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All right, let's go ahead and get started.
Our presenter this morning is Rob Castillo
from the Injection-Storage Permits department
in the technical permitting section
of the oil and gas division.
Rob, whenever you're ready.
Rob: Thanks Molly.
How's it going everyone?
My name is Rob Castillo.
I am one of the technical parameters
here at the Railroad Commission, specifically the UIC group.
First I just wanna thank everyone for being here today.
The fact that this is a crazy time in our world
and the fact that you're here, means that you care about
doing these applications correctly.
Hopefully by the time I finished this presentation,
you'll feel a little bit more comfortable
about doing these permit applications by yourself.
All right, well, let's go and get started.
This is kind of just an overview
of what we're gonna go over today.
I'm gonna briefly talk about the UIC Online Manual.
I'm gonna go into a little bit about the origins
of our program but then we're gonna get into the meat of it.
We're gonna talk about the permit application details.
All right.
I'm gonna talk about the forms, attachments,
the administrative technical and seismic review
that goes into this. All right.
Then I'm going to wrap things up
with the post permitting protests and hearing.
UIC Online Manual, this is an amazing tool to use
when you are doing your applications.
Everything that I'm gonna tell to you today,
you can find it online. Where can you find it?
That's a great question.
You can go to our website, rrc.texas.gov.
If you hover over oil and gas,
it brings you down to a little drop box
and you can go down and click on publication
and notices you click on that
and that's gonna bring you to this page right here.
Under manuals, the first little tab right there,
I've got it circled, click on that link.
It's an injection/disposal well permitting.
All right, click on that.
We're almost there. I promise.
These two pages right here, they're just great.
Specifically the summary of standards and procedures,
when you all call and say,
"Hey, Rob, what do I do with this?
What can I do about my administrative review,
the packer setting or anything?"
We all have these links open.
It's just so useful.
The summary of standards and procedures,
it has templates for a lot
of the administrative review attachments
that you're gonna need.
It goes into detail about the technical review
that we do on your application.
It just has a lot of great information
that you're gonna need to finish these applications.
I highly recommend using these UIC Online Manual.
Because it really is gonna help you out,
and it's a great tool to use.
All right, just a brief history of our program
why did this all get started?
Well, it was the Safe Drinking Water Act of 1974.
The main focus of this was to protect human health
and the fresh water drinking sources that we use.
From that the, UIC, I'm gonna be using a lot of acronyms.
The UIC or Underground Injection Control program
was created.
In our program, what we do is we prohibit
the contamination of these USDW's,
which in another acronym, what is the USDW?
I'm gonna define this a little bit more later,
but the USDW is an Underground Sources of Drinking Water.
We're focusing on protecting the contamination of this USDW.
In 1982, Texas being the great state that we are,
we got privacy.
We took the steering wheel on it.
Ever since we've been really getting at it.
Currently we've got about 33,000 active wells in our state.
What does that mean?
Well, that means that we are the largest UIC program
in the nation.
Remember I told you about the USDW
and what really defines it.
The USWD, we define it as anything as less than 10,000
parts per million total dissolved solids, or TDS,
as you probably know.
This is what the Safe Drinking Water protects
in both Statewide Rule 9 and 46.
It's this fresh water that's less than 10,000 parts
per million.
You also have probably heard us talk about the BUQW
or the Base of the Usable-Quality Water.
That's anything less than 3,000 parts
per million total dissolved solids.
Then sometimes on your determination letters
you get from the groundwater unit,
you'll see something called Superior Water.
That's anything less than a 1,000 parts per million TDS.
Here's a great little chart that shows
the different types of classes that are monitored.
The Commission, we only do class two and three.
Today we're mostly just only gonna focus on class two.
Class one, five and six, I believe the TCEQ
still monitors those class four,
the BPA still looks over those.
As you can see, 75% of the applications in wells we have
are secondary or enhanced recovery.
24% are the disposal wells, and 1% is brine mining
or hydrocarbon storage.
Most of our wells are secondary and EOR wells.
All right, so you decided that you wanna do
an injection disposal well.
What form are you going to use?
That's a great question and it's a great starting point.
If you are saying, you plan to dispose
into a nonproductive formation,
then you're going to need to use a Form W-14.
If you plan to inject
or to dispose into a productive formation,
you're gonna need to use a Form H-1 and H-1A.
W-14 there's a Statewide Rule 9. H-1 and H-1As,
those are Statewide Rule 46.
If you plan to inject into multiple zones,
do a H-1 and H1A because...
What happens is whenever I get a W-14,
what I do is I do a two mile radius search
around your well or propose well, and if...
What I look for is I look for current
or historical production.
Let's say you plan to dispose into the X formation.
I'm just making up a formation here.
I'm going to go around and look.
If I find any production, current or historical
in this X formation,
I'm gonna have to make you switch to an H-1 and H-1A.
It's really unfortunate when we have to ask you
20 days into this,
"Hey, you need to switch forms.
You're gonna have to renotify and republish."
It's always important that you know what form to use.
If you ever have any questions, feel free to give us a call.
We'll try and help you out as best as we can with this.
Obviously down here at the bottom,
it says you need a mail the form and attachments
to the UIC here in Austin, and you gotta send a copy
to the district.
