WEBVTT

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<v Molly>Good morning, and thank you</v>

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for attending this webinar.

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You will be able to submit questions

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throughout the presentation,
by clicking the Q&amp;A button

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in the center of the
bottom of your window.

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You will see both the
questions and responses

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after they have been answered.

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Some questions may be
held for answer until the end

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of the presentation.

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Presentations and webinar
recordings are all available

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by navigating to RRC regulatory webinars

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from the Oil &amp; Gas
Workshops and Seminars page

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on the Railroad
Commission of Texas website.

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All right, let's go
ahead and get started.

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Our presenter this
morning is Rob Castillo

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from the Injection-Storage
Permits department

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in the technical permitting section

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of the oil and gas division.

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Rob, whenever you're ready.

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<v Rob>Thanks Molly.</v>

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How's it going everyone?

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My name is Rob Castillo.

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I am one of the technical parameters

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here at the Railroad Commission,
specifically the UIC group.

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First I just wanna thank
everyone for being here today.

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The fact that this is a
crazy time in our world

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and the fact that you're here,
means that you care about

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doing these applications correctly.

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Hopefully by the time I
finished this presentation,

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you'll feel a little
bit more comfortable

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about doing these permit
applications by yourself.

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All right, well, let's
go and get started.

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This is kind of just an overview

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of what we're gonna go over today.

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I'm gonna briefly talk about
the UIC Online Manual.

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I'm gonna go into a
little bit about the origins

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of our program but then we're
gonna get into the meat of it.

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We're gonna talk about
the permit application details.

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All right.

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I'm gonna talk about
the forms, attachments,

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the administrative
technical and seismic review

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that goes into this. All right.

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Then I'm going to wrap things up

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with the post permitting
protests and hearing.

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UIC Online Manual, this
is an amazing tool to use

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when you are doing your applications.

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Everything that I'm
gonna tell to you today,

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you can find it online.
Where can you find it?

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That's a great question.

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You can go to our
website, rrc.texas.gov.

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If you hover over oil and gas,

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it brings you down to a little drop box

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and you can go down
and click on publication

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and notices you click on that

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and that's gonna bring
you to this page right here.

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Under manuals, the
first little tab right there,

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I've got it circled, click on that link.

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It's an injection/disposal
well permitting.

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All right, click on that.

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We're almost there. I promise.

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These two pages right
here, they're just great.

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Specifically the summary
of standards and procedures,

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when you all call and say,

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"Hey, Rob, what do I do with this?

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What can I do about
my administrative review,

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the packer setting or anything?"

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We all have these links open.

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It's just so useful.

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The summary of standards and procedures,

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it has templates for a lot

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of the administrative review attachments

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that you're gonna need.

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It goes into detail about
the technical review

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that we do on your application.

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It just has a lot of great information

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that you're gonna need
to finish these applications.

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I highly recommend using
these UIC Online Manual.

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Because it really is gonna help you out,

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and it's a great tool to use.

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All right, just a brief
history of our program

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why did this all get started?

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Well, it was the Safe
Drinking Water Act of 1974.

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The main focus of this
was to protect human health

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and the fresh water
drinking sources that we use.

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From that the, UIC, I'm gonna
be using a lot of acronyms.

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The UIC or Underground
Injection Control program

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was created.

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In our program, what
we do is we prohibit

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the contamination of these USDW's,

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which in another acronym,
what is the USDW?

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I'm gonna define this
a little bit more later,

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but the USDW is an Underground
Sources of Drinking Water.

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We're focusing on protecting
the contamination of this USDW.

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In 1982, Texas being
the great state that we are,

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we got privacy.

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We took the steering wheel on it.

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Ever since we've
been really getting at it.

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Currently we've got about
33,000 active wells in our state.

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What does that mean?

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Well, that means that we
are the largest UIC program

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in the nation.

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Remember I told you about the USDW

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and what really defines it.

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The USWD, we define it as
anything as less than 10,000

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parts per million total
dissolved solids, or TDS,

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as you probably know.

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This is what the Safe
Drinking Water protects

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in both Statewide Rule 9 and 46.

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It's this fresh water that's
less than 10,000 parts

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per million.

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You also have probably
heard us talk about the BUQW

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or the Base of the Usable-Quality Water.

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That's anything less than 3,000 parts

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per million total dissolved solids.

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Then sometimes on
your determination letters

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you get from the groundwater unit,

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you'll see something
called Superior Water.

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That's anything less than a
1,000 parts per million TDS.

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Here's a great little chart that shows

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the different types of
classes that are monitored.

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The Commission, we
only do class two and three.

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Today we're mostly just
only gonna focus on class two.

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Class one, five and
six, I believe the TCEQ

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still monitors those class four,

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the BPA still looks over those.

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As you can see, 75% of the
applications in wells we have

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are secondary or enhanced recovery.

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24% are the disposal
wells, and 1% is brine mining

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or hydrocarbon storage.

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Most of our wells are
secondary and EOR wells.

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All right, so you decided
that you wanna do

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an injection disposal well.

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What form are you going to use?

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That's a great question
and it's a great starting point.

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If you are saying, you plan to dispose

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into a nonproductive formation,

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then you're going to
need to use a Form W-14.

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If you plan to inject

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or to dispose into a
productive formation,

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you're gonna need to
use a Form H-1 and H-1A.

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W-14 there's a Statewide
Rule 9. H-1 and H-1As,

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those are Statewide Rule 46.

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If you plan to inject
into multiple zones,

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do a H-1 and H1A because...

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What happens is whenever I get a W-14,

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what I do is I do a
two mile radius search

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around your well or
propose well, and if...

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What I look for is I look for current

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or historical production.

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Let's say you plan to
dispose into the X formation.

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I'm just making up a formation here.

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I'm going to go around and look.

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If I find any production,
current or historical

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in this X formation,

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I'm gonna have to make you
switch to an H-1 and H-1A.

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It's really unfortunate
when we have to ask you

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20 days into this,

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"Hey, you need to switch forms.

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You're gonna have to
renotify and republish."

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It's always important that
you know what form to use.

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If you ever have any questions,
feel free to give us a call.

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We'll try and help you out
as best as we can with this.

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Obviously down here at the bottom,

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it says you need a mail
the form and attachments

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to the UIC here in Austin,
and you gotta send a copy

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to the district.

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If you just sent it to
the district but not us,

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we're not gonna see it.

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Be sure you send us
the form and then a copy

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to the district office.

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All right, what's the real
difference from these forms

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other than being productive
and non-productive?

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Well, it was about 250 bucks.

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The form W-14 was $250 for the fee.

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The H-1 and H-1A fee is $500.

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Currently until the end of the year,

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we are waiving these fees.

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Exception requests, here's
a good one, these are $375.

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These are example, let's
say packer exceptions.

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Suppose you're an H-1,
you wanna set your packer

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higher than a 100 feet.

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You can potentially
do a packer exception.

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You got to pay this $375,
tubing casing exceptions,

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that's another 375, if
you wanna roll that way.

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These are actually still being charged.

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The fees for the forums

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are being waived until
the end of the year.

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Obviously there's fees
that include a surcharge,

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and these are nonrefundable.

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If you call us up to make a payment,

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we can't take your payment.

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You gotta call down to central records.

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They're gonna give you...

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They're gonna take the payment,

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and they will give you a receipt.

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Darlene Cottle, she's
the one who handles

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all of our transactions up here.

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If you wanna give her the receipt,

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or put it on your application,
the receipt number,

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that just speeds things up.

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The last point, applications
will not begin being processed

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until they are paid,
and that's important.

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We're gonna talk about...

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We're mostly gonna look at the H-1 form.

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The H-1's got... It's
actually two pages.

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The first page, this H-1, the top of it

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is the P-5 information.

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What are we gonna look for there?

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Well, you have to have
an active P-5 obviously.

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This is where you're gonna
list your operator name,

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your number, put your address.

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Right below that, it's gonna
be more the P-4 information.

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Got to have the active P-4
just so you list your lease name,

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number, field name, all that good stuff.

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Be sure you fill all
this out appropriately.

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Going down, well,
actually, you know what?

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We're gonna talk about
field names real quick.

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Determining the field names,
most of you already know

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the field names you're
going to use for these wells.

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For H-1 and H-1A, the field
name, it should be correlative

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to the injection/disposure formation.

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It should be.

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If you're using multiple formations,

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you're gonna use the
deepest correlative formation.

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That's what you're
gonna use, or you keep

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the current field name
if the well's already

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on a proration schedule.

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That's for H-1A. For W-14,
it should be correlative

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to the formation more
than two miles away,

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or to the formation that is the source

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of your disposal fluids.

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Most of you already know
what field you're gonna use,

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but like I said, it
can get a little tricky.

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If you have a question, hit us up,

00:12:12.930 --> 00:12:15.173
we'll help you out for sure on this one.

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Going down further on that H-1,

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this is where you're
gonna list the reservoir data.

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This is the geology part of it.

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All you geology buffs out there.

00:12:28.250 --> 00:12:31.846
We give you four lines
to spew your heart out.

00:12:31.846 --> 00:12:34.530
This is where we really
want you to talk about

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the lithology, what you
know about the permeability,

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the porosity, bottom hole pressure.

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We need this filled out
because when it comes

00:12:43.200 --> 00:12:45.800
to sometimes if you go
through a seismic review,

00:12:45.800 --> 00:12:47.963
this stuff really comes
in handy to know.

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Be sure that you fill
the reservoir data part

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out as best as you know.

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Going down the H-1 again,

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this is the injection project data.

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This is the meat of that.

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This is pretty much
where you're gonna tell us

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what you're planning to do.

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21, this is... What is this?

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We wanna know what is this gonna be.

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Is this a water flood, pressure
maintenance, disposal well?

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This is where you let us know.

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Something about these,

00:13:18.620 --> 00:13:23.170
currently we are working
to better our forms.

00:13:23.170 --> 00:13:24.710
It can be a little confusing on this.

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If you look at item 21,

00:13:26.510 --> 00:13:29.738
the boxes correlate to
what's to the left of them.

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Right there, water flood
has a box to the right of it.

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What we see a lot of the times

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is when people mean disposal well,

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they'll check thermal recovery.

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It can be a little confusing

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because other does not have a checkbox.

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That's where it confuses somebody.

00:13:45.750 --> 00:13:48.710
Like I said, we're working
to better our forms.

00:13:48.710 --> 00:13:50.580
We're trying to make it a
little bit more user friendly,

00:13:50.580 --> 00:13:52.793
but it's something we see all the time.

00:13:52.793 --> 00:13:55.220
People wanna select disposal,

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but they'll actually
select thermal recovery.

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It's just something to look out for

00:13:59.600 --> 00:14:01.773
when you're checking these boxes.

00:14:03.070 --> 00:14:05.670
Item 23, if you plan to do...

00:14:05.670 --> 00:14:07.370
Be a commercial disposal well,

00:14:07.370 --> 00:14:09.490
this is where you're gonna let us know.

00:14:09.490 --> 00:14:13.040
Then item 25, this is where
you're gonna let us know

00:14:13.040 --> 00:14:15.270
what's going to be injected.

00:14:15.270 --> 00:14:16.910
We gotta know what
you're planning to inject,

00:14:16.910 --> 00:14:20.373
salt water, CO2, RCRA listed here.

