000 31,400 43

2011 28,300 281,000 31,500 83

* The majority of these complaints are drought related. Many others involve one time sampling events for oil and gas constituents, where lab data show no impact. About two wells per year are confirmed to be attributable to Oil & Gas activities.

* The majority of these complaints are drought related. Many others involve one time sampling events for oil and gas constituents, where lab data show no impact. About two wells per year are confirmed to be attributable to Oil & Gas activities.

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Contact Info

http://www.rrc.state.tx.us/

david.hill@rrc.state.tx.us 512 463 3011