If you just sent it to the district but not us,
we're not gonna see it.
Be sure you send us the form and then a copy
to the district office.
All right, what's the real difference from these forms
other than being productive and non-productive?
Well, it was about 250 bucks.
The form W-14 was $250 for the fee.
The H-1 and H-1A fee is $500.
Currently until the end of the year,
we are waiving these fees.
Exception requests, here's a good one, these are $375.
These are example, let's say packer exceptions.
Suppose you're an H-1, you wanna set your packer
higher than a 100 feet.
You can potentially do a packer exception.
You got to pay this $375, tubing casing exceptions,
that's another 375, if you wanna roll that way.
These are actually still being charged.
The fees for the forums
are being waived until the end of the year.
Obviously there's fees that include a surcharge,
and these are nonrefundable.
If you call us up to make a payment,
we can't take your payment.
You gotta call down to central records.
They're gonna give you...
They're gonna take the payment,
and they will give you a receipt.
Darlene Cottle, she's the one who handles
all of our transactions up here.
If you wanna give her the receipt,
or put it on your application, the receipt number,
that just speeds things up.
The last point, applications will not begin being processed
until they are paid, and that's important.
We're gonna talk about...
We're mostly gonna look at the H-1 form.
The H-1's got... It's actually two pages.
The first page, this H-1, the top of it
is the P-5 information.
What are we gonna look for there?
Well, you have to have an active P-5 obviously.
This is where you're gonna list your operator name,
your number, put your address.
Right below that, it's gonna be more the P-4 information.
Got to have the active P-4 just so you list your lease name,
number, field name, all that good stuff.
Be sure you fill all this out appropriately.
Going down, well, actually, you know what?
We're gonna talk about field names real quick.
Determining the field names, most of you already know
the field names you're going to use for these wells.
For H-1 and H-1A, the field name, it should be correlative
to the injection/disposure formation.
It should be.
If you're using multiple formations,
you're gonna use the deepest correlative formation.
That's what you're gonna use, or you keep
the current field name if the well's already
on a proration schedule.
That's for H-1A. For W-14, it should be correlative
to the formation more than two miles away,
or to the formation that is the source
of your disposal fluids.
Most of you already know what field you're gonna use,
but like I said, it can get a little tricky.
If you have a question, hit us up,
we'll help you out for sure on this one.
Going down further on that H-1,
this is where you're gonna list the reservoir data.
This is the geology part of it.
All you geology buffs out there.
We give you four lines to spew your heart out.
This is where we really want you to talk about
the lithology, what you know about the permeability,
the porosity, bottom hole pressure.
We need this filled out because when it comes
to sometimes if you go through a seismic review,
this stuff really comes in handy to know.
Be sure that you fill the reservoir data part
out as best as you know.
Going down the H-1 again,
this is the injection project data.
This is the meat of that.
This is pretty much where you're gonna tell us
what you're planning to do.
21, this is... What is this?
We wanna know what is this gonna be.
Is this a water flood, pressure maintenance, disposal well?
This is where you let us know.
Something about these,
currently we are working to better our forms.
It can be a little confusing on this.
If you look at item 21,
the boxes correlate to what's to the left of them.
Right there, water flood has a box to the right of it.
What we see a lot of the times
is when people mean disposal well,
they'll check thermal recovery.
It can be a little confusing
because other does not have a checkbox.
That's where it confuses somebody.
Like I said, we're working to better our forms.
We're trying to make it a little bit more user friendly,
but it's something we see all the time.
People wanna select disposal,
but they'll actually select thermal recovery.
It's just something to look out for
when you're checking these boxes.
Item 23, if you plan to do...
Be a commercial disposal well,
this is where you're gonna let us know.
Then item 25, this is where you're gonna let us know
what's going to be injected.
We gotta know what you're planning to inject,
salt water, CO2, RCRA listed here.
All right, now we're on the H-1A.
This is page two.
At first it's a little bit redundant, right?
It's the P-5 information all over again.
Then going down to your P-4 stuff again,
P-4 you get a little bit more detail.
It's gonna talk about the latitude, longitude.
We need directions to the nearest town.
As you can see further down,
it talks about well construction.
This is where you are gonna tell us
about your proposed well construction,
or if it's already drilled what's there.
If it's already drilled, it should match
what's in our records right now.
If it doesn't, we're gonna have to send what's called rad,
which is a request for additional information
to clarify what's going on.
Maybe you did some work, but you never let us know about it.
We need to take care of all that
before we can get this permit out to you.
Further down the H-1A, this is pretty much
where you tell us the injection interval you plan to go.
Your packer depth, max daily injection
volume you're requesting
and your max surface injection pressure.
All right, what I really wanna stress on this
is if you are planning to do this
to a directional horizontal well, it is crucial
that for really anything depth related
that you list both TVD and Measured Depth.
Total Vertical Depth and Measure Depth.
For sure on the injection interval,
we need that packer depth, tubing depth, TD plug backs,
really anything with depths.
We need both MD and TVD,
if this is a directional horizontal well.
You're also gonna have to list that on the article,
which I'll get into that in a little bit.
Be sure if it's a directional well, you put TVD on there
for your depths.