00:14:24.600 --> 00:14:26.273
All right, now we're on the H-1A.

00:14:26.273 --> 00:14:27.783
This is page two.

00:14:29.210 --> 00:14:31.270
At first it's a little
bit redundant, right?

00:14:31.270 --> 00:14:33.750
It's the P-5 information all over again.

00:14:33.750 --> 00:14:36.083
Then going down to your P-4 stuff again,

00:14:37.039 --> 00:14:39.450
P-4 you get a little bit more detail.

00:14:39.450 --> 00:14:42.000
It's gonna talk about
the latitude, longitude.

00:14:42.000 --> 00:14:44.473
We need directions to the nearest town.

00:14:45.726 --> 00:14:46.740
As you can see further down,

00:14:46.740 --> 00:14:48.760
it talks about well construction.

00:14:48.760 --> 00:14:51.030
This is where you are gonna tell us

00:14:51.030 --> 00:14:53.060
about your proposed well construction,

00:14:53.060 --> 00:14:56.093
or if it's already drilled what's there.

00:14:57.064 --> 00:14:59.230
If it's already drilled, it should match

00:14:59.230 --> 00:15:00.965
what's in our records right now.

00:15:00.965 --> 00:15:04.196
If it doesn't, we're gonna
have to send what's called rad,

00:15:04.196 --> 00:15:07.940
which is a request for
additional information

00:15:07.940 --> 00:15:10.370
to clarify what's going on.

00:15:10.370 --> 00:15:13.207
Maybe you did some work, but
you never let us know about it.

00:15:13.207 --> 00:15:15.450
We need to take care of all that

00:15:15.450 --> 00:15:17.500
before we can get
this permit out to you.

00:15:21.630 --> 00:15:23.730
Further down the
H-1A, this is pretty much

00:15:23.730 --> 00:15:26.660
where you tell us the
injection interval you plan to go.

00:15:26.660 --> 00:15:29.370
Your packer depth, max daily injection

00:15:29.370 --> 00:15:31.340
volume you're requesting

00:15:31.340 --> 00:15:33.370
and your max surface injection pressure.

00:15:33.370 --> 00:15:36.130
All right, what I really
wanna stress on this

00:15:36.130 --> 00:15:38.240
is if you are planning to do this

00:15:38.240 --> 00:15:42.980
to a directional
horizontal well, it is crucial

00:15:42.980 --> 00:15:44.830
that for really anything depth related

00:15:44.830 --> 00:15:49.830
that you list both TVD
and Measured Depth.

00:15:50.100 --> 00:15:53.390
Total Vertical Depth and Measure Depth.

00:15:53.390 --> 00:15:54.920
For sure on the injection interval,

00:15:54.920 --> 00:15:59.085
we need that packer depth,
tubing depth, TD plug backs,

00:15:59.085 --> 00:16:00.880
really anything with depths.

00:16:00.880 --> 00:16:02.970
We need both MD and TVD,

00:16:02.970 --> 00:16:05.733
if this is a directional
horizontal well.

00:16:07.400 --> 00:16:09.510
You're also gonna have
to list that on the article,

00:16:09.510 --> 00:16:12.370
which I'll get into
that in a little bit.

00:16:12.370 --> 00:16:16.040
Be sure if it's a directional
well, you put TVD on there

00:16:16.040 --> 00:16:16.873
for your depths.

00:16:19.880 --> 00:16:23.793
Finally, down at the
bottom, H-1, it's the signature.

00:16:24.930 --> 00:16:27.140
There's not a spot, and once again,

00:16:27.140 --> 00:16:29.440
I stress, we're working on our forms.

00:16:29.440 --> 00:16:31.210
There's not a spot for your email.

00:16:31.210 --> 00:16:32.970
We like when you put
your email right there

00:16:32.970 --> 00:16:34.145
above your signature.

00:16:34.145 --> 00:16:38.013
It really helps speed up
correspondence between us.

00:16:38.930 --> 00:16:40.960
It really helps because if not,

00:16:40.960 --> 00:16:43.240
we're gonna have to
send it in the old snail mail.

00:16:43.240 --> 00:16:44.870
That could be everything from a rad

00:16:44.870 --> 00:16:46.650
to actually issuing your permits.

00:16:46.650 --> 00:16:50.050
Obviously you would wanna
get your permit quicker.

00:16:50.050 --> 00:16:51.610
We like when you put
your email right there

00:16:51.610 --> 00:16:52.673
above your signature.

00:16:56.081 --> 00:16:58.380
The administrative
review, so like I said,

00:16:58.380 --> 00:16:59.890
there's many parts of this review.

00:16:59.890 --> 00:17:02.450
There's the administrative,
technical, seismic

00:17:02.450 --> 00:17:04.020
and then there's final.

00:17:04.020 --> 00:17:06.170
Let's talk about the
administrative review.

00:17:08.810 --> 00:17:10.790
What are the permit specialists gonna do

00:17:10.790 --> 00:17:12.320
in part of this review?

00:17:12.320 --> 00:17:14.620
Well, they're gonna make
sure that your fees are paid,

00:17:14.620 --> 00:17:15.920
like I said.

00:17:15.920 --> 00:17:19.470
They're gonna make sure that
the form is full and complete.

00:17:19.470 --> 00:17:21.870
They make sure all the
attachments are there

00:17:21.870 --> 00:17:24.470
and they're gonna
actually build the folder

00:17:24.470 --> 00:17:28.443
and enter your application
into our tracking system.

00:17:32.230 --> 00:17:34.470
Another thing they're gonna
do is they're gonna make sure,

00:17:34.470 --> 00:17:36.830
like I said earlier, they're
gonna make sure you've got

00:17:37.859 --> 00:17:38.790
a current P-5 on file.

00:17:38.790 --> 00:17:42.430
Make sure your corporation
and franchise taxes are paid.

00:17:42.430 --> 00:17:44.260
They're gonna make sure the P-4 is okay.

00:17:44.260 --> 00:17:47.390
Verify that you are the
operator of the lease.

00:17:47.390 --> 00:17:49.670
For a new lease, you file form P-4

00:17:49.670 --> 00:17:51.020
with the completion report.

00:17:52.420 --> 00:17:54.820
They're gonna make
sure that this application

00:17:54.820 --> 00:17:56.820
isn't already an existing UIC well.

00:17:56.820 --> 00:17:57.653
It happens.

00:17:57.653 --> 00:17:59.500
Sometimes you take over a well

00:17:59.500 --> 00:18:01.940
and you didn't know that it
already had a UIC permit on it.

00:18:01.940 --> 00:18:05.393
We've seen it before, so
they're gonna do all that.

00:18:08.970 --> 00:18:10.460
There's gonna be a good bit of documents

00:18:10.460 --> 00:18:12.519
that you're gonna have to submit

00:18:12.519 --> 00:18:14.447
for the administrative review.

00:18:14.447 --> 00:18:15.987
The Notice of Application.

00:18:15.987 --> 00:18:19.307
What we want you to
do is we want you to notify

00:18:19.307 --> 00:18:21.400
a good bit of people about this.

00:18:21.400 --> 00:18:24.360
We want you to mail or deliver a copy

00:18:24.360 --> 00:18:27.770
of either the W-14 or the H-1.

00:18:27.770 --> 00:18:30.110
Here's an important part, front and back

00:18:30.110 --> 00:18:33.010
to the surface owner.

00:18:33.010 --> 00:18:35.230
Hopefully they know what's going on.

00:18:35.230 --> 00:18:38.091
If this is the commercial
disposal application,

00:18:38.091 --> 00:18:40.641
you're gonna need to notify
adjacent service owners

00:18:41.910 --> 00:18:44.660
operators of active
wells within a half mile

00:18:44.660 --> 00:18:48.490
of your proposed well, the county clerk,

00:18:48.490 --> 00:18:51.400
and if your well is located
within the city limits,

00:18:51.400 --> 00:18:53.480
you need to notify the city clerk.

00:18:53.480 --> 00:18:55.423
If not, you don't
need to worry about it.

00:18:56.340 --> 00:18:58.380
I said, front and back,
and that's important

00:18:58.380 --> 00:19:00.430
because on the back
of these applications

00:19:01.313 --> 00:19:04.330
is instructions for the
people to be able to protest.

00:19:04.330 --> 00:19:06.880
That's why we wanna know
that they have the ability

00:19:06.880 --> 00:19:08.910
to do that if they want.

00:19:08.910 --> 00:19:11.930
It's important you send
both front and back

00:19:11.930 --> 00:19:13.980
of the applications
to all these parties.

00:19:17.104 --> 00:19:19.460
Some more documents, like I said,

00:19:19.460 --> 00:19:22.176
is you're gonna have
to submit a labeled map

00:19:22.176 --> 00:19:25.800
showing the location of
the wells within a half mile

00:19:25.800 --> 00:19:27.850
of your proposed
injection disposal well.

00:19:28.863 --> 00:19:31.700
If this were a commercial disposal well,

00:19:31.700 --> 00:19:33.610
you're gonna need to provide a plan

00:19:33.610 --> 00:19:35.160
showing the surface track boundaries

00:19:35.160 --> 00:19:38.080
of all the adjacent track boundaries.

00:19:38.080 --> 00:19:41.460
I've got a good example of
that here on the next page.

00:19:41.460 --> 00:19:43.010
We also, finally, we're gonna need you

00:19:43.010 --> 00:19:45.590
to list all the names of
all those affected parties

00:19:45.590 --> 00:19:48.310
and then pretty much just
have a signed statement

00:19:48.310 --> 00:19:52.384
indicating that you sent
that form to all those people.

00:19:52.384 --> 00:19:53.900
We need a signed statement

00:19:53.900 --> 00:19:56.000
pretty much just
saying that you did this.

00:19:57.620 --> 00:19:59.704
That track boundary I was talking about,

00:19:59.704 --> 00:20:02.830
this is a good example
of what it should look like.

00:20:02.830 --> 00:20:05.090
There, you can see
a well pad right there

00:20:05.090 --> 00:20:06.780
on the Gary Stearns.

00:20:06.780 --> 00:20:08.040
Obviously you had submitted

00:20:08.040 --> 00:20:11.860
to the M A Snell Investments
Trust, the Dorothy Garrett,

00:20:11.860 --> 00:20:14.450
but what about this
Dorothy Garrett family,

00:20:14.450 --> 00:20:16.669
is right directly across
the road, this little road.

00:20:16.669 --> 00:20:20.980
What many people don't know
is you would want to send it

00:20:20.980 --> 00:20:22.430
to the Dorothy Garrett family,

00:20:22.430 --> 00:20:25.470
just because it touches that
infant dismally, small point,

00:20:25.470 --> 00:20:27.570
that corner in that little roads there

00:20:27.570 --> 00:20:29.370
doesn't mean we don't
need to notify them.

00:20:29.370 --> 00:20:30.703
You need to notify them,

00:20:31.730 --> 00:20:34.070
because it touches
just that little corner.

00:20:34.070 --> 00:20:36.123
That means they got to get notified.

00:20:37.200 --> 00:20:38.410
Like I said, if you have any questions

00:20:38.410 --> 00:20:40.800
on who you need to notify, call us up,

00:20:40.800 --> 00:20:42.853
our permit specialists
are great at this.

