California Strategy Addresses EPA Concerns About Injection Wells, Protection of Aquifers

By Carolyn Whetzel

Feb. 10 — California has proposed a strategy to respond to Environmental Protection Agency concerns about the state's Class II underground injection well program and to bring the program into compliance with the Safe Drinking Water Act.

Correcting deficiencies in the program is a priority, Steven Bohlen, supervisor of the California Department of Conservation's Division of Oil, Gas and Geothermal Resources, said during a Feb. 9 conference call with reporters.

Bohlen said the plan forwarded to the EPA Feb. 6 is the culmination of an ongoing review of the Class II underground injection well program by state and federal officials to address concerns raised by a 2011 federal audit and report.

California won approval from the EPA in 1983 to supervise the regulation of Class II injection wells associated with oil and gas operations. Class II wells are injected with the fluids to stimulate production and to dispose of fluid by-products from drilling. Some Class II wells also can be used to store hydrocarbons.

A key focus of the plan is the state's proposed strategy to address permits the Division of Oil, Gas and Geothermal Resources (DOGGR) has issued for injection wells in hydrocarbon-bearing zones with aquifers without first obtaining the necessary exemptions required under the Safe Drinking Water Act.

The letter to the EPA follows a recent analysis of the DOGGR's records by the Associated Press indicating the state has recently issued permits allowing oil companies to inject production fluids or wastes into 2,553 federally protected aquifers.

140 Wells for Immediate Review 

Of the 2,553 recently permitted wells, the state has identified 140 active wells for immediate review by the State Water Resources Control Board to determine if they pose a potential risk to groundwater supplies, Bohlen said.

Those 140 wells have been identified as lacking hydrocarbons and contain water with less than 3,000 micrograms per liter of total dissolved solids, he said.

Last summer, the state closed down 11 injection wells it found posed a threat to drinking water supplies, Bohlen said.

“Our primary goal has always been to ensure the protection of public health and safety and the environment, and we believe that overall, we have been successful,” Bohlen said. Still, he said there are problems with the program.

The injection wells are an integral part of California's oil and gas operations, Bohlen said. Currently, there are more than 50,000 oil field injection wells operating in the state and 75 percent of those are used for enhanced oil recovery activities such as steam flood, cyclic steam, water flood and natural gas injection, he said.

Proposed Actions 

In the letter and plan submitted to the EPA, the state proposed two workshops, one later in February and another in March, to inform the oil and gas industry, environmental groups and others of what data are needed to justify an aquifer exemption. A related guidance document is due out April 1, the state said in the letter.

Also, California has proposed a series of administrative and rulemakings to eliminate the injection wells in the “undisputedly non-exempt aquifers.”

Jointly drafted by the DOGGR and State Water Resources Control Board, the letter also outlines recent steps taken to address deficiencies in California's program included in the EPA audit, such as the hiring of additional staff, establishing a new monitoring and compliance unit and allocation of increased financial resources.

Finally, the state committed to conduct, over the next three years, a thorough review of the underground injection control program and related regulations and to develop any needed new regulations.

To contact the reporter on this story: Carolyn Whetzel in Los Angeles at

To contact the editor responsible for this story: Larry Pearl at