Finally, down at the bottom, H-1, it's the signature.
There's not a spot, and once again,
I stress, we're working on our forms.
There's not a spot for your email.
We like when you put your email right there
above your signature.
It really helps speed up correspondence between us.
It really helps because if not,
we're gonna have to send it in the old snail mail.
That could be everything from a rad
to actually issuing your permits.
Obviously you would wanna get your permit quicker.
We like when you put your email right there
above your signature.
The administrative review, so like I said,
there's many parts of this review.
There's the administrative, technical, seismic
and then there's final.
Let's talk about the administrative review.
What are the permit specialists gonna do
in part of this review?
Well, they're gonna make sure that your fees are paid,
like I said.
They're gonna make sure that the form is full and complete.
They make sure all the attachments are there
and they're gonna actually build the folder
and enter your application into our tracking system.
Another thing they're gonna do is they're gonna make sure,
like I said earlier, they're gonna make sure you've got
a current P-5 on file.
Make sure your corporation and franchise taxes are paid.
They're gonna make sure the P-4 is okay.
Verify that you are the operator of the lease.
For a new lease, you file form P-4
with the completion report.
They're gonna make sure that this application
isn't already an existing UIC well.
It happens.
Sometimes you take over a well
and you didn't know that it already had a UIC permit on it.
We've seen it before, so they're gonna do all that.
There's gonna be a good bit of documents
that you're gonna have to submit
for the administrative review.
The Notice of Application.
What we want you to do is we want you to notify
a good bit of people about this.
We want you to mail or deliver a copy
of either the W-14 or the H-1.
Here's an important part, front and back
to the surface owner.
Hopefully they know what's going on.
If this is the commercial disposal application,
you're gonna need to notify adjacent service owners
operators of active wells within a half mile
of your proposed well, the county clerk,
and if your well is located within the city limits,
you need to notify the city clerk.
If not, you don't need to worry about it.
I said, front and back, and that's important
because on the back of these applications
is instructions for the people to be able to protest.
That's why we wanna know that they have the ability
to do that if they want.
It's important you send both front and back
of the applications to all these parties.
Some more documents, like I said,
is you're gonna have to submit a labeled map
showing the location of the wells within a half mile
of your proposed injection disposal well.
If this were a commercial disposal well,
you're gonna need to provide a plan
showing the surface track boundaries
of all the adjacent track boundaries.
I've got a good example of that here on the next page.
We also, finally, we're gonna need you
to list all the names of all those affected parties
and then pretty much just have a signed statement
indicating that you sent that form to all those people.
We need a signed statement
pretty much just saying that you did this.
That track boundary I was talking about,
this is a good example of what it should look like.
There, you can see a well pad right there
on the Gary Stearns.
Obviously you had submitted
to the M A Snell Investments Trust, the Dorothy Garrett,
but what about this Dorothy Garrett family,
is right directly across the road, this little road.
What many people don't know is you would want to send it
to the Dorothy Garrett family,
just because it touches that infant dismally, small point,
that corner in that little roads there
doesn't mean we don't need to notify them.
You need to notify them,
because it touches just that little corner.
That means they got to get notified.
Like I said, if you have any questions
on who you need to notify, call us up,
our permit specialists are great at this.
They know how to look at these and they will help you out
and let you know who you should notify.
Further going on to you hearing me talk about
the commercial disposal wells.
Let me break that down for you.
There are three things that make you...
Requirements, not things that make you
a commercial disposal well, and it has to be all three.
If you're just one of them, you're not
a commercial disposal well. What are they?
They are, if your waste is partially or wholly tripped in,
that's one.
If there's a disposal fee or a compensation being charged,
that's the second one,
and this is your primary purpose of business.
If you meet all three of those, yes.
What you are is going to be a commercial disposal well.
If you're just one of them, you're not.
This happens a lot.
I get this a lot. People call up say, hey, Rob.
It's being parked trucked over there,
but it's not the other two.
Then, no, you're not a commercial disposal well.
If you meet all three of these, then yes,
this is a commercial disposal well.
This last part is just, there's a little bit more
that goes into the facilities
for these commercial disposal well.
It's just saying that all the spill prevention
and all containment, it's gotta be done
before you even start disposing.
That's obvious.
Going back, so more on the administrative review
like I said, we want you to notify a lot of people.
That means you got to put it...
We want you to publish it for one day in a newspaper
that's in general circulation in the county.
If you're down South San Antonio, don't put it in Dallas.
We want it in general circulation in the county.
We want you to actually submit the newspaper clipping
with a notarized affidavit of publication.
We have a template.
Remember that UIC Online Manual
I was talking about in the beginning,
there's a template of this affidavit
on the administrative review,
and it just lines it out for you.
Then here at the bottom,
it says obviously a 15-day waiting period
after the notice and period,
after the notice and publication,
that's when we start that protest window
after this notice period.
What do you put on this published notice text?
Well, it should match the application
pretty straightforward.
It's gonna have direction and miles to the nearest town.
We want you to list your interval, if you're doing H-1A,
and you got a bunch of wells on there,
just do the shallowest and the deepest.
That way you cover the whole thing.
