Erath County residents and the Middle Trinity Groundwater Conservation District (MTGCD) are once again joining forces in an effort to protect area water supplies against the potential hazards posed by oil and gas waste disposal wells. They are sounding a common battle cry, their mantra: “Not within the aquifer recharge zone!”
Why the protest? On Wednesday, May 14, EOG Resources of Fort Worth published a notice of application for a non-commercial disposal well to be located within Erath County, only 1.72 miles east of Morgan Mill. Following the publication of the notice, water watchdogs began organizing a campaign of protest, and now, the next step is to wait for a hearing with the Railroad Commission of Texas (RRC.)
Ramona Nye, spokeswoman for the RRC, said protest letters have been received. However, an application has not yet been filed by EOG. She explained that it is not unusual for protest letters to be delivered prior to the application.
“We have not received an application from EOG for a proposed salt water injection well in the Morgan Mill area,” Nye said. “However, a drilling permit has already been approved for the site.”
Nye also said once an application is received, a hearing would be scheduled since more than the required minimum of one protest letter has been filed.
Joe Cooper, MTGCD manager, said a letter was drafted and sent from his office to the Environmental Service Section of the Oil and Gas Division of the Railroad Commission of Texas the same day the notification of application was published in the Empire-Tribune. Cooper explained that the letter is standard practice of the local groundwater district.
“We (the MTGCD) sent a letter to the Railroad Commission disputing the proposed well,” Cooper said. “This is the standard practice of the district since the site is located within the aquifer recharge zone.”
Cooper’s statement is a common one, repeated time and time again at the MTGCD meetings and at hearing protesting such wells.
“There are better places to locate a disposal well,” Cooper said. “There has to be a better location than directly within the aquifer recharge zone.”
In addition, on May 15, Cooper mailed a certified letter to EOG stating that the letter of protest would be removed if the oil and gas production company would agree to the district’s water testing requirements — another standard practice of the MTGCD.
“The letter to EOG stated our protest will be removed if they agree to benchmark water testing,” Cooper said. “If they agree to water testing at four separate locations around the site, to be tested prior to disposal and annually after operation begins, we will withdraw our objection.”
As of May 28, the letter had not been returned.
Cooper also said the proposed well, which will be injected into strata in subsurface depth interval from 5,500 to 9,000 feet, will be a non-commercial well.
“The concern would be even greater if it was a commercial disposal well,” Cooper said. “Non-commercial means it will only be used to dispose of oil and gas waste and no other commercial or industrial waste which poses a greater threat to our water.”
Disposal wells, such as the one being proposed by EOG, inject fluid into an underground interval that is not productive of oil and gas.
Why the concern? Locals fear the contamination of area water supply. At the same time, the RRC states that the potential harm is minimal.
According to the RRC, oilfield brine or produced (salt) water found in the same formations that produce oil and gas is the primary waste produced. In addition, the RRC states the agency’s permitting and well monitoring processes in addition to field inspections are in place to prevent pollution.
At the same time, the RRC says small quantities of substances used in the drilling, completion and production operations of a well such as minor amounts of drilling mud, fracture fluids, well treatment fluids and residual hydrocarbons may be mixed in the waste stream.
Finally, the RRC says there are no known instances of ongoing groundwater contamination as a result of saltwater disposal activities in the Barnett Shale play - the state’s largest natural gas play that has been actively producing natural gas since 1997.
In the case that the EOG permit is denied, the war is not over. The watchdogs will continue their efforts to safeguard the water supply.
Applications may be protested by affected parties by contacting the Railroad Commission at: Railroad Commission of Texas, Underground Injection Control Program, Wm B. Travis Building, 1701 N. Congress Austin, Texas 78711.
According to the RRC, of the 425 disposal well applications filed in Texas during the fiscal year 2006, 23 were denied, 29 were withdrawn or returned and 28 were referred for a public hearing, representing an approval rate of 80 percent.