1. Texas Underground Injection Control Program 2017
TCEQ Environmental Conference and Trade Fair May 17, 2017
Lorrie Council, P.G., Manager, UIC Permits Section
Radioactive Materials Division
Office of Waste
Image Group is TCEQ Logo and Diagram of Class I Injection Wells
Image Group is TCEQ Logo and Diagram of Class I Injection Wells

2. Underground Injection Control (UIC) Program 2017 Presentation Content
Organizational & Staff Updates
UIC Well Inventory by Well Class
Class I Injection Well Inventory & Highlights
Class III Injection Well Inventory & Highlights
Class V Injection Well Inventory & Highlights
Aquifer Storage & Recovery Wells
UIC Contact Information
Image Group is TCEQ Logo and Diagram of Class I Injection Wells
Image Group is TCEQ Logo and Diagram of Class  I Injection Wells

3. TCEQ UIC Organization UIC Program Implemented by:
Office of Waste, Radioactive Materials Division (RMD): Permitting
Office of Compliance & Enforcement: Workover Approvals, Routine Operations/Reporting, Compliance, Enforcement
UIC Class I/III Permitting for In-Situ Uranium Facilities Conducted By RMD’s Radioactive Materials Section
RMD’s UIC Permits Section Focus:
Permits/Authorizations Evaluation & Processing for Class I & Class V Injection Wells, including Aquifer Storage & Recovery
UIC Programmatic Reporting
UIC Rulemaking & Legislative Bill Analysis
UIC Program Coordination (internal & external to agency)
Image Group is TCEQ Logo and Diagram of Class  I Injection Wells

4. TCEQ UIC Staff Updates The New Reality: Doing More with Less
This means streamlining processes and prioritizing assignments
UIC Permits Section Staffing Changes:
Tom Ortiz, PhD, PE, UIC Engineer, joined June 2016
Kathryn Hoffman, PE, UIC Engineer, retired May 2017
Conrad Kuharic, PG, UIC Geologist, retired July 2016
Radioactive Materials Section Staffing Changes:
Tony Gonzalez, Uranium Licensing & Permitting Work Lead, as of January 2017
Image reads "Standards + Tools = Streamlined Processes"

5. TCEQ UIC Inventory by Well Class
Type of Injection Well
Number of Facilities
Permitted or Authorized Wells
Active Permitted Wells
Wells Temporarily Abandoned
Other Wells (Plugged, Under Closure Review) I
Hazardous Waste Disposal 23 80 52 3 2
Nonhazardous Waste Disposal 24 93 46 1
III
In Situ Mining 9 NA
6,208 IV
Prohibited (unless specifically authorized) 6
145 V
Miscellaneous Wells (~21 subclasses)
2,475
48,732
Total No. Facilities and Wells (as reported to EPA 2/24/17)
2,537
49,050
6306 4
A table lists numbers of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2017, broken down by class of injection well
A table lists numbers of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2017, broken down by class of injection well

6. UIC Class I Permit Applications & Permits Issued in 2016
Class I Applications Received
Class I Permits Issued
New Permit 8
Permit Renewal 11 12
Permit Renewal/Major Amend 1 3
Permit Renewal/Minor Amend
Major Amendment
Minor Amendment 9 7
Minor Modification 13
Endorsement
Transfer 6
PIU Registration New/Renewal
A table depicts Class 1 applications by type as compared to the Class 1 permits issued for that type, for 2015.
A table depicts Class 1 applications by type as compared to the Class 1 permits issued for that type, for 2015.

7. Class I Highlights
TCEQ received new Class I permit applications for two facilities: New industrial facility along the Texas Gulf Coast (two hazardous waste disposal wells); Commercial non-hazardous waste disposal well in North Texas currently permitted as a Class II oil & gas commercial disposal well.
Several Class I renewal, amendment, & minor modification applications were completed in 2016 or are in process (several in final notice period).
UIC Permits Staff conducted a review of geologic literature & records regarding induced seismicity from deep well injection (David Murry will be covering this in the following presentation)
UIC Permits Staff also worked with permittees on reservoir pressure & operating pressure monitoring for atypical situations in E. Texas & the Texas Panhandle, including downhole injection pressure monitoring
Image is a picture from an injection well site.

8. Class I Highlights, cont.
Two new wells were installed recently but are currently addressing well construction issues & workovers for issues such as mechanical integrity or differing reservoir conditions than anticipated in the permits.
One new well (non-hazardous waste) came on line in early 2017 to replace a well that had been in an over-pressured reservoir (E. Texas). This new well is completed in a lower, under-pressured formation and has downhole pressure monitoring instrumentation. The original well (hazardous waste) was successfully plugged & abandoned.
Three additional hazardous waste disposal wells & two non-hazardous Class I wells were successfully plugged & abandoned in 2016.
Image is a Diagram of Class I Injection Wells

9. UIC Class III Applications & Permits Issued in 2016
Class III Applications Received
Class III Permits Issued
New Area Permit 1
Area Permit Renewal
Permit Renewal/Major Amend
Major Amendment
Permit or PAA Minor Amend 10 9
Permit or PAA Minor Mod 2
Endorsement 11
Transfer
A table lists Class three applications by type compared to class three permits by each respective type.
A table lists Class three applications by type compared to class three permits by each respective type.