If this is gonna be a commercial well,
so you plan to inject certain things like H2S
or NORM, NORM is Naturally Occurring Radioactive Material.
You need to put that on there.
Of course you gotta put instructions
for people to be able to protest the application
on the publish notice tax.
Once again, there's an example of all this
on that UIC Online Manual.
You can see why it's just a great tool to use.
That wrapped up the administrative review.
The technical review, hopefully I know a little bit more
about this, because this is what I do.
One of the first things we look for
in the technical reviews, is we look at the GAU Letters
and Geologic Isolation.
The Groundwater Advisor Unit, or the GAU,
issues, these GW-2s.
GW-2s are these
Groundwater Protection Determination Letters.
It is important that when you're filing for your GW-2,
that when it comes to the little part that says,
what is the purpose of this filing
that you fill this out correctly?
If you're doing this for an H-1, purpose of filing
must be H-1.
If you're doing this for W-14, purposes of filing
must be W-14. Why do we say that?
Because sometimes if you do something
like a new drill purpose, they won't put the USDW on it.
We wanna know where the USDW is on it.
It has to be valid too.
If you've done one within five years,
it should be okay. It's gonna be okay.
Anything older than five years,
we'd have to get you to do a new one.
It's just really important that you get the purpose
for filing correct.
Because with the W-14s,
they're gonna also send a second letter
that's called a no harm letter saying
that there's adequate isolation there.
You hear about me talking about all this isolation.
What are we really looking for when it comes to isolation?
Well, Statewide Rule 46 says we're looking for 250 feet
of isolating strata between the top
of your interval and the Base of the Usable-Quality Water.
Now, that's cumulative.
Cumulative 250 feet of isolation, low permeability strata,
shales, clays and hydrides, that's what we're looking for.
When it comes to isolation from USDW,
we're looking for at least 50 feet of continuous isolation.
A pre-primacy wells,
or these are wells without adequate separation.
If you're in this category of pre-primacy or aquifer exempt,
that means you are allowed to inject closer
to these BUQ and UCW.
However, we're gonna add a condition on your permit saying,
it's called FSL or Fluid Source Limit.
What that says is you can only inject
or dispose fluids that were pulled directly
from the same lease in same formation.
We're just saying, you're just putting back
what's already come from there.
That's part of the whole aquifer exemption,
not everyone's aquifer exemption.
I'm gonna tell you that right now,
but if you have questions, like I said,
give us a call and we'll look it up for you.
We've got a program and we can run it,
run it through and check real quick for you.
E-log, your electric log.
All right.
We want you to submit a complete electric log
with header that shows the proposed zone
in overlying strata.
Let's say your interval is from 1,000 to 2,000 feet.
Your log should go at least to 2,000 feet.
Sometimes we get people who will only send us a log
that cuts off at 900.
No, we need to see the whole interval.
We wanna see everything that's going on down
to your bottom interval.
If you're doing an H-1A, you got multiple wells on there.
You're just gonna do one log.
We don't need the application to be books,
a huge application.
Another thing that's gonna help us out
is you can submit these logs online.
Use the digital well logs submission online.
I can literally just go in there
and tie your application to your submission.
If you wanna give us a submission number,
say you did do it online,
all you gotta do is do a little screenshot
of whenever you submitted your well log.
Just do a screenshot of that and attach it to your form,
your application, and I can literally just go in there
and tie it to your application.
It's so easy.
All right, if you annotate your log,
you get brownie points from us.
It really does help us out to confirm isolation
and the protection of all this fresh water.
If you label all the impermeable strata, that's amazing.
We'd love to see that in all these.
Obviously it doesn't happen all the time,
but if you do kudos to you.
I mean, it's great.
Annotations help in those close call scenarios.
Whenever we're trying to say is there enough data?
Should this be okay
when it comes to a close call on a size of review?
Will say, you know what?
They already annotated the log.
Boom, here we go. Let's just move forward.
It just speeds things up whenever we get
to these tough cases, tough scenarios.
All right, the AOR, you heard me talk about a half-mile map
back with administrator review.
Well, for the technical review,
we need a quarter-mile AOR done.
We also need you to submit a table
of all the wells within that AOR.
They should have at least name, the number,
API, all the good stuff, plug status, all that.
Also, you're going to need to confirm
that the wells are on a proration schedule
and have been properly plugged.
I'm actually gonna walk you through
on how you can make an AOR map, using our GIS Viewer.
If you, once again,
go to our Commission website, rrc.texas.gov,
down here in the bottom link you can see
it says useful links.
You can click on map Public GIS Viewer,
or you can just click on the map right there.
That'll bring you to our amazing GIS Viewer.
Here's what it looks like.
Let me see if I can zoom in a little bit more.
You see that little... The bull's eye
that's got a green dot in the middle.
What that is going to allow you to do
it's gonna allow you to select a radius.
What it's gonna do is any well that's in that radius
that's gonna pretty much pull all the information
on those wells, and it's gonna create an Excel file for you.
You enter in your API or your coordinates,
select your radius, click on the well, and boom.
You see how it highlights all the wells right there
in your AOR.
Then you click export to CSV that creates
this Excel spreadsheet.
Then it's just what it looks like right here.
