FERC Order Denying Stay of Kinder Morgan's Broad Run Expansion ProjectMarcellus Drilling News
Several anti-drillers filed an appeal of the Federal Energy Regulatory Commission's Certificate for the Kinder Morgan Broad Run Expansion Project, asking for a stay claiming a removal of 40 acres of forest for a compressor station would irreparably harm Mom Earth. FERC has ruled against the stay and told the antis Mom Earth will be just fine.
Final Environmental Impact Statement for NEXUS Gas Transmission ProjectMarcellus Drilling News
The Final Environmental Impact Statement (FEIS) for the NEXUS Pipeline project, a $2 billion, 255-mile interstate pipeline that will run from Ohio through Michigan and eventually to the Dawn Hub in Ontario, Canada. FERC gave the project a thumbs up, which clears the way for a Certificate to be issued in early 2017.
A letter from Rover Pipeline to the Federal Energy Regulatory Commission requesting the agency issue the final certificate that will allow Rover to begin tree-clearing and construction of the 511-mile pipeline through Pennsylvania, West Virginia, Ohio and Michigan. If the certificate is delayed beyond the end of 2016, it will delay the project an extra year due to tree-clearing restrictions (to accommodate federally-protected bats).
A report issued by the Government Accountability Office looking at the information collected by the federal EPA and the individual states with regard to wastewater fluids injected into Class II injection wells. Several anti-drilling members of the U.S. Congress wanted ammunition in their efforts to oppose fracking and figured this was a good as way as any to do
Delaware Riverkeeper Letter to DRBC Requesting Intervention to Stop PennEast ...Marcellus Drilling News
A letter authored by THE Delaware Riverkeeper herself, Maya van Rossum, petitioning the Delaware River Basin Commission to interject itself into the permitting process of the PennEast Pipeline that is slated to run from Wilkes-Barre, PA all the way to Trenton, NJ, carrying abundant, cheap Marcellus Shale natural gas.
FERC Order Denying Stay of Kinder Morgan's Broad Run Expansion ProjectMarcellus Drilling News
Several anti-drillers filed an appeal of the Federal Energy Regulatory Commission's Certificate for the Kinder Morgan Broad Run Expansion Project, asking for a stay claiming a removal of 40 acres of forest for a compressor station would irreparably harm Mom Earth. FERC has ruled against the stay and told the antis Mom Earth will be just fine.
Final Environmental Impact Statement for NEXUS Gas Transmission ProjectMarcellus Drilling News
The Final Environmental Impact Statement (FEIS) for the NEXUS Pipeline project, a $2 billion, 255-mile interstate pipeline that will run from Ohio through Michigan and eventually to the Dawn Hub in Ontario, Canada. FERC gave the project a thumbs up, which clears the way for a Certificate to be issued in early 2017.
A letter from Rover Pipeline to the Federal Energy Regulatory Commission requesting the agency issue the final certificate that will allow Rover to begin tree-clearing and construction of the 511-mile pipeline through Pennsylvania, West Virginia, Ohio and Michigan. If the certificate is delayed beyond the end of 2016, it will delay the project an extra year due to tree-clearing restrictions (to accommodate federally-protected bats).
A report issued by the Government Accountability Office looking at the information collected by the federal EPA and the individual states with regard to wastewater fluids injected into Class II injection wells. Several anti-drilling members of the U.S. Congress wanted ammunition in their efforts to oppose fracking and figured this was a good as way as any to do
Delaware Riverkeeper Letter to DRBC Requesting Intervention to Stop PennEast ...Marcellus Drilling News
A letter authored by THE Delaware Riverkeeper herself, Maya van Rossum, petitioning the Delaware River Basin Commission to interject itself into the permitting process of the PennEast Pipeline that is slated to run from Wilkes-Barre, PA all the way to Trenton, NJ, carrying abundant, cheap Marcellus Shale natural gas.
A critique of New York's draft drilling regulations for hydraulic fracturing submitted by Judith Enck, Region 2 Administrator for the federal Environmental Protection Agency. The critique was submitted on Weds, Jan 11 just hours before the filing deadline closed at the New York State DEC.
NY DEC Letter Refusing to Grant Stream Crossing Permits for Constitution Pipe...Marcellus Drilling News
A totally bogus BS letter refusing to grant stream crossing permits for the much-needed Constitution Pipeline in New York State. Gov. Andrew Cuomo instructed the Dept. of Environmental Conservation to refuse the permits on political grounds--and this letter is the bogus excuses the DEC made up in order to cover Cuomo's political dictatorial decision.
Positive Declaration for Pilgrim Pipeline from NY DEC & Thruway AuthorityMarcellus Drilling News
A document instruction the proposed Pilgrim Pipeline, which is really two pipelines (one heading south from Albany to NJ carrying Bakken oil, the other north from NJ to Albany carrying gasoline and other refined products) will need to complete a full environmental review before the project will be considered. Both anti-fossil fuel freaks and the pipeline builders welcomed the news (strangely).