00:20:43.857 --> 00:20:47.837
They know how to look at
these and they will help you out

00:20:47.837 --> 00:20:50.443
and let you know who you should notify.

00:20:53.580 --> 00:20:56.110
Further going on to you
hearing me talk about

00:20:56.110 --> 00:20:58.960
the commercial disposal wells.

00:20:58.960 --> 00:21:01.230
Let me break that down for you.

00:21:01.230 --> 00:21:04.350
There are three things that make you...

00:21:05.290 --> 00:21:08.670
Requirements, not things that make you

00:21:08.670 --> 00:21:12.710
a commercial disposal
well, and it has to be all three.

00:21:12.710 --> 00:21:14.350
If you're just one of them, you're not

00:21:14.350 --> 00:21:17.575
a commercial disposal
well. What are they?

00:21:17.575 --> 00:21:22.575
They are, if your waste is
partially or wholly tripped in,

00:21:25.650 --> 00:21:26.880
that's one.

00:21:26.880 --> 00:21:30.610
If there's a disposal fee or a
compensation being charged,

00:21:30.610 --> 00:21:31.970
that's the second one,

00:21:31.970 --> 00:21:34.370
and this is your primary
purpose of business.

00:21:34.370 --> 00:21:36.770
If you meet all three of those, yes.

00:21:36.770 --> 00:21:39.390
What you are is going to be
a commercial disposal well.

00:21:39.390 --> 00:21:42.350
If you're just one of them, you're not.

00:21:42.350 --> 00:21:43.430
This happens a lot.

00:21:43.430 --> 00:21:46.574
I get this a lot. People
call up say, hey, Rob.

00:21:46.574 --> 00:21:48.680
It's being parked trucked over there,

00:21:48.680 --> 00:21:50.100
but it's not the other two.

00:21:50.100 --> 00:21:52.220
Then, no, you're not a
commercial disposal well.

00:21:52.220 --> 00:21:55.140
If you meet all three
of these, then yes,

00:21:55.140 --> 00:21:57.123
this is a commercial disposal well.

00:21:58.010 --> 00:21:59.990
This last part is just,
there's a little bit more

00:21:59.990 --> 00:22:01.640
that goes into the facilities

00:22:01.640 --> 00:22:03.200
for these commercial disposal well.

00:22:03.200 --> 00:22:05.480
It's just saying that
all the spill prevention

00:22:05.480 --> 00:22:07.690
and all containment, it's gotta be done

00:22:07.690 --> 00:22:09.290
before you even start disposing.

00:22:11.320 --> 00:22:12.203
That's obvious.

00:22:13.850 --> 00:22:18.040
Going back, so more on
the administrative review

00:22:18.040 --> 00:22:20.090
like I said, we want you
to notify a lot of people.

00:22:20.090 --> 00:22:21.620
That means you got to put it...

00:22:21.620 --> 00:22:25.970
We want you to publish it
for one day in a newspaper

00:22:25.970 --> 00:22:28.470
that's in general
circulation in the county.

00:22:28.470 --> 00:22:31.251
If you're down South San
Antonio, don't put it in Dallas.

00:22:31.251 --> 00:22:33.983
We want it in general
circulation in the county.

00:22:35.580 --> 00:22:39.090
We want you to actually
submit the newspaper clipping

00:22:39.090 --> 00:22:42.285
with a notarized
affidavit of publication.

00:22:42.285 --> 00:22:43.640
We have a template.

00:22:43.640 --> 00:22:45.203
Remember that UIC Online Manual

00:22:45.203 --> 00:22:47.360
I was talking about in the beginning,

00:22:47.360 --> 00:22:49.580
there's a template of this affidavit

00:22:49.580 --> 00:22:51.640
on the administrative review,

00:22:51.640 --> 00:22:53.763
and it just lines it out for you.

00:22:55.513 --> 00:22:57.470
Then here at the bottom,

00:22:57.470 --> 00:23:00.020
it says obviously a
15-day waiting period

00:23:00.020 --> 00:23:01.770
after the notice and period,

00:23:01.770 --> 00:23:03.240
after the notice and publication,

00:23:03.240 --> 00:23:05.750
that's when we start that protest window

00:23:05.750 --> 00:23:07.183
after this notice period.

00:23:09.138 --> 00:23:12.310
What do you put on this
published notice text?

00:23:12.310 --> 00:23:14.770
Well, it should match the application

00:23:14.770 --> 00:23:16.353
pretty straightforward.

00:23:17.578 --> 00:23:20.340
It's gonna have direction
and miles to the nearest town.

00:23:20.340 --> 00:23:23.930
We want you to list your
interval, if you're doing H-1A,

00:23:23.930 --> 00:23:25.390
and you got a bunch of wells on there,

00:23:25.390 --> 00:23:27.410
just do the shallowest and the deepest.

00:23:27.410 --> 00:23:30.053
That way you cover the whole thing.

00:23:30.940 --> 00:23:33.150
If this is gonna be a commercial well,

00:23:33.150 --> 00:23:36.330
so you plan to inject
certain things like H2S

00:23:36.330 --> 00:23:40.420
or NORM, NORM is Naturally
Occurring Radioactive Material.

00:23:40.420 --> 00:23:42.700
You need to put that on there.

00:23:42.700 --> 00:23:45.430
Of course you gotta put instructions

00:23:45.430 --> 00:23:48.110
for people to be able
to protest the application

00:23:48.110 --> 00:23:50.560
on the publish notice tax.

00:23:50.560 --> 00:23:52.740
Once again, there's
an example of all this

00:23:52.740 --> 00:23:54.760
on that UIC Online Manual.

00:23:54.760 --> 00:23:57.573
You can see why it's
just a great tool to use.

00:24:01.438 --> 00:24:04.290
That wrapped up the
administrative review.

00:24:04.290 --> 00:24:06.650
The technical review,
hopefully I know a little bit more

00:24:06.650 --> 00:24:09.203
about this, because this is what I do.

00:24:11.490 --> 00:24:13.070
One of the first things we look for

00:24:13.070 --> 00:24:16.000
in the technical reviews, is
we look at the GAU Letters

00:24:16.000 --> 00:24:17.453
and Geologic Isolation.

00:24:18.770 --> 00:24:22.240
The Groundwater
Advisor Unit, or the GAU,

00:24:22.240 --> 00:24:25.930
issues, these GW-2s.

00:24:25.930 --> 00:24:27.801
GW-2s are these

00:24:27.801 --> 00:24:30.110
Groundwater Protection
Determination Letters.

00:24:30.110 --> 00:24:34.201
It is important that when
you're filing for your GW-2,

00:24:34.201 --> 00:24:37.320
that when it comes to
the little part that says,

00:24:37.320 --> 00:24:39.340
what is the purpose of this filing

00:24:39.340 --> 00:24:41.720
that you fill this out correctly?

00:24:41.720 --> 00:24:44.730
If you're doing this for
an H-1, purpose of filing

00:24:44.730 --> 00:24:46.820
must be H-1.

00:24:46.820 --> 00:24:48.990
If you're doing this for
W-14, purposes of filing

00:24:48.990 --> 00:24:52.380
must be W-14. Why do we say that?

00:24:52.380 --> 00:24:53.630
Because sometimes if you do something

00:24:53.630 --> 00:24:57.167
like a new drill purpose,
they won't put the USDW on it.

00:24:57.167 --> 00:24:59.753
We wanna know where the USDW is on it.

00:25:00.667 --> 00:25:02.890
It has to be valid too.

00:25:02.890 --> 00:25:06.160
If you've done one within five years,

00:25:06.160 --> 00:25:08.690
it should be okay. It's gonna be okay.

00:25:08.690 --> 00:25:10.220
Anything older than five years,

00:25:10.220 --> 00:25:12.080
we'd have to get you to do a new one.

00:25:12.080 --> 00:25:14.090
It's just really important
that you get the purpose

00:25:14.090 --> 00:25:15.313
for filing correct.

00:25:16.410 --> 00:25:17.870
Because with the W-14s,

00:25:17.870 --> 00:25:20.260
they're gonna also send a second letter

00:25:20.260 --> 00:25:22.520
that's called a no harm letter saying

00:25:22.520 --> 00:25:24.523
that there's adequate isolation there.

00:25:26.690 --> 00:25:29.323
You hear about me talking
about all this isolation.

00:25:30.380 --> 00:25:32.870
What are we really looking
for when it comes to isolation?

00:25:32.870 --> 00:25:37.170
Well, Statewide Rule 46
says we're looking for 250 feet

00:25:38.599 --> 00:25:42.730
of isolating strata between the top

00:25:42.730 --> 00:25:46.443
of your interval and the Base
of the Usable-Quality Water.

00:25:47.850 --> 00:25:49.613
Now, that's cumulative.

00:25:51.100 --> 00:25:56.020
Cumulative 250 feet of
isolation, low permeability strata,

00:25:56.020 --> 00:26:01.010
shales, clays and hydrides,
that's what we're looking for.

00:26:01.010 --> 00:26:03.240
When it comes to isolation from USDW,

00:26:03.240 --> 00:26:07.383
we're looking for at least 50
feet of continuous isolation.

00:26:09.110 --> 00:26:10.700
A pre-primacy wells,

00:26:10.700 --> 00:26:14.183
or these are wells without
adequate separation.

00:26:15.780 --> 00:26:20.380
If you're in this category of
pre-primacy or aquifer exempt,

00:26:20.380 --> 00:26:24.210
that means you are
allowed to inject closer

00:26:24.210 --> 00:26:26.920
to these BUQ and UCW.

00:26:26.920 --> 00:26:30.023
However, we're gonna add a
condition on your permit saying,

00:26:30.023 --> 00:26:33.980
it's called FSL or Fluid Source Limit.

00:26:33.980 --> 00:26:37.110
What that says is you can only inject

00:26:37.110 --> 00:26:40.930
or dispose fluids that
were pulled directly

00:26:40.930 --> 00:26:43.660
from the same lease in same formation.

00:26:43.660 --> 00:26:45.040
We're just saying,
you're just putting back

00:26:45.040 --> 00:26:47.270
what's already come from there.

00:26:47.270 --> 00:26:49.410
That's part of the
whole aquifer exemption,

00:26:49.410 --> 00:26:51.200
not everyone's aquifer exemption.

00:26:51.200 --> 00:26:53.470
I'm gonna tell you that right now,

00:26:53.470 --> 00:26:55.380
but if you have questions, like I said,

00:26:55.380 --> 00:26:57.299
give us a call and
we'll look it up for you.

00:26:57.299 --> 00:26:58.460
We've got a program and we can run it,

00:26:58.460 --> 00:27:00.660
run it through and
check real quick for you.

00:27:03.610 --> 00:27:05.430
E-log, your electric log.

00:27:05.430 --> 00:27:06.840
All right.

00:27:06.840 --> 00:27:09.830
We want you to submit
a complete electric log

00:27:09.830 --> 00:27:13.160
with header that shows the proposed zone

00:27:13.160 --> 00:27:15.130
in overlying strata.

00:27:15.130 --> 00:27:18.890
Let's say your interval is
from 1,000 to 2,000 feet.

00:27:18.890 --> 00:27:22.250
Your log should go
at least to 2,000 feet.

