Federal Underground Control Regulations and Their Impact on the Oil Industry (includes associated papers 12562 and 12569 )
- Jerry J. Wasicek (Union Oil Co.)
- Document ID
- Society of Petroleum Engineers
- Journal of Petroleum Technology
- Publication Date
- August 1983
- Document Type
- Journal Paper
- 1,409 - 1,411
- 1983. Society of Petroleum Engineers
- 4.6 Natural Gas
- 1 in the last 30 days
- 63 since 2007
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Distinguished Author Series articles are general, descriptiverepresentations that summarize the state of the art in an area of technology bydescribing recent developments for readers who are not specialists in thetopics discussed. Written by individuals recognized as experts in the area,these articles provide key references to more definitive work and presentspecific details only to illustrate the technology. Purpose: to informthe general readership of recent advances in various areas of petroleumengineering.
Until the U.S. Congress passed the Safe Drinking Water Act (PL 93-523)inDec. 1974, regulation of subsurface injection wells was the sole province ofthe individual states. The Safe Drinking Water Act placed permitting ofsubsurface injection wells under the control of the Environmental ProtectionAgency (EPA). However, states were Protection Agency (EPA). However, stateswere encouraged to adopt or modify their underground injection-control(UIC)regulatory programs to obtain EPA approval, thereby returning authority to thestates to administer the UIC program. This return is known as"primacy." Duringthe 1940's and early 1950's, oil-producing states on their own initiativeadopted effective regulations for subsurface disposal and injection wells usedin oil and gas operations. Among other objectives, state injection-well ruleswere designed to protect freshwater aquifers.
History gives convincing evidence that state regulations were effective inprotecting underground waters. Documented cases of pollution of freshwateraquifers by oilfield injection and disposal wells are few and limited in area.Congressional recognition of the effectiveness of state control programs wasevident in the original language of the Safe Drinking Water Act. However,Congress expressed its recognition more clearly in the Dec. 1980 amendments tothe act (PL 96-502) by instructing the EPA to grant approval to existing stateregulatory programs for oil and gas field injection wells programs for oil andgas field injection wells under general-standards rather than the more specificstandards imposed on other classes of injection wells. Part C of PL 93-523 setsout the requirements for approvable state programs. Originally, states wererequired to comply with Sec. 1422 (b)(1)(A). Among other conditions, thissection provided that a state program must meet all requirements of EPAregulations in effect under Sec. 1421. The Dec. 1980 amendments to the SafeDrinking Water Act added Sec. 1425, which allowed states greater flexibility inobtaining EPA approval for their existing Class II injection-well program. Sec.1425 gave states the option to demonstrate that their UIC program for Class IIwells generally meets the requirements of Sec. 1421 (b)(1), Subparagraphs (A)through (D), in lieu of the showing required under Sec. 1422 (b)(1)(A).Congress did include the provision in PL 93-523 that regulations and guidelinesadopted by the EPA and the states should not interfere needlessly with oil andgas operations (Sec. 1422[c]). The Senate committee report accompanying the actcomments further on this precaution as follows. ...This Amendment prohibitsregulations for state underground injection-control programs from prescribingrequirements which would interfere with oil or natural gas or disposal ofbyproducts associated with such production, except that such requirements areauthorized to be prescribed if essential to assure that underground sources ofdrinking water will not be endangered by such activity. ...The Committee'sintent in adopting this amendment was not to require an impossible burden ofproof on the states as a condition of promulgation of any such regulations.Rather, the Committee sought to assure that constraints on energy productionactivities would be kept as limited in scope as possible while still assuringthe safety of present and potential sources of drinking water. present andpotential sources of drinking water. Similar provisions were adopted withrespect to EPA regulations.
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