10. Class III Highlights
The low pricing of uranium yellow cake continues to affect the uranium industry & TCEQ’s permitting workload for in-situ uranium mines mirrors the industry slowdown.
TCEQ’s UIC Program continued coordinating more closely with EPA Region 6 to facilitate EPA’s review/approval of UIC Program revision requests related to Aquifer Exemptions at Class III in-situ uranium mines.
EPA Region 6 approved one aquifer exemption related UIC Program revision request in March 2017 for the proposed Burke Hollow in-situ uranium mine in Bee County. TCEQ’s formal request for the program revision had been sent to EPA in December 2016.
Image is a photo of uranium yellow cake

11. UIC Class V Authorizations 2016
Class V Well Type
Number of Authorizations or Amendments Issued
Number of Associated Wells
Stormwater Drainage Wells 5D02 1
Aquifer Recharge Wells 5R21 (includes ASR Wells) 2
Septic System/Drain Field Disposal Method 5W32
Aquifer Remediation 5X26 75
3,625 (includes temporary injection points)
Experimental Wells 5X25
Total 80
3,631
A table lists the number of Authorizations and Amendments along with the number of associated wells for each type of class five well.
A table lists the number of Authorizations and Amendments along with the number of associated wells for each type of class five well.

12. Class V Highlights
TCEQ adopted revised rules in response to HB655 on Aquifer Storage & Recovery (ASR) Wells, 30 Texas Administrative Code (TAC), eff. May 19, 2016
Chapter 39 (Public Notice)
Chapters 295 & 297 (Water Rights)
Chapter 331 (UIC)
TCEQ adopted revised rules in response to HB2230 which authorizes Class V permitting of RRC-permitted Class II disposal wells to authorize disposal of non-hazardous drinking water residuals (DWTR) & desalination concentrates. Rules (30 TAC 331) became effective December 29, 2016.
Link to New Class V ASR & DWTR disposal well authorization application forms are located online
As of April 20, 2017, TCEQ received two applications for ASR experimental wells. TCEQ issued one authorization & is processing the other application. No applications have been received for DWTR disposal using a dually-permitted Class V-Class II injection well.

13. Aquifer Storage & Recovery (ASR)
ASR projects may be authorized by individual permit, general permit, or by rule; public notice required for individual ASR permit.
TCEQ notifies groundwater conservation/other special purpose districts with authority to regulate groundwater withdrawal of applications received for authorization by rule.
Rules no longer require a 2-stage authorization process (i.e., pilot project no longer required)
Removed requirement for injectate to meet the drinking water standards found in 30 TAC Chapter 290. Specified injected water must meet requirements of federal SDWA Section 1421 (d)(2)
Image Group is Diagram of ASR Wells
Image Group is Diagram of ASR Wells

14. Aquifer Storage & Recovery
Requires all wells for a single ASR project to be located within a contiguous boundary of one parcel of land or two/more adjacent parcels under common ownership, lease, agreement or contract
ASR projects in the jurisdiction of a groundwater conservation or special purpose district with authority to regulate groundwater withdrawal are subject to the district’s rules for the volume of water produced that exceeds the recoverable volume
Rules require TCEQ to make a determination on the volume of water that can be recovered as compared to the volume of water injected:
Per 30 TAC (g)(1): An authorization or permit issued … may not authorize a volume of water to be recovered that exceeds the volume of water that is injected or the volume of injected water that the commission determines can be recovered, whichever is less
Image group is a photo of a barbed wire fence and a diagram of Texas divided by Groundwater Conservation Districts
Image group is a photo of a barbed wire fence and a diagram of Texas divided by Groundwater Conservation Districts

15. Factors Considered in Determining ASR Recoverability
Hydrogeologic Factors:
Aquifer permeability
Aquifer thickness
Aquifer confinement
Aquifer hydraulic gradient
Geology - structural setting
Geology – Aquifer formation, mineral content
Ambient water quality
Stratigraphic cross section of Permian strata exposed in the Apache Mountains

16. Factors Considered in Determining ASR Recoverability
Design & Operational Factors:
Size of project area & depth to injection zone
Thickness & location of storage zone(s) w/in the aquifer
Initial buffer-zone building phase & long-term maintenance of the buffer zone
Volume of injected water for each cycle
Duration/frequency of cycles & cycle storage periods
Well design & performance/Well field & various configurations
Quality of injected water & possible pre-treatment
Image group is a satellite photo of a field with well configurations and a photo of 3 glass bottles containing liquid.

17. ASR Recoverability: What if I Don’t Have All the Info?
Obtain a UIC Class V Experimental Well Authorization. Design & conduct a testing program, based on project needs, such as :
Obtain additional hydrogeologic information
Characterize injection water
Characterize formation & ambient water quality
Design & build injection/recovery test well(s)
Conduct limited injection & recovery operations (e.g., cycle testing)
Submit monitoring information & summary report
If ASR Project is feasible, prepare & submit ASR application to TCEQ
Image Group is Diagram of ASR wells and a Well cover.
Image Group is Diagram of ASR wells and a Well cover.

18. TCEQ New ASR Authorization Application Form
Required Elements:
General Facility/Operator Information, Core Data Form, Legal Description, Signature Page, Notice Information
ASR Project Area
Area of Review & Artificial Penetrations
Well Construction & Closure
Injection Well Operation
Project Geology, Hydrogeology, and Geochemistry (should have spatially complete actual data for project site such as core testing, well logging, chemistry of injected & aquifer waters to make evaluation of geochemical interactions, etc.)
Demonstration of Recoverability (site specific analysis, may include groundwater modeling, cycle testing data, etc.)
Image is a photo of a TCEQ application form.

19. Questions? Lorrie Council, P.G. Manager, UIC Permits Section
Texas Commission on Environmental Quality
(512)
Main RMD/UIC Phone:
TCEQ Main Web Page
UIC Permits Webpage