Submission of Lake Ontario Waterkeeper - Relicensing hearing before the Canad...LOWaterkeeper
Cameco Corporation (Cameco) is currently applying to renew its Fuel Facility Operating Licence FFOL-3631.0/2017 (the licence) for its Port Hope Conversion Facility (PHCF). This licence was issued on February 28, 2012, (valid from March 1, 2012) and will expire February 28, 2017.
The requested licence is for a ten-year period and would permit Cameco to continue to produce nuclear fuel for reactors in Canada and abroad. Currently, the facility is permitted to process and produce up to 2,800 tonnes of uranium as UO2 which is used for CANDU reactor fuel and up to 12,500 tonnes of UF6 which is exported for processing into light water reactor fuel. The requested licence would also permit Cameco to make significant changes to its facility, renovating some buildings, decommissioning others, and building entirely new facilities on the
PHCF site. These changes collectively comprise its Vision in Motion (VIM) project. More specifically, Cameco’s proposed VIM project involves:
• Removing up to 150,000 cubic metres (m3) of radioactive contaminated waste. This includes contaminated soil excavation, “legacy” drummed waste generated at the facility before 1988, and rubble from demolished older buildings at the PHCF site and Center Pier). This waste will be taken to Canadian Nuclear Laboratories’ secure long-term waste management facility in Port Hope;
• Removing 11 older or under-utilized buildings from the PHCF site and Center Pier;
• Constructing of 4 new buildings and the refurbishment or modification of 7 other buildings at the site;
• Installing of new pump and treat wells to address the groundwater contamination that will remain under the PHCF site after VIM is completed;
• Improving the facility’s stormwater management infrastructure; and
• Moving the eastern fence-line of the PHCF away from the harbour to help facilitate greater public access to Port Hope’s waterfront.
Waterkeeper has been involved in several other past decision-making processes before the CNSC concerning this facility, including its environmental assessment (EA) under the Canadian Environmental Assessment Act, 1992, as well as its application for a Certificate of Approval from the then Ontario Ministry of Environment for its industrial sewage permit. During these processes, Waterkeeper expressed concerns regarding the facility’s poor stormwater management, the need for better cooling water technology, and the need for better environmental monitoring and public communication.
In the last five years, some progress has been made to ensure the initiative supports a more swimmable, drinkable, and fishable Lake Ontario. But more work is still needed.
The final version of a guidance from the federal Environmental Protection Agency establishing a definition for what is and is not diesel fuel for the purposes of evaluating whether that substance can be allowed in fracking fluid.
Submission of Lake Ontario Waterkeeper - Reviewing Canadian Nuclear Safety Co...LOWaterkeeper
The Port Hope Area Initiative (PHAI) is an internationally significant undertaking. It is the biggest radioactive waste clean-up project in Canadian history, and involves one of the largest nuclear waste holding facilities in North America. The PHAI is comprised of two distinct projects: the Port Hope waste relocation project (“Port Hope Project”), and the Port Granby waste relocation project (“Port Granby Project”). Together, both projects seek to clean up a combined two-million cubic metres (m3) of low-level radioactive waste from various sites across Port Hope and Port Granby.
The Port Hope Project involves excavating 1,223,250 m3 of historic radioactive waste from several sites around the town of Port Hope to a Long-term Waste Management Facility (PH LTWMF) just north of the community. The project was subject to an environmental assessment (EA) under the Canadian Environmental Assessment Act, 1992 (CEAA, 1992) which was conducted from 2001 to 2007. In 2009, the CNSC granted a five-year Nuclear Waste Substance Licence to Atomic Energy Canada Limited (AECL) to implement the project. In 2012, AECL applied to have its licence extended for ten years. This was granted by the Canadian Nuclear Safety Commission (CNSC), making the current licence valid until December 31, 2022.
The Port Granby Project involves the removal of 450,000 m3 of historic radioactive waste from the existing and poorly contained Port Granby waste management facility to a new above ground waste management facility (the PG LTWMF) 700 metres north of the Lake Ontario shoreline. The Port Granby Project was also subject to a federal EA under CEAA, 1992 and the project was approved in 2009. After a public hearing in September 2010, the CNSC granted AECL a ten-year licence to implement this project.
In the last five years, some progress has been made to ensure the initiative supports a more swimmable, drinkable, and fishable Lake Ontario. But more work is still needed.
DRBC Docket: XTO Energy Application to Withdraw Surface Water at Oquaga CreekMarcellus Drilling News
Delaware River Basin Commission - Hearing to review an application form XTO Energy to withdraw .25 million gallons of water per day from the Oquaga Creek in the Town of Sanford, NY for purposes of shale gas drilling exploration and production.
Summary of New Rules for Horizontal Drilling in West Virginia, as of July 1, ...Marcellus Drilling News
A summary of the new rules drillers in WV have to follow--rules that have been developed over the past two years. This summary of the changes and new rules is provided by the WV law firm Lewis Glasser Casey & Rollins, PLLC.
Waterkeeper's Review of CNSC's Regulatory Oversight Report for Uranium and Nu...LOWaterkeeper
The CNSC asked Swim Drink Fish Canada/Lake Ontario to look into its 2016 Regulatory Oversight Report for
Uranium and Nuclear Substance Processing Facilities in Canada. CNSC provided funding for the review.