I mean, it gives you everything, API, status, lat launch,
and this is just a shorted version of it.
It tells you everything, and this is pretty much
your quarter-mile table that we're asking for.
This is such a great tool to use on top of the manual
to use, when you're doing these applications.
Here's an example of an amazing...
We would love to see this all the time.
It doesn't happen, but we would love to see it like this.
It's numbered, color-coded,
I mean, this is amazing.
You can see here that the numbers correspond
to the table on the next page.
When we're going through and saying this one here
is a plug one, here's her dry well.
Here, this is where it goes.
This is what we would love to see.
If you can do this, that's amazing.
This is great.
What happens, let's say you have some wells
in your quarter mile that have a status
of unknown dry hole or plug.
What we're gonna need, even though we may have the records
in our system.
We need you to submit a plugging records for those wells.
Either W-3s or the good old form four.
We need to see them for any wells that are listed
as plugged, dry hole or are known
that are in your quarter mile.
If you cannot find any of these records,
sometimes you call the district up,
because sometimes if you can't find it on your own,
call your district office up,
maybe they can help you out a little bit on that.
There's some other things you can do.
Say, hey, Rob, I can't find these plugging records,
then there's another route to go.
Well, there's two routes.
You can either plug those wells yourself.
Nobody really wants to do that it seems,
or you can submit these pressure front calculations.
The whole purpose of this quarter mile review
is to ensure that if there are any improperly plugged wells
within a quarter mile of your proposed well,
that, if you were to start injecting disposing
in your proposed well, that a fluid migrated
to this problem well, that it would not migrate up
and contaminate the USDW.
Like I said, the other route you could do
is these Pressure Front Calculations.
These calculations are going to show that
this either that will happen, that fluid will migrate
to this nearest problem well, and that it says,
you know what?
It won't reach the USDW or that it will.
Now, these have to be prepared
by a Texas registered professional engineer.
In my first seminar I did, a lady asked me,
does it have to be a Texas PE?
The answer is, yes,
it has to be a Texas registered professional engineer.
Those are some routes that you need to go.
Just to wrap that up, if you have a well,
wells that are listed as plugged, dry hole or unknown
within a quarter mile, one first thing,
the easiest thing submit plugging records,
that'd be threes or form fours.
If you can't do that, you press your front calculation,
you need a PE to do it, to show that the USDW
would not be contaminated, or if you can't do that,
then lastly, you just gotta plug those wells yourself.
All right, when you set Surface Casing,
so what are the requirements we look for that?
If you're a new drill, if this is gonna be a new drill well,
or if it's for a commercial disposal well,
you have to set surface casing through the BUQW.
Remember what the BUQ is that Base
of the Usable-Quality Water.
If you're converting an old production well,
then, and let's say, you didn't know...
They didn't know where the BUQ was back then.
They say casing short, surface casing short
of where we know it is now,
then what we're gonna do is we're gonna issue
what's called PTT cam. It's just what it is.
It's annual.
It's an annual H-5 with weekly tubing and casing monitoring.
Remember if it's for a new drill
or a commercial disposal well,
you gotta set that surface casing through the BUQ.
All right, long string casing.
What are we looking for on here?
Well, we're looking for your top of cement
and it has to be adequate.
If you are calculating your top of cement,
if it's based off calculation,
we need to see at least 600 feet of cement
above the top injection interval.
All right, what if you say,
"Hey, Rob it's already been done.
I'm gonna run a temperature survey
to show where my top of cement is."
I say, great.
Well, I need to see 250 feet with the temperature survey
of cement above your top interval.
Let's just say, hey, you say, hey, Rob, I wanna run a CBL
or a Cement Bond Log.
Then we only need to see a 100 feet of cement
above the top interval.
It's gotta be at least 80% bonded.
That's key. We can't see any occasion of channeling.
Once again, if you're doing your top of cement
of calculation, it's gotta be 600 feet above your interval,
250 feet for your temperature survey,
if you wanna go that way or 100 feet for a CBL.
All right, packer setting, this is a good one.
If for W-14 Statewide Rule 9, there is no wiggle room.
You have to set your packer within a 100 feet
of your top permitted zone.
That is it.
There's no wiggle room on that one.
For a H-1 and H-1A, there's a little wiggle room.
Remember that packer exception fee I was talking about,
it was 375. Suppose you wanna set your packer
a little bit higher than 900 feet,
this is the route you can go.
You can say, hey, I wanna do an exception
or I wanna apply for an exception.
You gotta pay the fee.
That's one thing you gotta do.
You gotta submit an annotated log.
We got to see, and you gotta label it and say,
hey, Rob, I'm gonna set this packer up here.
I'm gonna show you that there are no permeable formations
between where this packer's going in that top interval.
That's number two.
We're gonna look to make sure
there's no permeable formations in between your packer
or the top interval.
We're also gonna make sure that there's at least 200 feet
of cement above that packer.
That's three, and that you're at least 150 feet
away from the BUQ.
There's four things that make it.
You got to pay that fee, you gotta submit the annotated log,
200 feet of cement above your packer,
and it's gotta be at least 150 feet away from the BUQ.
W-14s, no wiggle room, gotta be within a 100 feet
at the top of your interval.
