American Oil and Gas Reporter - November 2015 - 132

States Oppose Federal Seismic Control
OKLAHOMA CITY-A multistate
guide written to help regulatory agencies
evaluate and develop strategies to handle
seismic events that some people have
linked to injection wells is a positive
step because it brings more science into
the debate, asserts an Oklahoma Independent Petroleum Association officer.
Kim Hatfield, chairman of OIPA's
induced seismic work group, says the
primer, written by the StateFirst coalition,
calls for a government response on the
state, not federal, level.
"Earthquakes are an emotional issue,
but emotion is not helpful in addressing
and solving the problems," says Hatfield,
president of Crawley Petroleum in Oklahoma City. "Geology matters. Geology
is local, and the things that are issues in
Oklahoma are completely different from
the situation in Ohio. This is not a onesize-fits-all issue."
Thirteen states partnered through the
StatesFirst initiative, which was organized
by the Ground Water Protection Council
and Interstate Oil & Gas Compact Commission, to produce the primer on the
underground injection control (UIC) program, Potential Injection-Induced Seismicity Associated with Oil and Gas Development: A Primer on Technical and
Regulatory Considerations Informing Risk
Management and Mitigation.
Edward Cross, president of the Kansas
Independent Oil & Gas Association, says
a significant amount of public attention
remains focused on Class II injection
wells. "Given the long history of successful
UIC operations across the nation, the
likelihood that induced seismic events
will occur in properly permitted and operated UIC wells is very small," Cross
states. "Too often, the mere presence of
nearby oil or gas wells, or UIC wells, results in allegations that they are the source

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of seismic activity."
Those allegations, combined with often
sensational media coverage, highlight the
need for more scientific research, Cross
says, adding the primer seeks to provide
guidance for mitigating the risks of induced
seismicity.
"Seismic activity is going to fluctuate
naturally, and efforts are being made to
ensure the assumptions and results of the
numerous studies and reports on seismic
activity are correct, scientifically based,
and limited in scope to the site-specific
features of the areas in question," Cross
reports. "Producers are best served by
engaging state officials to assure that the
information used in any analysis is scientifically sound. Progress is being made
to better understand these events."
Mitigating Risks
StatesFirst says its Induced Seismicity
by Injection Work Group wrote the primer.
That group is composed of representatives
of state oil and gas regulatory agencies
and geological surveys, who worked with
experts from academia, industry, federal
agencies and environmental organizations,
according to the coalition.
The primer concludes that managing
and mitigating the risks associated with
induced seismicity are best considered at
the state level, with specific considerations
at local or regional levels. In areas where
induced seismic events are thought to
have occurred, StatesFirst says its primer
also identifies the range of multidisciplinary approaches states have used to manage and mitigate risks, discusses scientific
methods for evaluating causes of events,
identifies underground faults of concern,
and distinguishes risks and hazards. It
also outlines how states can best provide
scientific information to the public.
According to StatesFirst, the science
required to understand induced seismicity
and predict its impacts still is undergoing
significant changes, and the primer is
written to provide state regulatory agencies
with current scientific and technical information.
"State regulatory agencies that deal
with potential injection-induced seismicity
should be prepared to use tools, knowledge
and expertise, many of which are offered
in this primer, to prepare for and respond
to potential occurrences of induced seismicity," says Rex Buchanan, interim director
of the Kansas Geological Survey and work
group co-chairman for the initiative.
The primer primarily focuses on potential induced seismicity associated with

132 THE AMERICAN OIL & GAS REPORTER

Class II disposal wells, the group says.
Those wells are regulated under the UIC
program, for which the U.S. Environmental Protection Agency has delegated
enforcement authority to most states. Its
assessment says the majority of U.S. disposal wells do not pose a hazard for induced seismicity. However, the primer
adds that most cases of injection-induced
felt earthquake activity are associated
with direct injections into basement rocks
or into overlying formations with permeable avenues of communication with
basement rocks that are close to faults of
concern.
The primer points out the most common
data available for Class II disposal wells
are injection rates and volumes, and injection-well tubing pressures. The data
are reported routinely under both direct
EPA regulation and state UIC program
requirements. The frequency for reporting
injection volumes and pressures varies
among regulatory agencies, and depends
on site circumstances, it notes. Bottomhole pressures, which are more suitable
for evaluating reservoir conditions, are
not as readily available, the primer notes.
The frequency of recording and reporting surface pressure, and injection
rate and volume data varies according to
regulatory agency requirements. The
primer adds improvements in data availability have progressed under state initiatives, such as the Oklahoma Corporation
Commission rule authorizing requests for
daily Arbuckle formation disposal well
pressure and volumes.
Cooperation
Oklahoma regulators, not OIPA, were
directly involved in the StatesFirst primer,
Hatfield reports, adding the association
helped with developing the guide and continues to contribute to mitigating impacts
from induced seismicity. Analysis of seismic events from the Rocky Mountains
Arsenal incident in the 1960s supported
theories that fluid injections into basement
rock could be related to earthquake activity,
he recalls. OIPA members stepped forward
by contributing information on Oklahoma
conditions, Hatfield says.
"OCC needed a map of these basement
faults to help in its regulation of wells.
OIPA knew that preferentially oriented
faults in the basement could be a problem,"
Hatfield says. "OCC turned to the Oklahoma Geologic Survey, the constitutionally
mandated organization that shepherds all
the state's natural resources and also
maintains the state seismic array. OGS

American Oil and Gas Reporter - November 2015

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