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Produced Water White Paper 34 designed to protect underground sources of drinking water (USDWs). A USDW is an aquifer or portion of an aquifer that supplies any public water systems or contains sufficient quantity of groundwater to supply a public water system; currently supplies drinking water for human consumption or contains fewer than 10,000 milligrams/liter total dissolved solids; and is not an aquifer exempted from UIC regulations. For regulatory control purposes, underground injection is grouped into five classes of injection wells. An injection well is defined as any bored, drilled or a driven shaft or a dug hole, where the depth is greater than the largest surface dimension that is used to inject fluids underground. Class I wells are used for the emplacement of hazardous and nonhazardous fluids (industrial and municipal wastes) into isolated formations beneath the lowermost underground source of drinking water. Class I operations are the most strictly regulated by the SDWA and are further controlled by the Resource Conservation and Recovery Act. Class II wells inject brines and other fluids associated with oil and gas production. Class III wells inject fluids associated with solution mining of minerals. Class IV wells, which involve the injection of hazardous or radioactive wastes into or above a USDW, are banned unless authorized under other statutes for groundwater remediation. Class V wells include underground injection wells not included in Classes I through IV. Class V governs wells that inject nonhazardous fluids into or above a USDW — typically shallow, onsite disposal systems, such as floor and sink drains discharging directly or indirectly to ground water, dry wells, leach fields, and similar types of drainage wells. Wells used for injecting produced water are considered Class II wells. Class II subclasses include enhanced recovery wells (Class II-R) and disposal wells (Class II-D). Numerous fields are operated under an enhanced recovery mode when water, steam, or other substances are injected to a producing formation to help move the crude oil to wells for collection. These are typically water-flood or steam-flood operations. The application of enhanced recovery can prolong the productive life of certain hydrocarbon deposits (i.e., water-drive reservoirs) and increases the resource yield. In this scenario, produced water ceases being a waste and becomes a beneficial resource. Produced water can also be injected solely for disposal. In this case, the water is typically injected to a formation other than the producing formation. The EPA’s regulations establish minimum standards for state programs prior to receiving primary responsibility (primacy) for the UIC program under Section 1422 of the SDWA. (A state program can always be more stringent than the federal blueprint.) In 1981, Congress added Section 1425 to the SDWA, which relieves oil and gas-related injection well programs in the states from having to meet the technical requirements in the federal UIC regulations. (This reinforced the statutory instruction that the EPA not interfere with the production of oil and gas unless the requirements are essential for the protection of USDWs.) Instead, the demonstration can be made that the state has an effective program (including adequate oversight, record-keeping, and reporting) in place to prevent the endangerment of USDWs by underground injection operations. The EPA thus can approve delegation of the UIC program to the states in several ways, including for (1) all well classes under Section 1422 of the SDWA, (2) oil and gas injection wells under Section 1425 of the SDWA, and/or (3) all but oil and gas injection wells under SectionPDF Image | Produced Water from Production of Crude Oil
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