Injection pressures.
How do we do this?
Well, we do it as typical maximum
is a half psi per foot of depth.
What does that mean?
Let's say your top interval is 1,000 feet.
We do 1,000 times 0.5.
That means your max service injection pressure
is 500 psi.
Now, for certain scenarios, this can change.
For coastal wells, shallow coastal wells
that are less than 2,000 feet.
So you're gonna be injecting above that Barnett Shale
up in Dallas area, North Texas,
or if you're injecting into the Delaware formations,
we may, may, limit to a quarter psi per foot.
Instead of that thousand, they could be what, 250.
That's just an example.
If you're in these areas, you may be limited, keyword may,
to this quarter psi per foot.
All right, here's the last bullet.
Fracture step-rate test may, and that's a big word,
may justify a higher pressure.
We have guidelines on our step-rate tests on our UIC Manual.
While engineers have worked hard on this,
and it is a great tool to use.
We actually lay down as far as how these tests
should be done and everything.
Look on that manual and see,
if you're gonna do a step-rate test to try
and justify higher volumes of pressures,
I would highly advise reading our manual
on the guidelines for step-rate tests.
All right, ejection fluids.
If you plan to inject H2S,
we require well specific story that Statewide Rule 36.
You're gonna have to go through a public hearing,
if you're planning the H2S.
You're also gonna need administrative approval
from your district office H2S coordinator.
Really, the best part, when you...
If you're gonna do H2S, call your district office up,
say, hey, I need to talk to my H2S coordinator
and they will help you out.
There's certain forms you've got to fill out.
Like I said, you gotta get this public hearing possibly.
There's some duties you're gonna have to do
to be able to inject H2S.
Now, if you're planning to do fresh water,
there's almost just as much, maybe even more.
You're gonna have to submit a Form H-7.
We're also gonna want you to fill out
what's called a freshwater questionnaire.
We're gonna need you to submit a plat
of all the freshwater rights
and finally a chemical analysis of the freshwater.
There's a lot that goes into planning to inject H2S
and freshwater.
A lot of people can't find the questionnaire.
Sometimes it gets hidden, but if...
Here's a hint.
If you go to our website and you type in questionnaire
in our search box, it's literally the only thing
that pops up.
I don't know why it's so hard to find, but if you go...
If you wanna just search for it, it will pop up.
That's the only thing in our search engine.
All right, that was a technical review.
We're doing great here.
Seismic review.
Let's talk about the seismic review.
Let's say you're an H-1 disposal or the W-14.
There is a seismic events over 2.0 magnitude
within a 9.08 kilometer radius around your proposed well.
That triggers this seismic review.
There were amendments to the rules 9 and 46.
They were made in 2014.
These amendments say that the Commission, RRC,
may modify suspend or terminate a permit
if disposal is likely to be contributing
to seismic activity.
This is also when we started requiring
this seismic information with disposal applications.
I'm gonna show you actually how to do
one of this seismic screenings.
The second point is just including a seismic survey
from the USGS catalog.
We will take into consideration, text net.
There's USGS catalog and the text net catalog.
I'm gonna show you both of them.
Here's the link for the USGS.
It's on here.
Text net looks like this.
Here's a link for that.
Text net is a little bit more user friendly,
but I'm gonna show you how to do your seismic search
via the USGS.
This just says, like I said,
RRC staff will consider both USGS
and text net catalogs in assessing seismic trigger.
Be sure you not only just do USGS, you check text net.
That way you're not surprised when we come back and say,
hey, you're gonna do a size of review and you say,
no, there's no events in USGS.
I said, well, there may be.
There was one in text next.
Be sure you just check text net.
That way you're not surprised.
Actually I think this page is just talking about
how to get to it, where you're gonna modify the date
and time, the magnitude and update the latitude
and longitude.
You're gonna need to submit screenshots of all this.
Let me just show you what it's gonna look like.
On that link, it'll take you to the catalog.
The catalog starts off with this, this magnitude date
and time.
On magnitude, you obviously need to customize it.
Minimum should be two.
We're looking for anything only above 2.0.
Date and time, you need to set it at 1973, one January 1st.
That's when this all, this catalog started.
Obviously the end date should be whatever date
you ran the tool.
Screenshot of this.
Bringing it to the advanced options.
Right here under circle,
this is where you enter your (indistinct) launch in that 83.
That's the datum we want you to use.
Be sure you do outer radius of 9.08.
That's what we're looking for.
Submit a screenshot of this,
and then you click go and then what it should do,
if you have events, it'll look like this.
This is what it will look like.
Then do a screenshot of this.
If you don't have events in your radius,
a little box will prompt up and say,
there were no events in the radius
and just do a screenshot of that and attach it.
That's it.
Like I said, be sure you check text net,
because you don't wanna get surprised.
Text net picks up an event that USGS didn't.
Remember we consider both catalogs.
This supplemental info for seismicity.
If we see that there is an earthquake over 2.0
in your radius, we're gonna at first issue a rad saying,
hey, we need some geologic maps from you.
These are structure maps, Isopach maps and cross sections,
kind of gonna give us a little bit more information
about the geology area.
We want you to show your faults, formation, thickness,
all that good stuff on these.
