from Bill Gordon.
A lot of folks are asking how our Bluff Dale / EOG Resources went.
Out of the 215 citizens that protested - only 20 to 22 showed up for the hearing. This was a disappointment.
EOG made an excellent presentation that was difficult to challenge - this did not surprise me.
We had two big ticket items that we had previously requested from EOG.
1) Remove "commercial" status of disposal well.
2) Agree to a water quality monitoring program for water wells near the Disposal well.
EOG agreed to amend their W-14 application to a "non-commercial" disposal well. This was our No. one priority and we were pleased with this outcome.
EOG would not agree to a water quality monitoring program. However, it was discussed, most likely for the first time in an RRC hearing. We plan to do our own water quality monitoring on nearby water wells as several citizens live nearby. We will not give up on this as EOG will be back soon for another waste disposal well. They plan to drill 500 wells in Erath County in the next ten years. The Legislators and the RRC should be requiring this - not the citizens.EOG also changed their proposed injection Pressure from 3000 psi to 2000 psi. This is good.
They also changed their sacks of cement for the surface casing from 215 to 325. This is also good since the surface casing is the main protection to the fresh water strata. EOG already uses more cement on their production casing than the RRC requires - this is VERY good. EOG has always planed for 3000 feet of cement above the packer and the upper injection interval - the RRC only requires 100 to 400 feet (depending on method of measurement). Of the 14 SWDW applications I have reviewed in the past 16 months, EOG's cementing plan is one of the best. I have one more company with our only SWDW in Erath County that cements the production casing all the way to the surface. The more cement - the better.
They also increased their production tubing size from 2-3/8" to 3-7/8". This was most likely required to compensate for volume loss due to the decrease in injection pressure.
A major issue remaining that the RRC has no control over (so they say) is traffic safety. We will be watching this issue closely and may have to get TX-Dot involved later. The EOG location is near a blind curve on a FM road with no paved shoulders.
One thing that I did notice since this was my second hearing, is that the RRC Examiners seemed to be a bit more friendly than in the Era, TX hearing that I attended on March 23rd. Era had 171 protesters and I counted 70 attending. I believe the RRC is concerned with the large number of citizens that are getting involved in SWDW issues.
Over all, we spent some money, but we also caused EOG to spend even more, plus we stopped their permit from being rubber stamped by the RRC and this put the "burden of proof" on EOG to prove that their well design would not contaminate the aquifer. The RRC should require all SWDW applicants to do this on all permit applications without the citizens having to protest to get the burden of proof placed where it needs to be.
Most of all, we sent a message that if a SWDW is permitted for Erath County - we want it done right.
It appears to me that the citizens are becoming the Regulation Enforcement Agency rather than the RRC!!!