00:27:22.250 --> 00:27:25.550
Sometimes we get people
who will only send us a log

00:27:25.550 --> 00:27:26.697
that cuts off at 900.

00:27:26.697 --> 00:27:28.270
No, we need to see the whole interval.

00:27:28.270 --> 00:27:30.800
We wanna see everything
that's going on down

00:27:30.800 --> 00:27:32.000
to your bottom interval.

00:27:33.060 --> 00:27:35.970
If you're doing an H-1A, you
got multiple wells on there.

00:27:35.970 --> 00:27:38.000
You're just gonna do one log.

00:27:38.000 --> 00:27:40.791
We don't need the
application to be books,

00:27:40.791 --> 00:27:44.810
a huge application.

00:27:44.810 --> 00:27:47.910
Another thing that's gonna help us out

00:27:47.910 --> 00:27:52.083
is you can submit these logs online.

00:27:52.083 --> 00:27:55.680
Use the digital well
logs submission online.

00:27:55.680 --> 00:27:57.600
I can literally just go in there

00:27:57.600 --> 00:28:00.610
and tie your application
to your submission.

00:28:00.610 --> 00:28:02.900
If you wanna give us
a submission number,

00:28:02.900 --> 00:28:04.340
say you did do it online,

00:28:04.340 --> 00:28:06.510
all you gotta do is
do a little screenshot

00:28:06.510 --> 00:28:08.950
of whenever you submitted your well log.

00:28:08.950 --> 00:28:11.210
Just do a screenshot of
that and attach it to your form,

00:28:11.210 --> 00:28:13.620
your application, and I
can literally just go in there

00:28:13.620 --> 00:28:15.060
and tie it to your application.

00:28:15.060 --> 00:28:16.363
It's so easy.

00:28:19.840 --> 00:28:22.570
All right, if you annotate your log,

00:28:22.570 --> 00:28:24.140
you get brownie points from us.

00:28:24.140 --> 00:28:29.140
It really does help us
out to confirm isolation

00:28:31.277 --> 00:28:33.615
and the protection
of all this fresh water.

00:28:33.615 --> 00:28:38.615
If you label all the impermeable
strata, that's amazing.

00:28:39.023 --> 00:28:41.210
We'd love to see that in all these.

00:28:41.210 --> 00:28:43.140
Obviously it doesn't
happen all the time,

00:28:43.140 --> 00:28:45.040
but if you do kudos to you.

00:28:45.040 --> 00:28:46.053
I mean, it's great.

00:28:47.000 --> 00:28:50.140
Annotations help in
those close call scenarios.

00:28:50.140 --> 00:28:53.411
Whenever we're trying to
say is there enough data?

00:28:53.411 --> 00:28:56.323
Should this be okay

00:28:56.323 --> 00:28:58.166
when it comes to a close
call on a size of review?

00:28:58.166 --> 00:28:59.295
Will say, you know what?

00:28:59.295 --> 00:29:00.128
They already annotated the log.

00:29:00.128 --> 00:29:01.550
Boom, here we go.
Let's just move forward.

00:29:01.550 --> 00:29:04.310
It just speeds things up whenever we get

00:29:04.310 --> 00:29:06.653
to these tough cases, tough scenarios.

00:29:10.740 --> 00:29:14.670
All right, the AOR, you heard
me talk about a half-mile map

00:29:14.670 --> 00:29:16.640
back with administrator review.

00:29:16.640 --> 00:29:17.910
Well, for the technical review,

00:29:17.910 --> 00:29:21.410
we need a quarter-mile AOR done.

00:29:21.410 --> 00:29:24.670
We also need you to submit a table

00:29:24.670 --> 00:29:27.520
of all the wells within that AOR.

00:29:27.520 --> 00:29:29.693
They should have at
least name, the number,

00:29:30.790 --> 00:29:33.631
API, all the good stuff,
plug status, all that.

00:29:33.631 --> 00:29:36.790
Also, you're going to need to confirm

00:29:36.790 --> 00:29:38.940
that the wells are on
a proration schedule

00:29:38.940 --> 00:29:40.543
and have been properly plugged.

00:29:42.160 --> 00:29:43.430
I'm actually gonna walk you through

00:29:43.430 --> 00:29:48.430
on how you can make an
AOR map, using our GIS Viewer.

00:29:49.830 --> 00:29:51.200
If you, once again,

00:29:51.200 --> 00:29:55.140
go to our Commission
website, rrc.texas.gov,

00:29:55.140 --> 00:29:57.040
down here in the bottom link you can see

00:29:57.040 --> 00:29:58.010
it says useful links.

00:29:58.010 --> 00:30:00.880
You can click on map Public GIS Viewer,

00:30:00.880 --> 00:30:04.040
or you can just click
on the map right there.

00:30:04.040 --> 00:30:08.201
That'll bring you to our
amazing GIS Viewer.

00:30:08.201 --> 00:30:10.590
Here's what it looks like.

00:30:10.590 --> 00:30:12.435
Let me see if I can
zoom in a little bit more.

00:30:12.435 --> 00:30:14.690
You see that little... The bull's eye

00:30:14.690 --> 00:30:16.570
that's got a green dot in the middle.

00:30:16.570 --> 00:30:18.030
What that is going to allow you to do

00:30:18.030 --> 00:30:21.300
it's gonna allow you to select a radius.

00:30:21.300 --> 00:30:23.972
What it's gonna do is any
well that's in that radius

00:30:23.972 --> 00:30:26.500
that's gonna pretty much
pull all the information

00:30:26.500 --> 00:30:29.970
on those wells, and it's gonna
create an Excel file for you.

00:30:29.970 --> 00:30:33.250
You enter in your API
or your coordinates,

00:30:33.250 --> 00:30:36.180
select your radius, click
on the well, and boom.

00:30:36.180 --> 00:30:38.519
You see how it highlights
all the wells right there

00:30:38.519 --> 00:30:39.413
in your AOR.

00:30:40.540 --> 00:30:43.170
Then you click export
to CSV that creates

00:30:43.170 --> 00:30:45.060
this Excel spreadsheet.

00:30:45.060 --> 00:30:46.870
Then it's just what it
looks like right here.

00:30:46.870 --> 00:30:51.870
I mean, it gives you everything,
API, status, lat launch,

00:30:52.260 --> 00:30:54.310
and this is just a
shorted version of it.

00:30:55.310 --> 00:30:57.750
It tells you everything,
and this is pretty much

00:30:57.750 --> 00:31:00.380
your quarter-mile table
that we're asking for.

00:31:00.380 --> 00:31:04.517
This is such a great tool
to use on top of the manual

00:31:04.517 --> 00:31:06.993
to use, when you're
doing these applications.

00:31:09.260 --> 00:31:11.640
Here's an example of an amazing...

00:31:11.640 --> 00:31:13.000
We would love to see this all the time.

00:31:13.000 --> 00:31:15.300
It doesn't happen, but we
would love to see it like this.

00:31:15.300 --> 00:31:16.970
It's numbered, color-coded,

00:31:16.970 --> 00:31:18.323
I mean, this is amazing.

00:31:20.430 --> 00:31:23.590
You can see here that
the numbers correspond

00:31:23.590 --> 00:31:25.690
to the table on the next page.

00:31:25.690 --> 00:31:27.860
When we're going through
and saying this one here

00:31:27.860 --> 00:31:29.830
is a plug one, here's her dry well.

00:31:29.830 --> 00:31:31.380
Here, this is where it goes.

00:31:31.380 --> 00:31:33.270
This is what we would love to see.

00:31:33.270 --> 00:31:35.230
If you can do this, that's amazing.

00:31:35.230 --> 00:31:36.233
This is great.

00:31:39.010 --> 00:31:43.740
What happens, let's
say you have some wells

00:31:43.740 --> 00:31:46.410
in your quarter mile that have a status

00:31:46.410 --> 00:31:50.623
of unknown dry hole or plug.

00:31:52.160 --> 00:31:55.360
What we're gonna need, even
though we may have the records

00:31:55.360 --> 00:31:56.840
in our system.

00:31:56.840 --> 00:32:01.840
We need you to submit a
plugging records for those wells.

00:32:01.980 --> 00:32:06.539
Either W-3s or the good old form four.

00:32:06.539 --> 00:32:09.860
We need to see them
for any wells that are listed

00:32:09.860 --> 00:32:13.710
as plugged, dry hole or are known

00:32:13.710 --> 00:32:15.210
that are in your quarter mile.

00:32:16.390 --> 00:32:20.660
If you cannot find any of these records,

00:32:20.660 --> 00:32:22.930
sometimes you call the district up,

00:32:22.930 --> 00:32:25.030
because sometimes if
you can't find it on your own,

00:32:25.030 --> 00:32:26.130
call your district office up,

00:32:26.130 --> 00:32:28.551
maybe they can help
you out a little bit on that.

00:32:28.551 --> 00:32:30.190
There's some other things you can do.

00:32:30.190 --> 00:32:34.580
Say, hey, Rob, I can't
find these plugging records,

00:32:34.580 --> 00:32:36.860
then there's another route to go.

00:32:36.860 --> 00:32:38.290
Well, there's two routes.

00:32:38.290 --> 00:32:41.250
You can either plug
those wells yourself.

00:32:41.250 --> 00:32:43.610
Nobody really wants to do that it seems,

00:32:43.610 --> 00:32:47.043
or you can submit these
pressure front calculations.

00:32:48.360 --> 00:32:51.170
The whole purpose of
this quarter mile review

00:32:51.170 --> 00:32:55.570
is to ensure that if there are
any improperly plugged wells

00:32:56.522 --> 00:32:59.410
within a quarter mile
of your proposed well,

00:32:59.410 --> 00:33:02.790
that, if you were to
start injecting disposing

00:33:02.790 --> 00:33:05.440
in your proposed well,
that a fluid migrated

00:33:05.440 --> 00:33:09.180
to this problem well, that
it would not migrate up

00:33:09.180 --> 00:33:11.083
and contaminate the USDW.

00:33:12.720 --> 00:33:13.960
Like I said, the other
route you could do

00:33:13.960 --> 00:33:16.460
is these Pressure Front Calculations.

00:33:16.460 --> 00:33:19.230
These calculations
are going to show that

00:33:19.230 --> 00:33:22.660
this either that will happen,
that fluid will migrate

00:33:22.660 --> 00:33:24.930
to this nearest problem
well, and that it says,

00:33:24.930 --> 00:33:25.763
you know what?

00:33:25.763 --> 00:33:29.110
It won't reach the USDW or that it will.

00:33:29.110 --> 00:33:31.530
Now, these have to be prepared

00:33:31.530 --> 00:33:35.090
by a Texas registered
professional engineer.

00:33:35.090 --> 00:33:37.593
In my first seminar I
did, a lady asked me,

00:33:37.593 --> 00:33:39.890
does it have to be a Texas PE?

00:33:39.890 --> 00:33:41.160
The answer is, yes,

00:33:41.160 --> 00:33:44.260
it has to be a Texas
registered professional engineer.

00:33:44.260 --> 00:33:45.730
Those are some routes
that you need to go.

00:33:45.730 --> 00:33:49.040
Just to wrap that
up, if you have a well,

00:33:49.040 --> 00:33:53.330
wells that are listed as
plugged, dry hole or unknown

00:33:53.330 --> 00:33:56.290
within a quarter mile, one first thing,

00:33:56.290 --> 00:33:58.240
the easiest thing
submit plugging records,

00:33:58.240 --> 00:34:00.090
that'd be threes or form fours.

