--> The Challenges Of Developing And Implementing A Groundwater Monitoring Plan To Comply With SB-4 Requirements

Pacific Section AAPG Convention

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The Challenges Of Developing And Implementing A Groundwater Monitoring Plan To Comply With SB-4 Requirements


SB4 interim regulations requiring a well-specific or area-specific Groundwater Monitoring Plan (GMP) for all well stimulation treatments (hydraulic fracturing and acid stimulations) that penetrate an USDW are being implemented by DOGGR until July 2015 when the State Water Resources Control Board (SWRCB) will become the lead agency for SB4 GMPs. Emergency regulations were introduced in January 2014, and then readopted in July 2014; final regulations from DOGGR will be implemented in July 2015 but will not include GMPs. The regulations regarding GMPs will become the responsibility of the SWRCB in July 2015; the upcoming changes are unknown to those trying to meet the regulatory requirements. Complying with the regulatory requirements has been a challenge for oil companies and regulators alike. Developing a hydrogeologic model is difficult when data on water wells, including their location, completion details, and groundwater analytical results are not public information. Calculations from electric logs to determine the base of the USDW, water with a Total Dissolved Solids concentration of less than 10,000 ppm, is of questionable accuracy. Scanned formation water analytical data available on the DOGGR web site is often of questionable quality and it is difficult to determine where and how the water samples were collected. Drilling and constructing a deep groundwater monitoring well with an oil drilling rig is fast and efficient but difficult when the companies do not have the required C-57 licensed contractor on staff. Determining the interval to perforate above the depth of protected water requires log interpretation, again with an uncertain margin of error. Collecting groundwater samples from deep monitoring wells is new to the groundwater sampling technicians. We have successfully used HydraSleeves, but not without breaking some of them in the process. Analytical laboratories need approximately 3.5 gallons of groundwater to run the required tests. Most laboratories cannot perform the radionuclide analysis. Discussions with the laboratory are important to ensure that the radionuclide results will be expressed in the required units, piC/L. Finding and meeting with neighboring water well owners to request permission to sample their water wells adds an important public relations aspect to the challenge.