Hydrogeologist Wilf Ruland provides an independent review of of the CNSC’s 2016 Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities, with a focus on environmental protection performance including storm water
runoff management at Cameco’s Port Hope Conversion Facility. Lake Ontario Waterkeeper was awarded CNSC funding to support Wilf's review.
AN ACT TO (1) RECONSTITUTE THE MINING COMMISSION AS THE MINING AND ENERGY COMMISSION, (2) REQUIRE THE MINING AND ENERGY COMMISSION AND OTHER REGULATORY AGENCIES TO DEVELOP A MODERN REGULATORY PROGRAM FOR THE MANAGEMENT OF OIL AND GAS EXPLORATION AND DEVELOPMENT ACTIVITIES IN THE STATE, INCLUDING THE USE OF HORIZONTAL DRILLING AND HYDRAULIC FRACTURING FOR THAT PURPOSE, (3) AUTHORIZE HORIZONTAL DRILLING AND HYDRAULIC FRACTURING, BUT PROHIBIT THE ISSUANCE OF PERMITS FOR THESE ACTIVITIES PENDING SUBSEQUENT LEGISLATIVE ACTION, (4) ENHANCE LANDOWNER AND PUBLIC PROTECTIONS RELATED TO HORIZONTAL DRILLING AND HYDRAULIC FRACTURING, AND (5) ESTABLISH THE JOINT LEGISLATIVE COMMISSION ON ENERGY POLICY.
design specification and problems of kuraz irrigation schemetamasgenqmokonnin
project work on design specification and design ,construction and management problems of omo kuraz-1 sugar development project irrigation system. omo kuraz irrigation project construction was started since 2004 E,c . its for education purpose only
A critique of New York's draft drilling regulations for hydraulic fracturing submitted by Judith Enck, Region 2 Administrator for the federal Environmental Protection Agency. The critique was submitted on Weds, Jan 11 just hours before the filing deadline closed at the New York State DEC.
NY DEC Letter Refusing to Grant Stream Crossing Permits for Constitution Pipe...Marcellus Drilling News
A totally bogus BS letter refusing to grant stream crossing permits for the much-needed Constitution Pipeline in New York State. Gov. Andrew Cuomo instructed the Dept. of Environmental Conservation to refuse the permits on political grounds--and this letter is the bogus excuses the DEC made up in order to cover Cuomo's political dictatorial decision.
Positive Declaration for Pilgrim Pipeline from NY DEC & Thruway AuthorityMarcellus Drilling News
A document instruction the proposed Pilgrim Pipeline, which is really two pipelines (one heading south from Albany to NJ carrying Bakken oil, the other north from NJ to Albany carrying gasoline and other refined products) will need to complete a full environmental review before the project will be considered. Both anti-fossil fuel freaks and the pipeline builders welcomed the news (strangely).
Submission of Lake Ontario Waterkeeper - Relicensing hearing before the Canad...LOWaterkeeper
Cameco Corporation (Cameco) is currently applying to renew its Fuel Facility Operating Licence FFOL-3631.0/2017 (the licence) for its Port Hope Conversion Facility (PHCF). This licence was issued on February 28, 2012, (valid from March 1, 2012) and will expire February 28, 2017.
The requested licence is for a ten-year period and would permit Cameco to continue to produce nuclear fuel for reactors in Canada and abroad. Currently, the facility is permitted to process and produce up to 2,800 tonnes of uranium as UO2 which is used for CANDU reactor fuel and up to 12,500 tonnes of UF6 which is exported for processing into light water reactor fuel. The requested licence would also permit Cameco to make significant changes to its facility, renovating some buildings, decommissioning others, and building entirely new facilities on the
PHCF site. These changes collectively comprise its Vision in Motion (VIM) project. More specifically, Cameco’s proposed VIM project involves:
• Removing up to 150,000 cubic metres (m3) of radioactive contaminated waste. This includes contaminated soil excavation, “legacy” drummed waste generated at the facility before 1988, and rubble from demolished older buildings at the PHCF site and Center Pier). This waste will be taken to Canadian Nuclear Laboratories’ secure long-term waste management facility in Port Hope;
• Removing 11 older or under-utilized buildings from the PHCF site and Center Pier;
• Constructing of 4 new buildings and the refurbishment or modification of 7 other buildings at the site;
• Installing of new pump and treat wells to address the groundwater contamination that will remain under the PHCF site after VIM is completed;
• Improving the facility’s stormwater management infrastructure; and
• Moving the eastern fence-line of the PHCF away from the harbour to help facilitate greater public access to Port Hope’s waterfront.
Waterkeeper has been involved in several other past decision-making processes before the CNSC concerning this facility, including its environmental assessment (EA) under the Canadian Environmental Assessment Act, 1992, as well as its application for a Certificate of Approval from the then Ontario Ministry of Environment for its industrial sewage permit. During these processes, Waterkeeper expressed concerns regarding the facility’s poor stormwater management, the need for better cooling water technology, and the need for better environmental monitoring and public communication.
In the last five years, some progress has been made to ensure the initiative supports a more swimmable, drinkable, and fishable Lake Ontario. But more work is still needed.