00:34:00.090 --> 00:34:02.699
If you can't do that, you
press your front calculation,

00:34:02.699 --> 00:34:06.410
you need a PE to do it,
to show that the USDW

00:34:06.410 --> 00:34:09.980
would not be contaminated,
or if you can't do that,

00:34:09.980 --> 00:34:12.680
then lastly, you just gotta
plug those wells yourself.

00:34:15.630 --> 00:34:17.640
All right, when you set Surface Casing,

00:34:17.640 --> 00:34:19.940
so what are the
requirements we look for that?

00:34:21.310 --> 00:34:24.840
If you're a new drill, if this
is gonna be a new drill well,

00:34:24.840 --> 00:34:28.680
or if it's for a
commercial disposal well,

00:34:28.680 --> 00:34:33.680
you have to set surface
casing through the BUQW.

00:34:34.000 --> 00:34:35.340
Remember what the BUQ is that Base

00:34:35.340 --> 00:34:36.740
of the Usable-Quality Water.

00:34:38.240 --> 00:34:40.693
If you're converting
an old production well,

00:34:42.390 --> 00:34:44.940
then, and let's say, you didn't know...

00:34:44.940 --> 00:34:47.770
They didn't know where
the BUQ was back then.

00:34:47.770 --> 00:34:50.810
They say casing short,
surface casing short

00:34:50.810 --> 00:34:52.530
of where we know it is now,

00:34:52.530 --> 00:34:55.320
then what we're gonna
do is we're gonna issue

00:34:55.320 --> 00:34:58.130
what's called PTT
cam. It's just what it is.

00:34:58.130 --> 00:34:59.000
It's annual.

00:34:59.000 --> 00:35:03.263
It's an annual H-5 with weekly
tubing and casing monitoring.

00:35:04.558 --> 00:35:07.160
Remember if it's for a new drill

00:35:07.160 --> 00:35:09.040
or a commercial disposal well,

00:35:09.040 --> 00:35:11.863
you gotta set that surface
casing through the BUQ.

00:35:14.980 --> 00:35:16.533
All right, long string casing.

00:35:17.470 --> 00:35:18.970
What are we looking for on here?

00:35:18.970 --> 00:35:20.567
Well, we're looking
for your top of cement

00:35:20.567 --> 00:35:22.215
and it has to be adequate.

00:35:22.215 --> 00:35:24.960
If you are calculating
your top of cement,

00:35:24.960 --> 00:35:27.120
if it's based off calculation,

00:35:27.120 --> 00:35:30.350
we need to see at
least 600 feet of cement

00:35:30.350 --> 00:35:32.950
above the top injection interval.

00:35:32.950 --> 00:35:34.327
All right, what if you say,

00:35:34.327 --> 00:35:37.348
"Hey, Rob it's already been done.

00:35:37.348 --> 00:35:40.040
I'm gonna run a temperature survey

00:35:40.040 --> 00:35:42.170
to show where my top of cement is."

00:35:42.170 --> 00:35:43.003
I say, great.

00:35:43.003 --> 00:35:46.770
Well, I need to see 250 feet
with the temperature survey

00:35:46.770 --> 00:35:48.728
of cement above your top interval.

00:35:48.728 --> 00:35:52.200
Let's just say, hey, you say,
hey, Rob, I wanna run a CBL

00:35:52.200 --> 00:35:54.280
or a Cement Bond Log.

00:35:54.280 --> 00:35:57.590
Then we only need to
see a 100 feet of cement

00:35:57.590 --> 00:35:59.143
above the top interval.

00:36:00.570 --> 00:36:02.740
It's gotta be at least 80% bonded.

00:36:02.740 --> 00:36:05.843
That's key. We can't see
any occasion of channeling.

00:36:06.710 --> 00:36:10.010
Once again, if you're
doing your top of cement

00:36:10.010 --> 00:36:13.570
of calculation, it's gotta be
600 feet above your interval,

00:36:13.570 --> 00:36:15.490
250 feet for your temperature survey,

00:36:15.490 --> 00:36:17.840
if you wanna go that
way or 100 feet for a CBL.

00:36:21.490 --> 00:36:23.790
All right, packer setting,
this is a good one.

00:36:25.270 --> 00:36:28.890
If for W-14 Statewide Rule
9, there is no wiggle room.

00:36:28.890 --> 00:36:32.420
You have to set your
packer within a 100 feet

00:36:32.420 --> 00:36:34.493
of your top permitted zone.

00:36:35.350 --> 00:36:36.400
That is it.

00:36:36.400 --> 00:36:38.640
There's no wiggle room on that one.

00:36:38.640 --> 00:36:41.830
For a H-1 and H-1A,
there's a little wiggle room.

00:36:41.830 --> 00:36:44.140
Remember that packer
exception fee I was talking about,

00:36:44.140 --> 00:36:47.310
it was 375. Suppose
you wanna set your packer

00:36:47.310 --> 00:36:49.640
a little bit higher than 900 feet,

00:36:49.640 --> 00:36:51.700
this is the route you can go.

00:36:51.700 --> 00:36:53.690
You can say, hey, I
wanna do an exception

00:36:53.690 --> 00:36:55.890
or I wanna apply for an exception.

00:36:55.890 --> 00:36:56.840
You gotta pay the fee.

00:36:56.840 --> 00:36:58.940
That's one thing you gotta do.

00:36:58.940 --> 00:37:01.853
You gotta submit an annotated log.

00:37:02.930 --> 00:37:05.420
We got to see, and you
gotta label it and say,

00:37:05.420 --> 00:37:07.670
hey, Rob, I'm gonna
set this packer up here.

00:37:07.670 --> 00:37:11.810
I'm gonna show you that there
are no permeable formations

00:37:11.810 --> 00:37:15.180
between where this packer's
going in that top interval.

00:37:15.180 --> 00:37:16.060
That's number two.

00:37:16.060 --> 00:37:18.096
We're gonna look to make sure

00:37:18.096 --> 00:37:20.540
there's no permeable
formations in between your packer

00:37:20.540 --> 00:37:22.180
or the top interval.

00:37:22.180 --> 00:37:25.470
We're also gonna make sure
that there's at least 200 feet

00:37:25.470 --> 00:37:26.990
of cement above that packer.

00:37:26.990 --> 00:37:31.230
That's three, and that
you're at least 150 feet

00:37:31.230 --> 00:37:32.130
away from the BUQ.

00:37:33.180 --> 00:37:35.120
There's four things that make it.

00:37:35.120 --> 00:37:38.370
You got to pay that fee, you
gotta submit the annotated log,

00:37:38.370 --> 00:37:40.700
200 feet of cement above your packer,

00:37:40.700 --> 00:37:45.173
and it's gotta be at least
150 feet away from the BUQ.

00:37:46.260 --> 00:37:49.400
W-14s, no wiggle room,
gotta be within a 100 feet

00:37:49.400 --> 00:37:50.800
at the top of your interval.

00:37:52.911 --> 00:37:55.020
Injection pressures.

00:37:55.020 --> 00:37:55.930
How do we do this?

00:37:55.930 --> 00:37:58.460
Well, we do it as typical maximum

00:37:58.460 --> 00:38:02.560
is a half psi per foot of depth.

00:38:02.560 --> 00:38:03.560
What does that mean?

00:38:04.530 --> 00:38:08.700
Let's say your top
interval is 1,000 feet.

00:38:08.700 --> 00:38:11.100
We do 1,000 times 0.5.

00:38:11.100 --> 00:38:14.440
That means your max
service injection pressure

00:38:14.440 --> 00:38:16.133
is 500 psi.

00:38:17.170 --> 00:38:20.880
Now, for certain
scenarios, this can change.

00:38:20.880 --> 00:38:22.633
For coastal wells, shallow coastal wells

00:38:22.633 --> 00:38:24.453
that are less than 2,000 feet.

00:38:25.359 --> 00:38:26.970
So you're gonna be injecting
above that Barnett Shale

00:38:26.970 --> 00:38:28.883
up in Dallas area, North Texas,

00:38:29.720 --> 00:38:32.440
or if you're injecting into
the Delaware formations,

00:38:32.440 --> 00:38:37.440
we may, may, limit to
a quarter psi per foot.

00:38:39.320 --> 00:38:41.963
Instead of that thousand,
they could be what, 250.

00:38:43.350 --> 00:38:44.500
That's just an example.

00:38:45.730 --> 00:38:49.800
If you're in these areas, you
may be limited, keyword may,

00:38:49.800 --> 00:38:52.370
to this quarter psi per foot.

00:38:52.370 --> 00:38:54.230
All right, here's the last bullet.

00:38:54.230 --> 00:38:58.340
Fracture step-rate test
may, and that's a big word,

00:38:58.340 --> 00:39:00.793
may justify a higher pressure.

00:39:02.260 --> 00:39:07.260
We have guidelines on our
step-rate tests on our UIC Manual.

00:39:07.279 --> 00:39:10.340
While engineers have
worked hard on this,

00:39:10.340 --> 00:39:12.190
and it is a great tool to use.

00:39:12.190 --> 00:39:15.070
We actually lay down
as far as how these tests

00:39:16.327 --> 00:39:18.430
should be done and everything.

00:39:18.430 --> 00:39:19.668
Look on that manual and see,

00:39:19.668 --> 00:39:21.600
if you're gonna do
a step-rate test to try

00:39:21.600 --> 00:39:24.437
and justify higher volumes of pressures,

00:39:24.437 --> 00:39:27.040
I would highly advise reading our manual

00:39:27.040 --> 00:39:29.583
on the guidelines for step-rate tests.

00:39:35.655 --> 00:39:38.283
All right, ejection fluids.

00:39:39.560 --> 00:39:43.080
If you plan to inject H2S,

00:39:43.080 --> 00:39:47.940
we require well specific
story that Statewide Rule 36.

00:39:47.940 --> 00:39:51.571
You're gonna have to go
through a public hearing,

00:39:51.571 --> 00:39:53.550
if you're planning the H2S.

00:39:53.550 --> 00:39:56.253
You're also gonna need
administrative approval

00:39:56.253 --> 00:39:59.583
from your district
office H2S coordinator.

00:40:01.290 --> 00:40:02.690
Really, the best part, when you...

00:40:02.690 --> 00:40:05.990
If you're gonna do H2S,
call your district office up,

00:40:05.990 --> 00:40:08.090
say, hey, I need to talk
to my H2S coordinator

00:40:08.090 --> 00:40:09.280
and they will help you out.

00:40:09.280 --> 00:40:11.330
There's certain forms
you've got to fill out.

00:40:11.330 --> 00:40:13.887
Like I said, you gotta get
this public hearing possibly.

00:40:13.887 --> 00:40:17.490
There's some duties
you're gonna have to do

00:40:17.490 --> 00:40:19.277
to be able to inject H2S.

00:40:21.500 --> 00:40:23.170
Now, if you're planning
to do fresh water,

00:40:23.170 --> 00:40:25.793
there's almost just as
much, maybe even more.

00:40:27.310 --> 00:40:29.673
You're gonna have to submit a Form H-7.

