Task force hears RRC rules, regulations
by Christina Rowland
Mar 06, 2012 | 558 views | 0 0 comments | 2 2 recommendations | email to a friend | print
Members of the Eagle Ford Task Force learned about commercial disposal wells, flaring rules, storage pits and field rules from Railroad Commission (RRC) employees at their latest task force meeting on Jan. 26, at the Remote Logistics International (Three Rivers Lodge) site in Three Rivers.

The task force is a group of elected officials, environmental companies, industry representatives and educators who come together monthly to discuss topics that affect their area.

“The Eagle Ford Shale Task Force has direct contact with the Railroad Commission through its creator, Commissioner David Porter,” said Live Oak County Judge Jim Huff. “This committee hopes to play a role in managing what is changing the face of our South Texas area and hopes to alleviate some of the pitfalls seen in areas of similar development.”

Doug Johnson, manager of injection and/storage permits for the Railroad Commission, was the first to speak at the Jan. 26 meeting. He addressed injection wells and commercial disposal wells. There are numerous requirements for both injection and commercial disposal wells.

One of the main things Johnson explained is all the disposal wells must be separated from freshwater by rock or impervious beds. This must be verified with a letter from the Texas Commission on Environmental Quality (TCEQ).

If the well is to be a commercial disposal well, the land owner and all the land owners of the adjacent property must be notified, as well as the county clerk, and a notice must be published in the paper of record for the county in which the well will be located. The public has an allotted amount of time to object to a commercial disposal well before it is permitted.

There are additional requirements for both types of wells about which Johnson went into more detail. He told the group that “every year each injection well (operator) files a status report.” The status report tells how much was injected into the well that year.

More specifics about the rules for the injection wells and the permitting process can be found on the Railroad Commission website.

After each speaker, audience members were allowed to ask questions. One listener asked, “Are there monitor wells around injection wells to track aquifers?”

The answer was no, but the woman was told that there are groundwater districts that monitor aquifer levels and contamination.

Johnson continued, “In the event we have a mishap where groundwater may have been impacted, monitor wells are put in place.”

Marathon Asset Manager Kirk Spilman told the room his company has a policy to do baseline water testing for any producing well prior to it being built, but that is just a policy his company uses, not a requirement of the RRC.

Gil Bujano, deputy director oil and gas division for the RRC, was the next to stand up and speak to the group about flaring rules.

He said once a well is completed, the operator can allow it to flare for 10 days but there are exceptions to the rule. If the well is still in the completion stage, a permit is not needed either.

He said all rules were on the website pertaining to flaring and that rule 32 specifically applied to what they were talking about.

Storage pit rules and regulations were next on the agenda with Michael Sims, manager of environmental permits for the Railroad Commission, leading the discussion.

“The main thing we do is surface waste management,” he said.

The storage pits are exposed to the air rather than buried like disposal wells. There are regulations that pertain to new pits and pits that are acquired through land purchases.

His group also regulates water recycling and land farming. He was added to the agenda because the topic came up in a previous task force meeting.

He said he and his staff are much busier than they used to be. The staff of three is now up to eight and his department is still needing more people.

Last to speak was Bujano but this time about field rules. The Eagle Ford is divided into different fields and there are additional rules specific to those fields.

“If you aren’t intimately involved in the industry, you don’t understand how important some of these rules are,” Commissioner Porter told the group.

One company, EOG Resources, has filed applications to make some of the field rules (in Eagleville 1 and Eagleville 2) permanent where the company is doing a lot of work.

Judge Huff called the rules, “a matter of great importance to the mineral owner and the producer alike.”

Steve Ellis, senior division counsel for EOG Resources, said, “Regulations have been reasonable and we are supporting what the commission has done up to this point.”

While everyone who is part of the task force speaks highly of the group and the chance to be a part of it, some still have some feelings of uncertainty about the RRC rules.

“I think there are some gaps in the rules because of this fracking,” said Glynis Strause, dean of institutional advancement at Coastal Bend College, in a phone call after the meeting. “They are running back and forth so fast, we need to make sure we don’t create environmental issues because of expediency.”

The next task force meeting will be in February but a date and location are yet to be set.

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