The final version of a guidance from the federal Environmental Protection Agency establishing a definition for what is and is not diesel fuel for the purposes of evaluating whether that substance can be allowed in fracking fluid.
Submission of Lake Ontario Waterkeeper - Reviewing Canadian Nuclear Safety Co...LOWaterkeeper
The Port Hope Area Initiative (PHAI) is an internationally significant undertaking. It is the biggest radioactive waste clean-up project in Canadian history, and involves one of the largest nuclear waste holding facilities in North America. The PHAI is comprised of two distinct projects: the Port Hope waste relocation project (“Port Hope Project”), and the Port Granby waste relocation project (“Port Granby Project”). Together, both projects seek to clean up a combined two-million cubic metres (m3) of low-level radioactive waste from various sites across Port Hope and Port Granby.
The Port Hope Project involves excavating 1,223,250 m3 of historic radioactive waste from several sites around the town of Port Hope to a Long-term Waste Management Facility (PH LTWMF) just north of the community. The project was subject to an environmental assessment (EA) under the Canadian Environmental Assessment Act, 1992 (CEAA, 1992) which was conducted from 2001 to 2007. In 2009, the CNSC granted a five-year Nuclear Waste Substance Licence to Atomic Energy Canada Limited (AECL) to implement the project. In 2012, AECL applied to have its licence extended for ten years. This was granted by the Canadian Nuclear Safety Commission (CNSC), making the current licence valid until December 31, 2022.
The Port Granby Project involves the removal of 450,000 m3 of historic radioactive waste from the existing and poorly contained Port Granby waste management facility to a new above ground waste management facility (the PG LTWMF) 700 metres north of the Lake Ontario shoreline. The Port Granby Project was also subject to a federal EA under CEAA, 1992 and the project was approved in 2009. After a public hearing in September 2010, the CNSC granted AECL a ten-year licence to implement this project.
In the last five years, some progress has been made to ensure the initiative supports a more swimmable, drinkable, and fishable Lake Ontario. But more work is still needed.
DRBC Docket: XTO Energy Application to Withdraw Surface Water at Oquaga CreekMarcellus Drilling News
Delaware River Basin Commission - Hearing to review an application form XTO Energy to withdraw .25 million gallons of water per day from the Oquaga Creek in the Town of Sanford, NY for purposes of shale gas drilling exploration and production.
Summary of New Rules for Horizontal Drilling in West Virginia, as of July 1, ...Marcellus Drilling News
A summary of the new rules drillers in WV have to follow--rules that have been developed over the past two years. This summary of the changes and new rules is provided by the WV law firm Lewis Glasser Casey & Rollins, PLLC.
Waterkeeper's Review of CNSC's Regulatory Oversight Report for Uranium and Nu...LOWaterkeeper
The CNSC asked Swim Drink Fish Canada/Lake Ontario to look into its 2016 Regulatory Oversight Report for
Uranium and Nuclear Substance Processing Facilities in Canada. CNSC provided funding for the review.
Hydrogeologist Wilf Ruland provides an independent review of of the CNSC’s 2016 Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities, with a focus on environmental protection performance including storm water
runoff management at Cameco’s Port Hope Conversion Facility. Lake Ontario Waterkeeper was awarded CNSC funding to support Wilf's review.
AN ACT TO (1) RECONSTITUTE THE MINING COMMISSION AS THE MINING AND ENERGY COMMISSION, (2) REQUIRE THE MINING AND ENERGY COMMISSION AND OTHER REGULATORY AGENCIES TO DEVELOP A MODERN REGULATORY PROGRAM FOR THE MANAGEMENT OF OIL AND GAS EXPLORATION AND DEVELOPMENT ACTIVITIES IN THE STATE, INCLUDING THE USE OF HORIZONTAL DRILLING AND HYDRAULIC FRACTURING FOR THAT PURPOSE, (3) AUTHORIZE HORIZONTAL DRILLING AND HYDRAULIC FRACTURING, BUT PROHIBIT THE ISSUANCE OF PERMITS FOR THESE ACTIVITIES PENDING SUBSEQUENT LEGISLATIVE ACTION, (4) ENHANCE LANDOWNER AND PUBLIC PROTECTIONS RELATED TO HORIZONTAL DRILLING AND HYDRAULIC FRACTURING, AND (5) ESTABLISH THE JOINT LEGISLATIVE COMMISSION ON ENERGY POLICY.
design specification and problems of kuraz irrigation schemetamasgenqmokonnin
project work on design specification and design ,construction and management problems of omo kuraz-1 sugar development project irrigation system. omo kuraz irrigation project construction was started since 2004 E,c . its for education purpose only
Human relations are more fragile than even glassware: if you hold them carefully they remain beautiful and attractive and if you drop/neglect them they break into numerous pieces which can never be attached and even if attached well they can only carry the broken impressions. Therefore, maintaining human relations today has become a ‘herculean task’ as life today has become very mechanical for many due to several reasons. It is the thought of this aspect of life today that gave birth to an ‘INNOVATIVE GESTURE’ to be extended to everybody who wish to keep their relations ever alive.
