Texas Underground Injection Control Program 2015 TCEQ Environmental Conference and Trade Fair May 6, 2015 Lorrie Council, P.G., Manager, UIC Permits Section Jan Bates, P.E., UIC Permits Section Project Manager Radioactive Materials Division Office of Waste Image Group is TCEQ Logo and Diagram of Class I Injection Wells

UIC Program Overview Image Group is a poster of the six classes of injection wells with labels that show TCEQ regulates Class I, Class III (except brine mining), Class IV and Class V injection wells in Texas while RRC regulates Class II, Class III brine mining, and a few Class V injection wells associated with the oil and gas industry. TCEQ Regulates RRC Regulates None in TX

TCEQ Well Inventory by Class Well Class Type of Injection Well Number of Facilities Active Wells Wells Temp. Abandoned I Hazardous Waste Disposal 24 59 5 Nonhazardous Waste Disposal 27 48 2 III In Situ Mining 7 7,008 - IV Prohibited (unless specifically authorized) 6 140 V Miscellaneous Wells (~21 subclasses) 2,422 43,502 Total No. Facilities and Wells (as reported to EPA in February 2015) 2,486 50,757 Image Group is TCEQ Logo and Diagram of Class I Injection Wells Table lists number of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2015, broken down by class of injection well

UIC Class I Permit Applications and Permits Issued in 2014 Class I Applications Class I Permits New Permit 12 Permit Renewal 8 5 Permit Renewal/Major Amend 6 Permit Renewal/Minor Amend Major Amendment 1 Minor Amendment Minor Modification 24 Endorsement 7 Transfer 11 PIU Registration New/Renewal 2 PIU Minor Amendment 4 Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Class I Highlights TCEQ received a large number of new Class I permit applications; some for new facilities, others as replacements for old wells (half of active wells are > 30 years old). TCEQ also processed 24 minor modifications related to workovers Railroad Commission “No-Harm” letters were initially not granted for a few applications due to presence of newer Oil & Gas wells in Texas (production from new petroleum reservoirs); this required Class I applicants to provide more detailed information to Railroad Commission for their evaluation TCEQ successfully flowed Class I injection well permit data to EPA in 2014 using the NEIEN dataflow process Image Group is TCEQ Logo and Diagram of Class I Injection Wells

UIC Class III Applications and Permits Issued in 2014 Class III Permits New Area Permit 2 Area Permit Renewal 1 Permit Renewal/Major Amend Production Area Authorization Major Amendment Permit or PAA Minor Amend 3 Permit or PAA Minor Mod Endorsement Transfer Aquifer Exemption Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Class III Highlights TCEQ’s UIC Program coordinated more closely with EPA Region 6 to facilitate EPA’s review and approval of UIC Program revision requests related to Aquifer Exemptions at Class III in-situ uranium mines. TCEQ/EPA site visit to the Mesteña mine to view proposed exempted area and nearby wells (non-potable) TCEQ began early coordination with EPA for the Palangaña mine to provide technical information related to a proposed exemption expansion, nearby wells, groundwater flow, etc. EPA Region 6 approved two aquifer exemption related UIC Program revision requests in 2014/2015: Rosita Expansion (Requested 5/20/10;Approved 1/30/14) Mesteña Expansion (Requested 5/7/13; Approved 9/25/14) La Palangana Expansion (Requested 12/5/14; Approved 3/26/15) Image Group is TCEQ Logo and Diagram of Class I Injection Wells

UIC Class V Authorizations 2014 Class V Well Type Number of Authorizations & Amendments Number of Associated Wells Aquifer Recharge 5R21 1 Aquifer Remediation 5X26 67 1,578 Other Wells 5X27 2 5 Total 70 1,584 70 Voluntary Revocation Applications Processed - All Were Aquifer Remediation Authorizations (most related to UIC outreach efforts) Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Class V Inventory Initiative TCEQ was able to use a student intern in 2014 to conduct a pilot program for a new initiative to review Class V authorization files, obtain updated information from regulated entities, and update TCEQ’s databases TCEQ met with EPA Region 6 and HQ staff to discuss challenges with electronic reporting and to conceptually lay out a simple data reporting project TCEQ requested UIC Special Project funding from EPA Region 6 and was granted a partial award for FY16 to expand the Class V authorization research and database update initiative, with a longer-term focus on electronic data reporting to EPA Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Injection Well Usage Trends Municipal water providers, industry, and agriculture sectors expressed interest in developing Aquifer Storage and Recovery (ASR) projects in Texas as a water management tool (legislation on ASR was introduced in the 84th Texas Legislature) Water providers continue to express interest in desalinating brackish groundwater and seawater to create new water supplies, as well as using injection wells to dispose drinking water treatment residuals (DWTR) (legislation was introduced in the 84th Texas Legislature on desalination) TCEQ and Texas Railroad Commission, in consultation with EPA Region 6 and Oklahoma DEQ, evaluated dual permitting of Class II salt water disposal wells and Class V wells for disposal of DWTR (legislation was introduced the 84th Texas Legislature on dual permitting) Image Group is TCEQ Logo and Diagram of Class I Injection Wells

UIC Related Rule Revisions HB 1079 (83rd Texas Legislature) regarding when contested case hearings can be considered for Class III Production Area Authorizations and use of Range Tables in Class III mine area permits – adopted 11/19/14, effective 12/11/14 SB 1532 (83rd Texas Legislature) concerning limited new authorizations for injection into and through the Edwards Aquifer in specific locations – to be considered for adoption at the Commission’s 6/3/15 Agenda Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Focus on In-Situ Uranium Mining During its February 2014 periodic program evaluation of the Texas Agreement State Programs, the Nuclear Regulatory Commission closely reviewed TCEQ’s UIC uranium mining regulatory program(Class III and Class I injection well permits and facilities); NRC found the UIC Program to be satisfactory EPA proposed new rules on 1/27/15 relating to groundwater restoration standards for in-situ uranium mining operations; the proposed federal rules would require substantial revisions to the Texas Class III UIC and Uranium Licensing rules; EPA’s deadline for comments on the proposed rules is 5/27/15 Image Group is TCEQ Logo and Diagram of Class I Injection Wells

TCEQ UIC Permits Section Staffing Update UIC Permits Section recently added new technical staff to address retirements and transfers that occurred in the last few years; Staffing now includes: 1 Section Manager (TX PG) 7 Geologists (TX PGs) 3 Engineers (TX PEs) 1 Environmental Permit Specialist 1 Customer Service Rep (part-time, contract) Image Group is TCEQ Logo and Diagram of Class I Injection Wells

Questions? Image Group is TCEQ Logo and Diagram of Class I Injection Wells

UIC Program Contact Information Lorrie Council, PG, Manager UIC Permits Section Radioactive Materials Division, Office of Waste Phone: 512-239-6461, Fax: 512-239-6464 Email: lorrie.council@tceq.texas.gov http://www.tceq.texas.gov Image Group is TCEQ Logo and Diagram of Class I Injection Wells http://www.tceq.texas.gov/permitting/waste_permits/uic_permits/uic.html