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TRCC regulates all saltwater disposal wells
By Jay Troell
A number of new applications are coming to the Railroad Commission of Texas (TRRC) requesting drilling permits for new saltwater disposal wells and re-permitting of existing disposal wells. These permit applications are primarily for the disposal of produced saltwater and some fracking liquids. Produced water, also called oilfield brine, comes up with the production of oil and gas.
The TRRC requires that adjacent landowners be notified of the pending applications, filed by the prospective operator on TRRC Form W-14. The Evergreen Underground Water Conservation District, Atascosa, Frio, Karnes and Wilson Counties, is receiving phone calls concerning these permit applications. Please note that the Evergreen has no legal jurisdiction over these permits and while we are sympathetic to any concerns landowners must contact the TRRC - Austin for specific information about a particular disposal well.
The TRRC website spells out the disposal well’s construction standards. Briefly the well must have surface casing and cement to the deepest usable quality groundwater level i.e. if the bottom of the aquifer is 1000 ft. the surface casing must extend below this depth followed by cement filling the annular space between the pipe and the hole. A second layer consisting of production casing must be installed to the well’s total depth and permanently cemented in place. The third layer of protection is the injection tubing extending to the bottom of the well and a packer to prevent back-flow into the production casing.
Generally the depths of the injection zone will be thousands of feet below any usable quality water but each Form W-14 spells out the injection depth and it is worth noting.
I would suggest anyone receiving a copy of a Form W-14 to review it carefully for a description of the well construction particularly the re-permitting of any existing disposal wells and noting whether there is surface casing below any known fresh water. While a new well has three layers of protection with new pipe and cement some existing wells do not have that protection. Years of corrosion could weaken or penetrate the old casing and cement can deteriorate.
As a safeguard any existing well should be pressure tested to verify the integrity of the casing/cement.
For further information please go the TRRC website and search for Saltwater Disposal Wells Frequently Asked Questions or contact the Railroad Commission directly in Austin.
Jay Troell is a director of the Evergreen Underground Water Conservation District in Pleasanton,.
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