We, the final year B.Tech. students, thought “can’t we do something that bridges the gap between people”? It struck our minds that we must help everybody in maintaining their relations well. Thus, human beings always remain humane despite their hectic schedule. That’s how 12NUIT.COM cameinto existence.
What can 12NUIT.COM do?
One may feel like greeting someone on his/her birthday/marriage day/success/achievement/ festivals and so on. However, one may not be able to do so due to the pressures of day-to-day life, though love to do. Such slips may be well avoided with the use of 12NUIT.COM. Thus,everyone is welcome to avail the services of 12NUIT.COM anytime.
We accept your orders to be sent to your dear ones. You may send your gift through us. Thus, our services hope to keep your relations much stronger than the strongest.
How did 12NUIT.COM come about?
One day one of our friends failed to wish his closest friend on her birthday. As a result there arose a serious problem in the form of misunderstanding and doubting. It took quite a long time to make peace. Given this bad, sad and unpleasant experience, we thought such slips must be avoided. Besides, we should become the source of avoidance as we believe in “prevention is better than cure”. Thanks to that girl who was indeed the sole reason for the reality of 12NUIT.COM.
“HOW MAY I HELP YOU?” says 12NUIT.COM
Delaware Riverkeeper v Pennsylvania Dept. of Environmental Protection - Leidy...Marcellus Drilling News
A sham court case brought by radical Big Green organization THE Delaware Riverkeeper. The case seeks to overturn decisions in both PA and NJ by environmental agencies in those state that had issued permits allowing the Williams Transco Leidy Southeast Expansion project to commence. The U.S. Court of Appeals found the agencies acted properly in reaching decisions to allow the project to commence.
Radical Enviro Groups' Notice of Intent to Sue the EPA to Force Regulation of...Marcellus Drilling News
Another "sue and settle" lawsuit that attempts to force the federal Environmental Protection Agency to illegally regulate oil and gas drilling--which Constitutionally is left up to the individual states. It is a sleazy way to stop fracking and drilling for what these groups consider to be "dirty" fossil fuels.
On June 21, 2016, United States District Judge Scott Skavdahl granted BakerHostetler’s petition for review of final agency action and declared the Bureau of Land Management’s (BLM’s) hydraulic fracturing rule unlawful. The court’s judgment sets aside BLM’s hydraulic fracturing rule.
Filling the Void: A Citizens' Audit of Ohio Oil and Gas Waste Disposal WellsMarcellus Drilling News
A faux "report" produced by 16 untrained volunteers (anti-drilling activitists) who claim to find evidence of mismanagement of the wastewater injection well program in Ohio on the part of the Ohio Dept. of Natural Resources. The solution, according to the virulently anti-drilling Ohio Citizen Action group that produced the report, is to have the federal EPA take over active oversight of the injection well program.
The Great Lakes-St. Lawrence River Basin Water Resources Compact was signed into federal law with great fanfare in 2008. However, states must do more to realize the Compact’s potential to better manage Great Lakes waters in and outside of the basin through comprehensive water conservation and efficiency programs, improved data sharing and more comprehensive permitting.
FERC Approval for Tennessee Gas Pipeline - Connecticut Expansion ProjectMarcellus Drilling News
The official FERC approval/certificate allowing the Connecticut Expansion project to move forward. The project includes building 13.42 miles of new pipeline loops in three states: Connecticut, Massachusetts and New York. When completed, the new looping will serve an additional 72,100 dekatherms of (mostly) Marcellus Shale gas to three utility companies in Connecticut.
A report by Citizens for Pennsylvania's Future criticizing PA Senate Bill 1100 and PA House Bill 1950 which are comprehensive bills adding new rules and regulations for drilling in the Marcellus Shale. PennFuture says the legislation in the bills should be "unbundled" and considered separately.
Texas Aquifer Exemptions - Clean Water Action august 2016
1. 1TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
What are Aquifer Exemptions?
Underground sources of drinking water (USDW) are federally-
protected by the Safe Drinking Water Act’s (SDWA) Under-
ground Injection Control (UIC) program. However, a little
known aspect of the program allows certain oil and gas and
mining activity to occur in groundwater that would otherwise
be protected as a drinking water source. This is an aquifer
exemption.
EPA developed the aquifer exemption program in the
1980’s when oil and gas interests argued that certain oil and
gas development would not be possible if every underground
source of drinking water were protected. Groundwater con-
taining less than 10,000 mg/l total dissolved solids (TDS) is
considered a USDW, unless EPA grants an aquifer exemption
which removes protections and allows injection activity.
In this way, aquifer exemptions essentially “write off”
underground sources of drinking water to allow for oil and
gas and mining activity to occur. Oil and gas companies use
aquifer exemptions for two primary purposes: to inject waste-
water underground for permanent disposal, or to inject water,
steam, chemicals and other fluids for enhanced recovery (ER).
Texas Aquifer Exemptions:
Ignoring Federal Law to
Fast Track Oil & Gas Drilling
T
he Railroad Commission of Texas has failed to implement Safe Drinking Water Act protections
and allowed injection activity into underground sources of drinking water — removing
them from future supplies at a time of rapid population growth and recurrent drought.