We wanna have all these for our records.
Suppose I grade it and it needs what's called
a fault slip potential, that's something else
that could be required.
If you have any relevant information that can assist
in the scoring, please submit it.
Just give us everything you know about the geology
of the area.
Geology of the area.
It really does help us out.
The purpose of the supplemental information
is to help us do a better seismic review.
We grade these on an ABC scale.
All right, I'm gonna get into this seismic,
the grading sheet.
It's broken up into three parts, faulting
and seismicity, operational factors and reservoir factors.
Faulting and seismicity is the biggest part
of the seismic review as it should be.
Operational factors that takes into consideration
any nearby wells that are disposing into the same formation.
What's the cumulative volume
that's going into this formation within the certain radius.
We're gonna look at that.
In reservoir factors, just the theology of the rock,
the characteristics of the area that plays more into that.
Faulting and seismicity is the biggest chunk
of this seismic review.
Like I said, we grade on ABC.
With each grade there are limits and conditions added
to your permit.
Let's say you get a grade A.
The max daily injection volume for grade A
is 30,000 barrels per day.
For a grade B it's 20,000, grade C is 10,000.
With all these, they're all gonna get permit conditions
on your permit.
We're gonna have daily H-10 records
that you're gonna have to submit.
Initial static bottom hole pressure test.
That's another one that's gonna go on.
If you're grade A and you're at 30,000,
we're gonna ask you to do a step rate tests.
All grades, Cs need to be reviewed,
are going to be reviewed
by our state seismologist for his approval.
Why?
We do this because, hey, you know what,
sometimes we'll give him a C,
show him a grade C and he'll say,
you know what, Rob, bump that up to a B, or he'll say,
you know what, maybe we shouldn't move forward
with this application.
This is just too much of a risk.
He's gonna look at all grade Cs our state seismologist.
Now, suppose you get a grade B or C and you say,
you know what, Rob, I just want more.
If you are eligible and our state seismologist,
their managers will determine if you're eligible
for what's called the seismic monitoring plan,
you can maybe possibly get up to 10,000 barrels per day more
added to your permit.
If you're at grade A, you're not getting higher than that.
I mean, if you wanna do a station, that's fine,
but you cannot go higher than 30.
If you got a B or C, and your eligible,
you may be able to get an extra 10,000 barrels per day.
You got to agree to implement a seismic monitoring plan
that augments the open public data network.
Then you're gonna have to develop
and implement a seismic event response plan.
This is just saying, you're gonna need to include
the method of monitoring.
We got to know the type of instrumentation,
reporting of data analysis in which network
you're gonna upload this all to.
All of these monitoring plans and response plans,
they're gonna be reviewed
by our state seismologists and our managers.
They're gonna be the ones to hopefully say, all right,
let's just move forward with this.
All right.
We're at the very end.
We're doing great here.
Hopefully, I still have your attention.
All right, permit amendment, application decision,
protest and hearing.
Let's talk real quickly about permanent amendments.
They really vary.
Let's just say you're doing an operator name change.
Those are easy.
Those are just formed fee.
That's all you gotta do.
Let's say you planned a manual injection interval uphold.
Well, that's pretty much a brand new application.
That's what it says here.
Filing requirements vary with the purpose of the amendments.
On our manual this table,
we have links to these tables that show
what you need to submit for different types of amendments.
This is great.
I mean, we have this all printed out on our desk
because it shows what we need to look
for certain amendments.
I highly recommend if you're doing an amendment,
use this because it just helps you out a lot.
All right, what's the timeline of all of this?
What's our permit timing.
How quick should you expect to get your permit back?
Well, according to our rule, Chapter one, rule 201,
our turnaround for these injection disposal applications,
it's 45 days.
That's our turnaround.
30 of those days should be for the initial review,
in 15 days for that final review.
Now, currently we're still meeting that target.
We're all over the place with this pandemic,
and we're still meeting that target.
Obviously, if you go into seismic review
or pressure of you and east Texas.
There's some more time that's gonna go into those.
45 days is our turnaround per Chapter one, rule 201.
Now, this slide, the after permit, this says,
so you're obviously gonna have to do some stuff
once you get your permit.
What are those things?
Well, you gotta do that H-5. Usually it's every five years.
Like I said for that PTT cam, you're gonna do an annual.
Be sure you do your H-5.
What else are you gonna do?
File a completion report.
Do you W-2 or G-1.
You can do this online now.
This just speeds things up.
Lease numbers or for new leases,
they're assigned after the final approval
of your completion report.
That's when you'll get it,
is after you do this completion report.
Also we will send you when your H-10 is due.
Be sure you get that H-10.
Submit it in, or else we can...
Margo, she will come.
We will let you know if you did not turn it in.
Be sure you do that H-5, that H-10 and get that W-2 in.
This slide is just talking about saying,
hey, you propose what you're gonna do.
Hopefully you do what you told us you're gonna do,
but obviously things happen.
This is also saying that if there's any remedial work
that we told you needed to be done, let's say,
we asked you to put a seaman bridge plug in,
do a squeeze or something like that.
This is where we're saying,
hey, you need to do all that before you can start injecting.
Any big changes.