00:40:31.110 --> 00:40:32.550
We're also gonna want you to fill out

00:40:32.550 --> 00:40:35.043
what's called a
freshwater questionnaire.

00:40:36.340 --> 00:40:38.740
We're gonna need you to submit a plat

00:40:40.173 --> 00:40:41.290
of all the freshwater rights

00:40:41.290 --> 00:40:44.343
and finally a chemical
analysis of the freshwater.

00:40:46.770 --> 00:40:50.648
There's a lot that goes
into planning to inject H2S

00:40:50.648 --> 00:40:51.520
and freshwater.

00:40:51.520 --> 00:40:53.310
A lot of people can't
find the questionnaire.

00:40:53.310 --> 00:40:55.100
Sometimes it gets hidden, but if...

00:40:55.100 --> 00:40:56.190
Here's a hint.

00:40:56.190 --> 00:40:59.280
If you go to our website
and you type in questionnaire

00:40:59.280 --> 00:41:01.030
in our search box, it's
literally the only thing

00:41:01.030 --> 00:41:02.340
that pops up.

00:41:02.340 --> 00:41:04.750
I don't know why it's so
hard to find, but if you go...

00:41:04.750 --> 00:41:07.047
If you wanna just
search for it, it will pop up.

00:41:07.047 --> 00:41:09.613
That's the only thing
in our search engine.

00:41:12.635 --> 00:41:15.210
All right, that was a technical review.

00:41:15.210 --> 00:41:16.610
We're doing great here.

00:41:16.610 --> 00:41:17.993
Seismic review.

00:41:18.920 --> 00:41:20.720
Let's talk about the seismic review.

00:41:23.460 --> 00:41:26.683
Let's say you're an H-1
disposal or the W-14.

00:41:27.860 --> 00:41:32.860
There is a seismic
events over 2.0 magnitude

00:41:33.710 --> 00:41:38.280
within a 9.08 kilometer radius
around your proposed well.

00:41:38.280 --> 00:41:41.193
That triggers this seismic review.

00:41:43.800 --> 00:41:46.480
There were amendments
to the rules 9 and 46.

00:41:46.480 --> 00:41:48.570
They were made in 2014.

00:41:48.570 --> 00:41:52.860
These amendments say
that the Commission, RRC,

00:41:52.860 --> 00:41:56.726
may modify suspend or terminate a permit

00:41:56.726 --> 00:42:01.440
if disposal is likely to be contributing

00:42:01.440 --> 00:42:03.720
to seismic activity.

00:42:03.720 --> 00:42:05.550
This is also when we started requiring

00:42:05.550 --> 00:42:09.840
this seismic information
with disposal applications.

00:42:09.840 --> 00:42:11.850
I'm gonna show you actually how to do

00:42:11.850 --> 00:42:13.483
one of this seismic screenings.

00:42:15.636 --> 00:42:18.720
The second point is just
including a seismic survey

00:42:18.720 --> 00:42:21.023
from the USGS catalog.

00:42:22.140 --> 00:42:24.663
We will take into
consideration, text net.

00:42:25.745 --> 00:42:28.030
There's USGS catalog
and the text net catalog.

00:42:28.030 --> 00:42:29.990
I'm gonna show you both of them.

00:42:30.910 --> 00:42:32.390
Here's the link for the USGS.

00:42:32.390 --> 00:42:33.303
It's on here.

00:42:34.800 --> 00:42:36.670
Text net looks like this.

00:42:36.670 --> 00:42:39.000
Here's a link for that.

00:42:39.000 --> 00:42:40.860
Text net is a little
bit more user friendly,

00:42:40.860 --> 00:42:45.070
but I'm gonna show you
how to do your seismic search

00:42:45.070 --> 00:42:46.973
via the USGS.

00:42:47.830 --> 00:42:49.010
This just says, like I said,

00:42:49.010 --> 00:42:51.914
RRC staff will consider both USGS

00:42:51.914 --> 00:42:56.503
and text net catalogs in
assessing seismic trigger.

00:42:58.456 --> 00:43:02.043
Be sure you not only just
do USGS, you check text net.

00:43:03.711 --> 00:43:05.700
That way you're not surprised
when we come back and say,

00:43:05.700 --> 00:43:08.200
hey, you're gonna do a
size of review and you say,

00:43:08.200 --> 00:43:10.270
no, there's no events in USGS.

00:43:10.270 --> 00:43:11.130
I said, well, there may be.

00:43:11.130 --> 00:43:13.170
There was one in text next.

00:43:13.170 --> 00:43:15.900
Be sure you just check text net.

00:43:15.900 --> 00:43:17.400
That way you're not surprised.

00:43:22.340 --> 00:43:24.440
Actually I think this
page is just talking about

00:43:24.440 --> 00:43:27.120
how to get to it, where
you're gonna modify the date

00:43:27.120 --> 00:43:30.470
and time, the magnitude
and update the latitude

00:43:30.470 --> 00:43:31.642
and longitude.

00:43:31.642 --> 00:43:34.940
You're gonna need to
submit screenshots of all this.

00:43:34.940 --> 00:43:36.590
Let me just show you
what it's gonna look like.

00:43:36.590 --> 00:43:39.840
On that link, it'll take
you to the catalog.

00:43:39.840 --> 00:43:43.930
The catalog starts off with
this, this magnitude date

00:43:43.930 --> 00:43:45.215
and time.

00:43:45.215 --> 00:43:49.260
On magnitude, you
obviously need to customize it.

00:43:49.260 --> 00:43:50.476
Minimum should be two.

00:43:50.476 --> 00:43:53.880
We're looking for
anything only above 2.0.

00:43:55.329 --> 00:43:59.317
Date and time, you need to
set it at 1973, one January 1st.

00:44:00.745 --> 00:44:03.780
That's when this all,
this catalog started.

00:44:03.780 --> 00:44:05.770
Obviously the end date
should be whatever date

00:44:05.770 --> 00:44:06.933
you ran the tool.

00:44:09.060 --> 00:44:10.330
Screenshot of this.

00:44:13.591 --> 00:44:15.170
Bringing it to the advanced options.

00:44:15.170 --> 00:44:16.160
Right here under circle,

00:44:16.160 --> 00:44:19.375
this is where you enter your
(indistinct) launch in that 83.

00:44:19.375 --> 00:44:22.000
That's the datum we want you to use.

00:44:22.000 --> 00:44:25.530
Be sure you do outer radius of 9.08.

00:44:25.530 --> 00:44:27.420
That's what we're looking for.

00:44:27.420 --> 00:44:29.850
Submit a screenshot of this,

00:44:29.850 --> 00:44:32.040
and then you click go
and then what it should do,

00:44:32.040 --> 00:44:35.060
if you have events,
it'll look like this.

00:44:35.060 --> 00:44:36.143
This is what it will look like.

00:44:36.143 --> 00:44:38.190
Then do a screenshot of this.

00:44:38.190 --> 00:44:40.230
If you don't have events in your radius,

00:44:40.230 --> 00:44:42.700
a little box will prompt up and say,

00:44:42.700 --> 00:44:45.280
there were no events in the radius

00:44:45.280 --> 00:44:47.460
and just do a screenshot
of that and attach it.

00:44:47.460 --> 00:44:48.450
That's it.

00:44:48.450 --> 00:44:50.796
Like I said, be sure you check text net,

00:44:50.796 --> 00:44:52.099
because you don't wanna get surprised.

00:44:52.099 --> 00:44:55.990
Text net picks up an
event that USGS didn't.

00:44:55.990 --> 00:44:57.793
Remember we consider both catalogs.

00:45:01.500 --> 00:45:04.523
This supplemental info for seismicity.

00:45:07.330 --> 00:45:09.903
If we see that there is
an earthquake over 2.0

00:45:09.903 --> 00:45:13.470
in your radius, we're gonna
at first issue a rad saying,

00:45:13.470 --> 00:45:16.460
hey, we need some
geologic maps from you.

00:45:16.460 --> 00:45:20.120
These are structure maps,
Isopach maps and cross sections,

00:45:20.120 --> 00:45:22.150
kind of gonna give us a
little bit more information

00:45:22.150 --> 00:45:23.940
about the geology area.

00:45:23.940 --> 00:45:27.270
We want you to show your
faults, formation, thickness,

00:45:27.270 --> 00:45:29.210
all that good stuff on these.

00:45:29.210 --> 00:45:31.433
We wanna have all these for our records.

00:45:32.380 --> 00:45:35.100
Suppose I grade it and
it needs what's called

00:45:35.100 --> 00:45:37.670
a fault slip potential,
that's something else

00:45:37.670 --> 00:45:39.490
that could be required.

00:45:39.490 --> 00:45:43.050
If you have any relevant
information that can assist

00:45:43.050 --> 00:45:44.970
in the scoring, please submit it.

00:45:44.970 --> 00:45:47.357
Just give us everything
you know about the geology

00:45:47.357 --> 00:45:48.610
of the area.

00:45:48.610 --> 00:45:50.530
Geology of the area.

00:45:50.530 --> 00:45:51.993
It really does help us out.

00:45:56.270 --> 00:45:57.790
The purpose of the
supplemental information

00:45:57.790 --> 00:46:00.419
is to help us do a
better seismic review.

00:46:00.419 --> 00:46:03.929
We grade these on an ABC scale.

00:46:03.929 --> 00:46:07.820
All right, I'm gonna
get into this seismic,

00:46:07.820 --> 00:46:08.984
the grading sheet.

00:46:08.984 --> 00:46:12.570
It's broken up into
three parts, faulting

00:46:12.570 --> 00:46:16.840
and seismicity, operational
factors and reservoir factors.

00:46:16.840 --> 00:46:20.220
Faulting and seismicity
is the biggest part

00:46:20.220 --> 00:46:22.683
of the seismic review as it should be.

00:46:23.580 --> 00:46:26.050
Operational factors that
takes into consideration

00:46:26.050 --> 00:46:31.050
any nearby wells that are
disposing into the same formation.

00:46:31.381 --> 00:46:33.370
What's the cumulative volume

00:46:33.370 --> 00:46:36.200
that's going into this formation
within the certain radius.

00:46:36.200 --> 00:46:37.470
We're gonna look at that.

00:46:37.470 --> 00:46:40.310
In reservoir factors, just
the theology of the rock,

00:46:40.310 --> 00:46:44.513
the characteristics of the
area that plays more into that.

00:46:46.263 --> 00:46:48.370
Faulting and seismicity
is the biggest chunk

00:46:48.370 --> 00:46:50.390
of this seismic review.

00:46:50.390 --> 00:46:52.057
Like I said, we grade on ABC.

00:46:54.710 --> 00:46:59.670
With each grade there are
limits and conditions added

00:46:59.670 --> 00:47:01.040
to your permit.

00:47:01.040 --> 00:47:04.170
Let's say you get a grade A.

00:47:04.170 --> 00:47:07.220
The max daily injection
volume for grade A

00:47:07.220 --> 00:47:09.900
is 30,000 barrels per day.

00:47:09.900 --> 00:47:14.900
For a grade B it's
20,000, grade C is 10,000.

00:47:16.039 --> 00:47:19.620
With all these, they're all
gonna get permit conditions

00:47:19.620 --> 00:47:20.453
on your permit.