The Commission has deemed federal regulations for aquifer exemptions “inapplicable” to Texas
oil and gas operations, despite agreeing, in 1982, to federal oversight of aquifer exemptions in a
Memorandum of Agreement with EPA.
Producing oil fields were given blanket approvals to inject fluids into potential drinking water
sources regardless of water quality in 1982, yet a map or list of these areas was never released.
Over the last 30 years of underground injection activity, no subsequent applications for aquifer
exemptions were ever filed. This disregard for federal requirements has led to decades of confu-
sion, potential illegal injection and increased risk to drinking water. The Railroad Commission
effectively prioritized the concerns of the oil and gas industry over the long term drinking water
needs of Texas residents.
2. 2TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
Railroad Commission Does Not Have
a Complete Idea of Which Aquifers
are Exempt
Injection wells used for oil and gas operations are
regulated under Class II injection wells of the UIC
program. Texas has 54,811 Class II injection wells, the
most of any state in the nation.1 These are wells used
for oil and gas wastewater disposal and enhanced
recovery. Surprisingly for a state with this many
injection wells, Texas has never reviewed any aquifer
exemption applications. [See Figure 1.] In practice this
would mean that the Railroad Commission has never
permitted an injection well into an aquifer contain-
ing less than 10,000 mg/l TDS. While possible, Clean
Water Action is skeptical of this conclusion due the
vast number of injection wells in Texas, and the rela-
tively common occurrence of injection into relatively
high quality aquifers in other states.
Through Freedom of Information Act (FOIA)
requests to U.S. EPA and the Railroad Commission,
Clean Water Action uncovered a potential multi-
decade long pattern in which the Railroad Commis-
sion ignored federal requirements to ensure protec-
tion of USDWs. Over time the Railroad Commission
normalized operating procedures which skirted
federal oversight of this issue, potentially leading to
illegally permitted injection wells and drinking water
sources destroyed.
Railroad Commission UIC Oversight
Responsibilities
The 1974 Safe Drinking Water Act authorized the U.S.
EPA to develop a program to protect USDWs from
the injection of fluids underground. EPA’s Under-
ground Injection Control (UIC) regulations set federal
minimum protections around USDWs. In 1982, Texas
applied for and was granted primary management
and oversight authority over its UIC Class II program.
In practice this meant that Texas gained the author-
ity to regulate oil and gas injection activity with the
understanding that its state regulations demon-
strated an “effective” program for protecting USDWs
from contamination.2 At the time of this primacy
agreement in 1982, EPA and the Railroad Commission
agreed that all currently producing oil fields would
be given blanket aquifer exemptions. Also, primacy
agreement correspondence stated, “Aquifer exemp-
tions would not be granted without EPA concur-
rence.”3 This requirement that EPA grant aquifer
exemptions is consistent with federal regulations.4
Figure 1. Letter from
Railroad Commission
to Clean Water Action,
June 23, 2016
3. 3TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
Correspondence between Railroad Commission
and U.S. EPA confirmed that the Railroad Commis-
sion agreed to provide maps of producing oil fields
that were exempt. It also
showed the Commission
did not have a complete
understanding of whether
these fields contained
USDWs, nor was it con-
cerned with determining
this information for EPA.
[See Figure 2.]
It remains unclear
whether EPA Region 6 or the Railroad Commission
has a list of oil fields that were considered exempt.
Clean Water Action asked for this information to be
made public over the past year with no results.5
The lack of an original list of aquifer exemptions
is problematic for two reasons. First, without the
necessary list from 1982 there is no way to decipher
which wells were permitted to inject into exempted
aquifers. Second, there is no way to prove that sub-
sequent injection wells
were permitted outside the
boundaries of the original
oil fields did not need an
aquifer exemption.
The terms outlined in
an EPA letter to the Rail-
road Commission [See
Figure 3.] which finalized
Texas aquifer exemptions
as of 1982 and approved a
process for future exemp-
tions presents serious
concerns. The Railroad
Commission has never released an original map and
a list of producing zones that were exempt. Addition-
ally, the Railroad Commission has never submitted
any expansion notices for
these producing zones that
might require an extension
of an aquifer exemption to
EPA. [See Figure 3.] This is
because the Railroad Com-
mission did not subject any
subsequent injection wells
to the full federal criteria
for protecting USDWs. As
a result, there is no way to know if the original fields
expanded into areas which contained sources of
drinking water which could have been used in the
future. Instead oil fields were expanded from their
original boundaries without required scrutiny and
injection activity was permitted regardless of water
quality.
Lastly, the terms concluded that the Railroad
Commission would submit aquifer exemptions for
new producing fields
(those discovered after
1982), or for non-producing
zones (used primarily for
wastewater disposal) to
EPA for final approval. The
Railroad Commission did
not follow this agreement.
These actions have
misled the public and dem-
onstrated a disregard for
the federal requirements
granted under the SDWA.
