The following is a fact sheet for our Petition to the Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR) for Rulemaking to amend (1) the Well Stimulation Treatment (WST) regulations (14 C.C.R. §§ 1783.1 & 1784), and (2) regulations governing chemical testing and disclosure requirements for the Class II Underground Injection Control (UIC) Program (14 C.C.R. §§ 1724.7 & 1724.10). Research from the California Council on Science and Technology’s 2015 report and other sources support the conclusion that well stimulation treatments and Class II injection wells are not being safely administered.
Summary of Key Points:
- DOGGR is only beginning to exercise its true grant of authorities under current oil and gas regulations. As such, more specific requirements are needed to protect the public from the risks of drinking water contamination.
- The safety requirements for the area of analysis performed prior to a WST, more commonly known as hydraulic fracturing and acid fracturing, are not protective of California’s aquifers.
- Current WST regulations are not protective because they require an area of analysis that is only two (2) times the axial dimensional stimulation area (ADSA) (See Petition at 8-9).
- California’s oil and gas fields are frequently located in shallow geologic zones, often located only a thousand feet, and sometimes only hundreds of feet, from shallow aquifers used as sources of water for municipalities and agriculture.
- Considering the great deal of uncertainty in predicting fracture distances during WSTs (see Petition at 9-11), DOGGR must review other wells, water resources, and geologic features within five (5) times the ADSA or one-quarter (1/4) mile, whichever is greater.
- Fluids used in WSTs contain a toxic cocktail of chemical constituents (See Petition at 13), however, enhanced oil recovery (EOR) operations involve many of the same chemicals. In contrast to current WST regulations, there are few testing and reporting requirements for Underground Injection Control (UIC) Class II EOR and wastewater disposal wells in California.
- Chemicals found in oil and gas production fluids include, for example, benzene, toluene, ethylbenzene and xylene (BTEX) compounds, an array of heavy metals including chromium, barium and mercury, and technically enhanced naturally occurring radioactive material (TENORM) (See Petition at 13).
- Currently, there is very little chemical testing required for Class II EOR and wastewater disposal wells. California regulations require a chemical analysis of injection fluids at the time of permitting, or when there is a change in the source of injection fluids.
- For what little testing that does occur, there is a great deal of variation; that is, there are no mandatory testing requirements for chemical compounds of waste fluids. Operators in one oil field can choose to test their waste fluid for semi-volatile organic compounds, metals, and BTEX compounds, while operators in a different field do not.
- Without such appropriate protections, the oil and gas industry can quietly continue WST, EOR and waste disposal, while risking contamination of California’s water resources.