00:47:21.300 --> 00:47:23.330
We're gonna have daily H-10 records

00:47:23.330 --> 00:47:25.440
that you're gonna have to submit.

00:47:25.440 --> 00:47:28.000
Initial static bottom
hole pressure test.

00:47:28.000 --> 00:47:30.160
That's another one that's gonna go on.

00:47:30.160 --> 00:47:32.240
If you're grade A and you're at 30,000,

00:47:32.240 --> 00:47:35.100
we're gonna ask you
to do a step rate tests.

00:47:35.100 --> 00:47:38.180
All grades, Cs need to be reviewed,

00:47:38.180 --> 00:47:39.950
are going to be reviewed

00:47:39.950 --> 00:47:43.260
by our state seismologist
for his approval.

00:47:43.260 --> 00:47:44.400
Why?

00:47:44.400 --> 00:47:46.110
We do this because, hey, you know what,

00:47:46.110 --> 00:47:48.610
sometimes we'll give him a C,

00:47:48.610 --> 00:47:50.310
show him a grade C and he'll say,

00:47:50.310 --> 00:47:53.040
you know what, Rob, bump
that up to a B, or he'll say,

00:47:53.040 --> 00:47:54.710
you know what, maybe
we shouldn't move forward

00:47:54.710 --> 00:47:55.880
with this application.

00:47:55.880 --> 00:47:57.480
This is just too much of a risk.

00:47:58.350 --> 00:48:01.943
He's gonna look at all grade
Cs our state seismologist.

00:48:03.550 --> 00:48:08.320
Now, suppose you get a
grade B or C and you say,

00:48:08.320 --> 00:48:10.803
you know what, Rob, I just want more.

00:48:13.026 --> 00:48:14.970
If you are eligible and
our state seismologist,

00:48:14.970 --> 00:48:17.520
their managers will
determine if you're eligible

00:48:17.520 --> 00:48:20.959
for what's called the
seismic monitoring plan,

00:48:20.959 --> 00:48:25.940
you can maybe possibly get up
to 10,000 barrels per day more

00:48:25.940 --> 00:48:28.220
added to your permit.

00:48:28.220 --> 00:48:31.123
If you're at grade A, you're
not getting higher than that.

00:48:31.123 --> 00:48:33.610
I mean, if you wanna
do a station, that's fine,

00:48:33.610 --> 00:48:36.023
but you cannot go higher than 30.

00:48:37.372 --> 00:48:40.090
If you got a B or C, and your eligible,

00:48:40.090 --> 00:48:42.873
you may be able to get an
extra 10,000 barrels per day.

00:48:43.840 --> 00:48:47.180
You got to agree to implement
a seismic monitoring plan

00:48:47.180 --> 00:48:50.023
that augments the
open public data network.

00:48:51.062 --> 00:48:53.161
Then you're gonna have to develop

00:48:53.161 --> 00:48:56.033
and implement a seismic
event response plan.

00:48:59.180 --> 00:49:00.610
This is just saying, you're
gonna need to include

00:49:00.610 --> 00:49:02.410
the method of monitoring.

00:49:02.410 --> 00:49:04.530
We got to know the
type of instrumentation,

00:49:04.530 --> 00:49:07.920
reporting of data
analysis in which network

00:49:07.920 --> 00:49:10.090
you're gonna upload this all to.

00:49:10.090 --> 00:49:12.570
All of these monitoring
plans and response plans,

00:49:12.570 --> 00:49:13.670
they're gonna be reviewed

00:49:13.670 --> 00:49:16.608
by our state seismologists
and our managers.

00:49:16.608 --> 00:49:18.620
They're gonna be the ones
to hopefully say, all right,

00:49:18.620 --> 00:49:20.320
let's just move forward with this.

00:49:23.340 --> 00:49:24.610
All right.

00:49:24.610 --> 00:49:25.443
We're at the very end.

00:49:25.443 --> 00:49:26.630
We're doing great here.

00:49:26.630 --> 00:49:28.090
Hopefully, I still have your attention.

00:49:28.090 --> 00:49:30.440
All right, permit amendment,
application decision,

00:49:30.440 --> 00:49:31.453
protest and hearing.

00:49:34.351 --> 00:49:36.323
Let's talk real quickly about
permanent amendments.

00:49:37.680 --> 00:49:38.693
They really vary.

00:49:39.710 --> 00:49:42.100
Let's just say you're doing
an operator name change.

00:49:42.100 --> 00:49:42.933
Those are easy.

00:49:42.933 --> 00:49:44.886
Those are just formed fee.

00:49:44.886 --> 00:49:46.130
That's all you gotta do.

00:49:46.130 --> 00:49:49.780
Let's say you planned a
manual injection interval uphold.

00:49:49.780 --> 00:49:52.473
Well, that's pretty much
a brand new application.

00:49:53.920 --> 00:49:55.517
That's what it says here.

00:49:55.517 --> 00:49:57.593
Filing requirements vary with
the purpose of the amendments.

00:50:00.090 --> 00:50:02.620
On our manual this table,

00:50:02.620 --> 00:50:04.870
we have links to these tables that show

00:50:04.870 --> 00:50:08.090
what you need to submit for
different types of amendments.

00:50:08.090 --> 00:50:08.923
This is great.

00:50:08.923 --> 00:50:11.290
I mean, we have this all
printed out on our desk

00:50:11.290 --> 00:50:13.033
because it shows what we need to look

00:50:13.033 --> 00:50:15.090
for certain amendments.

00:50:15.090 --> 00:50:17.210
I highly recommend if
you're doing an amendment,

00:50:17.210 --> 00:50:20.823
use this because it
just helps you out a lot.

00:50:22.930 --> 00:50:26.580
All right, what's the
timeline of all of this?

00:50:26.580 --> 00:50:28.676
What's our permit timing.

00:50:28.676 --> 00:50:32.489
How quick should you
expect to get your permit back?

00:50:32.489 --> 00:50:37.321
Well, according to our
rule, Chapter one, rule 201,

00:50:37.321 --> 00:50:40.932
our turnaround for these
injection disposal applications,

00:50:40.932 --> 00:50:43.783
it's 45 days.

00:50:44.750 --> 00:50:46.770
That's our turnaround.

00:50:46.770 --> 00:50:50.350
30 of those days should
be for the initial review,

00:50:50.350 --> 00:50:53.670
in 15 days for that final review.

00:50:53.670 --> 00:50:56.170
Now, currently we're
still meeting that target.

00:50:56.170 --> 00:50:58.470
We're all over the
place with this pandemic,

00:50:58.470 --> 00:51:01.270
and we're still meeting that target.

00:51:01.270 --> 00:51:03.610
Obviously, if you go into seismic review

00:51:03.610 --> 00:51:05.563
or pressure of you and east Texas.

00:51:06.417 --> 00:51:09.210
There's some more time
that's gonna go into those.

00:51:09.210 --> 00:51:13.297
45 days is our turnaround
per Chapter one, rule 201.

00:51:14.472 --> 00:51:18.610
Now, this slide, the
after permit, this says,

00:51:18.610 --> 00:51:20.420
so you're obviously
gonna have to do some stuff

00:51:20.420 --> 00:51:21.750
once you get your permit.

00:51:21.750 --> 00:51:22.660
What are those things?

00:51:22.660 --> 00:51:27.320
Well, you gotta do that H-5.
Usually it's every five years.

00:51:27.320 --> 00:51:31.030
Like I said for that PTT cam,
you're gonna do an annual.

00:51:31.030 --> 00:51:32.513
Be sure you do your H-5.

00:51:33.360 --> 00:51:34.430
What else are you gonna do?

00:51:34.430 --> 00:51:35.993
File a completion report.

00:51:37.028 --> 00:51:37.928
Do you W-2 or G-1.

00:51:38.810 --> 00:51:40.740
You can do this online now.

00:51:40.740 --> 00:51:43.200
This just speeds things up.

00:51:43.200 --> 00:51:44.840
Lease numbers or for new leases,

00:51:44.840 --> 00:51:47.450
they're assigned
after the final approval

00:51:47.450 --> 00:51:48.853
of your completion report.

00:51:49.730 --> 00:51:50.750
That's when you'll get it,

00:51:50.750 --> 00:51:52.740
is after you do this completion report.

00:51:52.740 --> 00:51:56.690
Also we will send you
when your H-10 is due.

00:51:56.690 --> 00:51:59.270
Be sure you get that H-10.

00:51:59.270 --> 00:52:01.010
Submit it in, or else we can...

00:52:01.010 --> 00:52:02.230
Margo, she will come.

00:52:02.230 --> 00:52:05.389
We will let you know
if you did not turn it in.

00:52:05.389 --> 00:52:08.433
Be sure you do that H-5,
that H-10 and get that W-2 in.

00:52:12.686 --> 00:52:14.843
This slide is just talking about saying,

00:52:16.190 --> 00:52:18.980
hey, you propose what you're gonna do.

00:52:18.980 --> 00:52:21.940
Hopefully you do what
you told us you're gonna do,

00:52:21.940 --> 00:52:23.823
but obviously things happen.

00:52:24.670 --> 00:52:28.030
This is also saying that if
there's any remedial work

00:52:28.030 --> 00:52:30.310
that we told you needed
to be done, let's say,

00:52:30.310 --> 00:52:33.600
we asked you to put a
seaman bridge plug in,

00:52:33.600 --> 00:52:35.790
do a squeeze or something like that.

00:52:35.790 --> 00:52:37.711
This is where we're saying,

00:52:37.711 --> 00:52:40.843
hey, you need to do all that
before you can start injecting.

00:52:42.250 --> 00:52:43.590
Any big changes.

00:52:43.590 --> 00:52:45.420
Let's say, you go, Rob,

00:52:45.420 --> 00:52:48.210
I didn't even go down to
my proposed top interval.

00:52:48.210 --> 00:52:50.396
Well, we're gonna need to
do a permanent amendment

00:52:50.396 --> 00:52:52.273
because that just can't happen.

00:52:53.170 --> 00:52:54.940
Just let us know if you
know things didn't go

00:52:54.940 --> 00:52:56.840
the way you planned
and we'll walk you through

00:52:56.840 --> 00:52:57.890
what needs to happen.

00:53:01.880 --> 00:53:03.830
What happens if you get denied?

00:53:03.830 --> 00:53:06.850
I know nobody wants to
talk about it, but it happens.

00:53:06.850 --> 00:53:09.890
If you have... So remember
I talked about these requests

00:53:09.890 --> 00:53:12.410
for additional information, these rads.

00:53:12.410 --> 00:53:16.435
Technically you only really
get two responses to these rads.

00:53:16.435 --> 00:53:18.978
If the application remains incomplete

00:53:18.978 --> 00:53:21.570
after two additional submittals,

00:53:21.570 --> 00:53:23.892
we can return to the application.

00:53:23.892 --> 00:53:27.760
That's one way you can
get denied or sent back.

00:53:27.760 --> 00:53:31.140
If you don't really
answer the rads correctly.

00:53:31.140 --> 00:53:34.060
Applications will be
administratively denied

00:53:34.060 --> 00:53:39.060
if the lease is under
severance or if it's sealed in.

00:53:39.190 --> 00:53:40.297
That's another way.

00:53:41.150 --> 00:53:44.760
Finally, if there's
unsatisfactory well completion.