In2014,itwasrevealedthatsimilarconfusion
over the original list of exempted aquifers
in 1983, combined with inadequacies in its
UIC permit review process led California’s
DivisionofOil,GasandGeothermalResources
(DOGGR) to improperly permit thousands of
wellstoillegallyinjectintopotentialsources
of drinking water. DOGGR has since begun
tooverhaulitsUICclassIIprogram,shutting
dozensofwellsandinitiatingrulemakingsto
ensure protection of USDWs.
Figure 2. Railroad
Commission to EPA
Region 6, March 21, 1982
It remains unclear whether EPA Region 6
or the Railroad Commission has a list of
oil fields that were considered exempt.
Clean Water Action asked for this
information to be made public over the
past year with no results.
4. 4TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
Further, the Railroad Commission agreed that
conditions where injection into USDWs could hap-
pen were common. It was even noted in the Program
Description document as a reason for oversight. [See
Figure 4.]
Railroad Commission Confirms
Lapses in Oversight that Puts
Drinking Water at Risk
EPA acknowledges the clear issues with state over-
sight and is taking steps to develop a comprehensive
inventory of aquifer exemptions nationwide and to
develop a “consistent and predictable process for the
review of Aquifer Exemptions requests.”6 Through
this process and due to sustained public interest,
the Railroad Commission admitted to inconsistent
oversight of exemptions and outlined resource capa-
bility issues. These failures prevented the Railroad
Commission from adequately assessing the number
of wells that may have been illegally injecting into
potential sources of drinking water.
In March 2016, the Railroad Commission provided
proof of at least two injection wells permitted into
USDWs without an aquifer exemption and admitted
there were more wells in a “handful” oil fields where
the water is deemed of drinking water quality (under
10,000 mg/l Total Dissolved Solids).7
Additionally, EPA stated that the Railroad Com-
mission said it would be an “administrative burden”
to identify all wells potentially permitted without
the required aquifer exemption.8 In its End the Year
Figure 3. Letter from EPA
to Railroad Commission
March 29, 1982
Figure 4. Texas UIC Primacy
Application Program
Description
5. 5TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
Evaluation of the Texas Class II UIC program, EPA on
August 15 2016 noted that the Railroad Commission
has said it is “moving forward with identifying and
delineating historical and current aquifer exemp-
tion areas which are considered exempt from full UIC
regulation,” it has still not delivered this information
necessary to determine whether its UIC program is
adequate to protect USDWs. EPA recommends “con-
tinued high prioritization of this effort”.9
As a result, Clean Water Action is skeptical of the
Railroad Commission’s view that its program is effec-
tive in protecting USDWs. Given that the Commission
has not done the work to publicly identify all wells
that are injecting into potential sources of drink-
ing water, we disagree that the wells provided as an
example of “little to no risk” to USDWs, present an
accurate picture of the Railroad Commission’s 54,811
injection well inventory.
There is a gap in understanding around whether
or not the Railroad Commission has permitted oil and
gas wastewater disposal wells to inject into USDW’s.
Clean Water Action acquired a database of Texas
injection wells, which includes over 13,000 disposal
wells injecting into non-productive zones (including
both active and plugged).10 The files for these wells
do not include accessible and specific water quality
information of the injection zone. Salinity informa-
tion would be necessary to determine whether
injection is occurring into a USDW. Importantly, these
areas were not given blanket aquifer exemptions in
1982 because they are not injecting into producing
zones. The Railroad Commission has not addressed
whether or not disposal wells have injected into
USDWs.
There are alarming similarities between the
documented failures of California’s UIC program and
the Railroad Commission’s view of federal standards
meant to protect drinking water.
The sheer number of injection wells permitted
since Texas took over control of its program sug-
gests there was a streamlined approach to permit-
ting injection wells that failed to adequately protect
USDWs. We are just beginning to determine the cost.
Texas Water Issues
Failure of the Railroad Commission to implement a
program that is protective of USDWs is all the more
alarming given that Texas faces serious water chal-
lenges due to continued population growth, fre-
quent drought, and the impacts of climate change.
Clean Water Action is skeptical of the Railroad
Commission’s view that its program is
effective in protecting USDWs.
There is a gap in understanding around how
the Railroad Commission handled injection
into USDWs when it permitted oil and gas
wastewater disposal wells.
6. 6TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
Railroad Commission Must Reform UIC Oversight to Protect Drinking Water
Clean Water Action contends that the protection of potential drinking water supplies in Texas, especially those
in drought prone areas, must be paramount. The Railroad Commission needs a dramatic overhaul of aquifer
exemption oversight in its UIC program:
• Complete an inventory of all injection wells, including disposal wells into non-productive
zones, to determine water quality information for the injection zone and to determine whether
or not injection has occurred into USDWs.
• Provide the necessary documentation for all injection wells that operated in <10,000 mg/l TDS
groundwater, and develop a database with all the necessary water quality, location, regulatory
criteria and Statement of Basis information for associated aquifer exemptions.
• Immediately halt injection activities that are occurring in USDWs, until all necessary aquifer
exemptions are granted by EPA.
• Require water quality information of the injection zone and demonstration of zonal isolation
from USDWs in all future UIC permit applications prior to project and well approvals.
• Provide a clear process for all future injection well permit applications to ensure that injection
into USDWs does not occur.