Let's say, you go, Rob,
I didn't even go down to my proposed top interval.
Well, we're gonna need to do a permanent amendment
because that just can't happen.
Just let us know if you know things didn't go
the way you planned and we'll walk you through
what needs to happen.
What happens if you get denied?
I know nobody wants to talk about it, but it happens.
If you have... So remember I talked about these requests
for additional information, these rads.
Technically you only really get two responses to these rads.
If the application remains incomplete
after two additional submittals,
we can return to the application.
That's one way you can get denied or sent back.
If you don't really answer the rads correctly.
Applications will be administratively denied
if the lease is under severance or if it's sealed in.
That's another way.
Finally, if there's unsatisfactory well completion.
Let's say you didn't do it
the way you told us you were gonna do it
and you just kept on going.
Then, yes, we can deny your permit then and cancel it.
So it's important that if any of these things happen,
you just let us know.
We will tell you what the best route you can do
to get everything... To hopefully try and fix the situation.
All right, here it is.
We're almost at the end.
I promise y'all.
Protested applications, all right,
nobody wants to get protested, but it happens.
All right. We, the staff may not administratively
issue a permit if it has a valid protest. All right?
These protests, remember that notification
I was talking about in the published notice.
Protests must be filed within 15 days of the date of notice,
the date of publication or the date that the application
is filed with us at the UIC, whichever is later.
Protests received after that window will not be considered.
Just know that 15 days is the window we give you
for this protest period.
What happens if you get protested, you say,
Rob, my protest, what can I do?
There's three things you can really do
to get out of your protest.
One, you can withdraw your application.
Nobody ever wants to do that.
It's an option.
Two, you can sweet talk your way out of this.
Get a withdrawal letter from the protestant.
Maybe you can get them to withdraw it.
Come to a compromise there or three, you can go to hearing.
The application must be administratively complete,
when it goes to hearing.
There's gonna be a pre-hearing and/or hearing
will be held pretty much up there and docket,
they're gonna make the decision.
They're gonna send it to me.
Then I will move forward with whatever they decide.
Those are your three routes that if you get protested,
like I said, in withdrawal, have your protestor withdrawal
or you can take it to hearing.
I think that's actually the end of it.
Here's our team leads.
Sean Avitt, he's our manager, figure this leader.
Jason Lockie, if you have any questions,
he's over all the permit specialists.
If you have any questions, you're running protest
with the administrator review, Jason Lockie,
he is the man to talk to.
Ric Rosso, he's my manager.
He's great.
If you have any questions regarding the technical,
the seismic review contact, Rick.
Finally Lauryn McFarland.
She's great.
She handles all...
She's over the H-5 groups.
If you got any questions regarding your H-5,
be sure you contact Lauryn McFarland.
I just wanna thank y'all for being here.
Like I said earlier, it really means a lot that you're here
because it means that you care
about what's your applications and you care
that you want to do this right.
I'm here.
I'm always available for you.
If you wanna send me an email,
here's my email right here, rob.castillo@rcc.texas.gov.
Feel free to contact me saying, you got a question,
reach out to me or give us a call at our main line.
One of us perimeters or permit specialist,
we are happy to help you through the application process.
Molly, I think that's it from me.
If there are any questions, I think we can take those.
Molly: Yes.
We've got about five minutes for questions
and it looks like Nicole has three
that haven't been answered yet.
The first can applications be mailed in PDF format
to the UIC email address currently?
Rob: Yeah. Right now because a lot of us are not
in the office, so we're actually accepting PDFs,
these digital copies to be sent in.
Molly: All right, next question for W-14,
what if the permitted disposal interval is 5,500 to 9,000
and the purse for disposal initially are 8,000 to 9,000.
Where should the packer be set?
Rob: As long as that packer is set above your purse
it can be inside of your interval.
Your packer can be set inside of your interval,
but it has to be above your top purse.
It cannot be below your purse,
but it can be within your proposed interval.
Molly: All right. One more question.
What is the current policy guidelines on huff and puff
involving injection and production into and
from of the same well?
Permit, no permit H-10, no H-10 packer, no packer?
Rob: That's actually a good question.
I'm gonna be honest.
I don't know that much off the top of my head
regarding the huff and puff.
I can take that if we can get the info for that question,
the info...
Email for that person, and I will get back to them
because I'm gonna be honest.
I am not that great at the huff and puff.
I don't know.
I think we have a few people who work on them.
If there's a way for us to get that attendees information,
I will get back to them with that information.
Molly: The question was submitted anonymously.
I'm just going to suggest
that whoever submitted that question-
Rob: Reach out to me.
Molly: Email's up on the screen right now.
Rob: You know what, Molly,
going back to that first question,
I think we can still send in the paper application
because we still have staff who is in the office.
I'm pretty sure that we accepted digital copies right now,
but we still would prefer you to send hard copy in
because once again, we have staff who's in the office
scanning these and sending them out.
Is there any other questions, Molly?
I'm sorry.
Didn't mean to cut you off there.
Molly: No. That's fine.
Those are all the questions that we have.
Rob: Great.
Molly: With that, I guess we'll go ahead
and conclude the webinar.
Thank you everyone so much for participating.
Thank you, Rob.
Rob: Thank you.