00:53:44.760 --> 00:53:46.670
Let's say you didn't do it

00:53:46.670 --> 00:53:48.040
the way you told us you were gonna do it

00:53:48.040 --> 00:53:49.950
and you just kept on going.

00:53:49.950 --> 00:53:53.100
Then, yes, we can deny
your permit then and cancel it.

00:53:53.100 --> 00:53:55.890
So it's important that if
any of these things happen,

00:53:55.890 --> 00:53:57.250
you just let us know.

00:53:57.250 --> 00:53:59.610
We will tell you what
the best route you can do

00:53:59.610 --> 00:54:03.123
to get everything... To
hopefully try and fix the situation.

00:54:06.600 --> 00:54:07.760
All right, here it is.

00:54:07.760 --> 00:54:08.593
We're almost at the end.

00:54:08.593 --> 00:54:09.940
I promise y'all.

00:54:09.940 --> 00:54:12.120
Protested applications, all right,

00:54:12.120 --> 00:54:14.380
nobody wants to get
protested, but it happens.

00:54:14.380 --> 00:54:18.590
All right. We, the staff
may not administratively

00:54:18.590 --> 00:54:23.050
issue a permit if it has
a valid protest. All right?

00:54:23.050 --> 00:54:25.820
These protests,
remember that notification

00:54:25.820 --> 00:54:27.970
I was talking about in
the published notice.

00:54:27.970 --> 00:54:32.970
Protests must be filed within
15 days of the date of notice,

00:54:33.150 --> 00:54:36.700
the date of publication or
the date that the application

00:54:36.700 --> 00:54:41.563
is filed with us at the
UIC, whichever is later.

00:54:42.920 --> 00:54:47.070
Protests received after that
window will not be considered.

00:54:47.070 --> 00:54:51.160
Just know that 15 days
is the window we give you

00:54:51.160 --> 00:54:52.453
for this protest period.

00:54:55.250 --> 00:54:58.750
What happens if you
get protested, you say,

00:54:58.750 --> 00:55:00.900
Rob, my protest, what can I do?

00:55:00.900 --> 00:55:03.670
There's three things you can really do

00:55:03.670 --> 00:55:05.580
to get out of your protest.

00:55:05.580 --> 00:55:08.430
One, you can withdraw your application.

00:55:08.430 --> 00:55:10.542
Nobody ever wants to do that.

00:55:10.542 --> 00:55:12.630
It's an option.

00:55:12.630 --> 00:55:15.600
Two, you can sweet
talk your way out of this.

00:55:15.600 --> 00:55:17.620
Get a withdrawal letter
from the protestant.

00:55:17.620 --> 00:55:19.223
Maybe you can get them to withdraw it.

00:55:19.223 --> 00:55:24.203
Come to a compromise there
or three, you can go to hearing.

00:55:25.840 --> 00:55:28.410
The application must be
administratively complete,

00:55:28.410 --> 00:55:30.220
when it goes to hearing.

00:55:30.220 --> 00:55:33.570
There's gonna be a
pre-hearing and/or hearing

00:55:33.570 --> 00:55:37.020
will be held pretty much
up there and docket,

00:55:37.020 --> 00:55:38.865
they're gonna make the decision.

00:55:38.865 --> 00:55:40.990
They're gonna send it to me.

00:55:40.990 --> 00:55:44.370
Then I will move forward
with whatever they decide.

00:55:44.370 --> 00:55:46.730
Those are your three routes
that if you get protested,

00:55:46.730 --> 00:55:50.020
like I said, in withdrawal,
have your protestor withdrawal

00:55:50.020 --> 00:55:51.520
or you can take it to hearing.

00:55:53.250 --> 00:55:56.204
I think that's actually the end of it.

00:55:56.204 --> 00:55:57.480
Here's our team leads.

00:55:57.480 --> 00:56:00.354
Sean Avitt, he's our
manager, figure this leader.

00:56:00.354 --> 00:56:02.850
Jason Lockie, if you have any questions,

00:56:02.850 --> 00:56:04.360
he's over all the permit specialists.

00:56:04.360 --> 00:56:07.123
If you have any questions,
you're running protest

00:56:07.123 --> 00:56:10.050
with the administrator
review, Jason Lockie,

00:56:10.050 --> 00:56:11.500
he is the man to talk to.

00:56:11.500 --> 00:56:13.440
Ric Rosso, he's my manager.

00:56:13.440 --> 00:56:14.273
He's great.

00:56:14.273 --> 00:56:16.727
If you have any questions
regarding the technical,

00:56:16.727 --> 00:56:19.330
the seismic review contact, Rick.

00:56:19.330 --> 00:56:22.450
Finally Lauryn McFarland.

00:56:22.450 --> 00:56:23.283
She's great.

00:56:23.283 --> 00:56:24.116
She handles all...

00:56:24.116 --> 00:56:26.570
She's over the H-5 groups.

00:56:26.570 --> 00:56:29.210
If you got any questions
regarding your H-5,

00:56:29.210 --> 00:56:32.003
be sure you contact Lauryn McFarland.

00:56:32.855 --> 00:56:35.450
I just wanna thank y'all for being here.

00:56:35.450 --> 00:56:38.060
Like I said earlier, it really
means a lot that you're here

00:56:38.060 --> 00:56:39.670
because it means that you care

00:56:39.670 --> 00:56:42.470
about what's your
applications and you care

00:56:42.470 --> 00:56:44.850
that you want to do this right.

00:56:44.850 --> 00:56:45.683
I'm here.

00:56:45.683 --> 00:56:46.810
I'm always available for you.

00:56:46.810 --> 00:56:48.520
If you wanna send me an email,

00:56:48.520 --> 00:56:52.933
here's my email right here,
rob.castillo@rcc.texas.gov.

00:56:53.950 --> 00:56:56.820
Feel free to contact me
saying, you got a question,

00:56:56.820 --> 00:56:59.170
reach out to me or give
us a call at our main line.

00:56:59.170 --> 00:57:01.843
One of us perimeters
or permit specialist,

00:57:03.790 --> 00:57:07.653
we are happy to help you
through the application process.

00:57:08.620 --> 00:57:11.350
Molly, I think that's it from me.

00:57:11.350 --> 00:57:14.320
If there are any questions,
I think we can take those.

00:57:14.320 --> 00:57:15.153
<v Molly>Yes.</v>

00:57:15.153 --> 00:57:16.910
We've got about five
minutes for questions

00:57:16.910 --> 00:57:19.790
and it looks like Nicole has three

00:57:21.465 --> 00:57:24.400
that haven't been answered yet.

00:57:24.400 --> 00:57:28.140
The first can applications
be mailed in PDF format

00:57:28.140 --> 00:57:31.000
to the UIC email address currently?

00:57:31.000 --> 00:57:33.920
<v Rob>Yeah. Right now
because a lot of us are not</v>

00:57:33.920 --> 00:57:36.490
in the office, so we're
actually accepting PDFs,

00:57:36.490 --> 00:57:38.473
these digital copies to be sent in.

00:57:39.637 --> 00:57:43.910
<v Molly>All right, next
question for W-14,</v>

00:57:43.910 --> 00:57:48.690
what if the permitted disposal
interval is 5,500 to 9,000

00:57:48.690 --> 00:57:52.590
and the purse for disposal
initially are 8,000 to 9,000.

00:57:52.590 --> 00:57:54.173
Where should the packer be set?

00:57:55.480 --> 00:58:00.326
<v Rob>As long as that packer
is set above your purse</v>

00:58:00.326 --> 00:58:02.490
it can be inside of your interval.

00:58:02.490 --> 00:58:04.950
Your packer can be set
inside of your interval,

00:58:04.950 --> 00:58:07.253
but it has to be above your top purse.

00:58:09.000 --> 00:58:10.440
It cannot be below your purse,

00:58:10.440 --> 00:58:13.563
but it can be within
your proposed interval.

00:58:15.300 --> 00:58:17.320
<v Molly>All right.
One more question.</v>

00:58:17.320 --> 00:58:20.320
What is the current policy
guidelines on huff and puff

00:58:20.320 --> 00:58:22.740
involving injection
and production into and

00:58:22.740 --> 00:58:24.340
from of the same well?

00:58:24.340 --> 00:58:28.073
Permit, no permit H-10,
no H-10 packer, no packer?

00:58:29.340 --> 00:58:31.798
<v Rob>That's actually
a good question.</v>

00:58:31.798 --> 00:58:32.631
I'm gonna be honest.

00:58:32.631 --> 00:58:34.580
I don't know that much
off the top of my head

00:58:34.580 --> 00:58:36.150
regarding the huff and puff.

00:58:36.150 --> 00:58:39.850
I can take that if we can
get the info for that question,

00:58:39.850 --> 00:58:41.140
the info...

00:58:41.140 --> 00:58:43.350
Email for that person,
and I will get back to them

00:58:43.350 --> 00:58:44.870
because I'm gonna be honest.

00:58:44.870 --> 00:58:46.970
I am not that great
at the huff and puff.

00:58:46.970 --> 00:58:47.803
I don't know.

00:58:47.803 --> 00:58:50.270
I think we have a few
people who work on them.

00:58:50.270 --> 00:58:54.280
If there's a way for us to get
that attendees information,

00:58:54.280 --> 00:58:57.521
I will get back to them
with that information.

00:58:57.521 --> 00:58:59.930
<v Molly>The question was
submitted anonymously.</v>

00:58:59.930 --> 00:59:01.890
I'm just going to suggest

00:59:01.890 --> 00:59:03.500
that whoever submitted that question-

00:59:03.500 --> 00:59:04.333
<v Rob>Reach out to me.</v>

00:59:04.333 --> 00:59:07.440
<v Molly>Email's up on
the screen right now.</v>

00:59:07.440 --> 00:59:08.420
<v Rob>You know what, Molly,</v>

00:59:08.420 --> 00:59:10.250
going back to that first question,

00:59:10.250 --> 00:59:15.250
I think we can still send
in the paper application

00:59:15.423 --> 00:59:19.030
because we still have
staff who is in the office.

00:59:19.030 --> 00:59:22.380
I'm pretty sure that we
accepted digital copies right now,

00:59:22.380 --> 00:59:25.900
but we still would prefer
you to send hard copy in

00:59:25.900 --> 00:59:28.500
because once again, we
have staff who's in the office

00:59:28.500 --> 00:59:31.100
scanning these and sending them out.

00:59:31.100 --> 00:59:32.710
Is there any other questions, Molly?

00:59:32.710 --> 00:59:33.630
I'm sorry.

00:59:33.630 --> 00:59:35.030
Didn't mean to cut you off there.

00:59:35.030 --> 00:59:36.140
<v Molly>No. That's fine.</v>

00:59:36.140 --> 00:59:38.649
Those are all the
questions that we have.

00:59:38.649 --> 00:59:39.482
<v Rob>Great.</v>

00:59:39.482 --> 00:59:41.050
<v Molly>With that, I
guess we'll go ahead</v>

00:59:41.050 --> 00:59:42.530
and conclude the webinar.

00:59:42.530 --> 00:59:44.993
Thank you everyone
so much for participating.

00:59:46.000 --> 00:59:47.403
Thank you, Rob.

00:59:47.403 --> 00:59:48.408
<v Rob>Thank you.</v>