Localities across the state are re-evaluating aquifers
once thought too brackish for human consumption.
The state legislature has encouraged this.
For example, House Bill 30 “related to the devel-
opment of seawater and brackish groundwater,”
passed by the legislature in 2015, states in part that,
“For many years this (brackish) water was considered
largely useless for most purposes, but advances in
technology and pressures on other supplies have
revealed that brackish groundwater is in fact a
vital resource. In addition to providing potentially
vast new supplies, the development of brackish
groundwater can reduce pressures on the use of fresh
groundwater.”11
Acting at the direction of the Texas Legislature, the
Texas Water Development Board is compiling maps
and characteristics of brackish groundwater in its
Brackish Resources Aquifer Characterization System
(BRACS) helping communities assess the viability of
their brackish groundwater supplies. The BRACS proj-
ect is due to be completed in 2022. Texas currently
has 34 municipal groundwater desalination plants.
7. 7TEXAS AQUIFER EXEMPTIONS: Ignoring Federal Law to Fast Track Oil & Gas Drilling
• Develop a process for submitting aquifer exemption applications to EPA that includes public
notice and a public hearing and opportunities for public comment.
• Map all current, past and future oil and gas production fields and wastewater disposal fields to
determine if these areas contain USDWs.
• Until these protections are put in place, there should be statewide moratorium on approving
any injection well that meets the criteria for an aquifer exemption.
• Undertake a comprehensive review of UIC regulations to ensure protections of USDWs and
other future potential drinking water supplies.
EPA should consider what the breakdown in oversight of Texas aquifer exemptions means for the broader
national program and take additional steps:
• Complete the national aquifer exemption database and develop a way to update it consistently
to provide EPA headquarters and regions with sufficient information on aquifer exemptions to
oversee state and EPA-managed programs.
• Conduct annual on-site UIC program evaluations.
• Conduct a comprehensive workforce analysis to identify the resources and staff necessary
to oversee state and EPA-managed programs and effectively protect underground sources of
drinking water.
• Conduct a third-party review and evaluation of Railroad Commission of Texas’ Class II
Underground Injection Control program for full compliance with the program description and
memorandum of agreement submitted in association with the State of Texas application for
primacy that was approved in 1982.
• EPA should expedite the oversight activities identified by the Government Accountability Office
in its 2016 report:12
ÒÒ Complete the national aquifer exemption database and develop a way to update it
consistently to provide EPA headquarters and regions with sufficient information on
aquifer exemptions to oversee state and EPA-managed programs.
ÒÒ Conduct annual on-site UIC program evaluations
ÒÒ Conduct a comprehensive workforce analysis to identify the resources and staff
necessary to oversee state and EPA-managed programs and effectively protect
underground sources of drinking water.
8. NOTES
1 Fiscal Year 2015 EPA Region 6 End-of-Year Evaluation Railroad Commission of Texas Underground Injection Control Program.
2 Safe Drinking Water Act Section 1425.
3 The Railroad Commission to EPA March 10 1982.
4 40 CFR 146.4. 40 CFR 144.7. Grevatt, Peter. Enhancing Coordination and Communication with States on Review and Approval of Aquifer Exemption
Under SDWA. U.S. Environmental Protection Agency. Office of Ground Water Drinking Water. July 24, 2014. “EPA is responsible for final review and
approval of all aquifer exemption request, based on the regulatory criteria in 40 CFR 14.6.4.”
5 Foster, David. “FOIA Request for Records Relating to the Texas Railroad Commissions Class II Underground Injection Control (UIC) program,
specifically as it relates to aquifer exemptions.” December 9, 2015. Additional requests were made through correspondence with Leslie Savage,
Assistant Director for Technical Permitting, Railroad Commission of Texas.
6 Grevatt, Peter. Enhancing Coordination and Communication with States on Review and Approval of Aquifer Exemption Under SDWA. U.S.
Environmental Protection Agency. Office of Ground Water Drinking Water. July 24, 2014.
7 The Railroad Commission to Region 6 EPA March 28, 2016.
8 EPA to the Railroad Commission June 1, 2015.
9 Fiscal Year 2015 EPA Region 6 End-of-Year Evaluation Railroad Commission of Texas Underground Injection Control Program.
10 The Railroad Commission website notes there are 8,100 active disposal wells, most of which inject into non-productive zones.
http://www.rrc.state.tx.us/about-us/resource-center/faqs/oil-gas-faqs/faq-injection-and-disposal-wells/
11 H.B. No 30. http://www.capitol.state.tx.us/tlodocs/84R/billtext/pdf/HB00030F.pdf#navpanes=0
12 Government Accountability Office. EPA Needs to Collect Information and Consistently Conduct Activities to Protect Underground Sources of
Drinking Water. February 2016.
600 W. 28th Street, Suite 202, Austin, TX 78705 | Phone 512.474.2046 | www.CleanWaterAction.org/tx
A Report by Clean Water Action and Clean Water Fund • August 2016
Acknowledgements
This report was written by John Noël, Clean Water Action/Clean Water Fund.
David Foster and Andrew Grinberg, Clean Water Action/Clean Water Fund,
provided substantial contributions in developing the report.