Spring 2017

Underground News

Providing Information to the Water Well, Underground Injection Control (UIC) & Underground Hydrocarbon Storage (UHS) Industries in Kansas and other Partners Interested in these Operations,

the Environment, Water Resources and Energy

Inside this Issue

GWTS Fall 2017 Seminar/Tech Fair

1

GWTS Staff Changes

2

UHS—Brine Pond Inspec-tions and Brine

3

CLV Remedia-tion Wells

4-5

Timeline for Water Well Contractor Re-newals

6

Procedure for Renewing Wa-ter Well Con-tractor License

7

Class II Well conversion to a Class I Well?

8

NEW WWC5 & WWC-5P

9

Upcoming CEU Opportunities

10

Office Holiday Closings

11

Web News 11

Did You Know 11

KDHE Staff 12

NEW EMPLOYEE—LOGAN WALKER

I am Logan Walker the new contract geologist with the KDHE Bureau of Water in the Geology and Well Technology Section. I will be helping out both the UIC (Brandy DeAmond) and Underground Hydrocarbon Storage (UHS – Jessica Crossman) Programs. I have a B.S and M.S in geology From Wichita State University. Prior to being contracted with KDHE-BOW, I worked as a staff geologist for an environmental consulting company. Then I went to the oil patch to work as an independent wellsite geologist in Oklahoma, Kansas, and Nebraska

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Geology & Well Technology Staff 2017

by Deb Biester

Page 3 Underground News

by Jessica Crossman, PG

UHS staff have been evaluating the existing program activities for practicality and efficiency over the last couple of years. Through this evaluation, it became apparent that some updating was needed in certain areas. It was decided that UHS staff will not physically inspect the brine ponds anymore, but will instead, witness one of the semi-annual brine pond inspections that facility personnel conduct each year, to ensure that the inspections are being done correctly. UHS staff also determined that a number of the brine spills that are being reported appear to be of de minimus volume and possibly do not require a formal written report. Another item of concern related to brine spills is inconsistency in the reports from one facility to another, as well as inconsistency on the KDHE end as to what qualifies for closure or conditional closure. The final issue on brine spills is the need to improve communication between UHS staff handling brine spills and KDHE’s Bureau of Environmental Remediation staff if a spill cannot be fully remediated. To communicate these changes to industry, UHS staff held a training session at the Williams offices at Conway on April 4, 2017. Approximately 30 facility personnel from all four Kansas UHS companies were in attendance. After a brief background on both brine ponds and brine spills, UHS staff presented on brine pond inspection changes, covering exactly how the inspections are expected to be conducted and what is expected in the semi-annual reports. It was emphasized that these should be close inspections of the berm and pond liner. Many examples of common defects were shown to demonstrate the type of problems that can be encountered. It was also stated that UHS staff should be notified at least two weeks prior to a facility conducting a brine pond inspection, to allow enough time for staff to schedule to be present to witness the inspection. For the brine spills reporting portion of the training, Joe Dom with the KDHE-Bureau of Environmental Remediation (BER), Spills Program presented on their role in spill reporting, the regulations behind it, and then talked about the new WebEOC database that is used to track spills. Following Joe, UHS staff covered in detail, what needs to be included in a closure request report for brine spills. This included a discussion of the expected content of each section of the report. The main changes expected in the reports include: the addition of a second map, showing where the spill was located at the facility; incorporating photographs of the spill at all phases (initial, cleanup actions, and restored spill site), and detailed justification for requesting conditional or full closure. The other big change to brine spills is happening with closures on the UHS program end. Spills that cannot be cleaned up below 1,000 mg/kg of chloride in the soil, that are located in areas that are not covered under an existing KDHE-BER order or agreement for remediation, will be referred to BER for evaluation. Following the UHS Program presentation on brine spill reporting and closures, Scott Nightingale with KDHE-BER spoke about where the 1,000 mg/kg value for chloride concentration in soil came from and explained that it may be possible for operators to calculate an alternate cleanup level with site specific information. This could allow for slightly higher cleanup levels for some brine spills at certain locations.

UHS Program Presents Brine Pond Inspection and Brine

Page 4 Underground News

Class V Remediation Injection Wells – Do You Need to Submit an Inventory Report,

Authorization Application, or Permit Application?

by Brandy DeArmond, PG

The answer is most likely an Authorization Application, but first I’ll tell you about an adventure I once had involving Class V Remediation Injection Wells. Thirteen years ago, I was an entry-level consultant in Florida, and my coworker and I were performing a series of molasses injections in the middle of a busy railyard, which involved making the molasses and water mixture on-site. One day, my coworker was mixing a batch of the concoction while I was checking pressure gauges on nearby injection wells, and the hose connected to the molasses portion of the mixture suddenly got away from him. Of course, I happened to be directly in the line of fire, and ended up looking like a character from an “I Love Lucy” episode, soaked from head to toe in the sticky substance. I even had molasses up inside my hard hat. It’s a wonder I will go near the stuff today. That anecdote may help you to remember that Remediation Injection Wells are a type of Class V injection well that usually only require an Authorization; in fact, very few types of Class V wells require a Permit in the State of Kansas. In general, Class V Injection Wells are shallow Injection Wells that inject fluids either into or above an underground source of drinking water (USDW). This is the most diverse Class of injection wells regulated by the KDHE Bureau of Water (BOW), and can be wide-ranging in scope and technology, from an open-loop geothermal heat pump return well to an Aquifer Storage and Recovery (ASR) project comprised of a complex system of wells. Along with their diverse nature, the regulatory requirements for the different types of Class V wells also vary significantly. For instance, an open-loop geothermal heat pump return well only requires completion of a simple Inventory Report, while a Permit Application is required for a complex ASR project. The majority of the Class V Injection Wells in the State of Kansas are aquifer remediation injection wells or temporary direct push points used to facilitate clean up, treatment, or prevention of contamination of a USDW by injecting remedial fluids into the subsurface. Some of the types of remedial technologies used to treat subsurface soil or groundwater contaminants in situ through these wells or points are air sparging, aerobic and anaerobic biodegradation, enhanced reductive dechlorination, and chemical oxidation. Examples of fluids injected are ambient air, pure oxygen, emulsified vegetable oil (EVO), molasses, potassium permanganate, and bioaugmentation bacteria. Target contaminants range from petroleum constituents and dry cleaning fluids to agricultural chemicals, or a combination thereof that have impacted or have the potential to impact soil or groundwater. Although the KDHE’s Bureau of Environmental Remediation (BER) is typically the regulatory authority for cleaning up contaminated sites in Kansas, the use of Class V Remediation Injection Wells must still be approved and inventoried by the BOW UIC Program through an Authorization.

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The term “Authorization” is short for “Authorization by Rule”, which allows an injection well to be operated without a Permit as long as the owners or operators: Submit inventory information to the KDHE UIC Program to verify that they are allowed to inject. This allows KDHE UIC personnel to ensure the well or point will not endanger a USDW; Operate the wells in a way that does not endanger USDWs; and Properly plug and abandon their Class V well when it is no longer being used, thereby preventing movement of any contaminated fluids into USDWs. After reviewing an owner or operator's Authorization Application, KDHE UIC staff may determine that a Permit is necessary to prevent USDW contamination. KDHE UIC Permits require a 30-day Public Notice Period, allowing the public to voice any concerns prior to the approval of the Permit. The various types of applications for UIC Class V wells as well as Inventory Report Forms, are available on the KDHE UIC webpage at: http://www.kdheks.gov/uic/Class_5.htm. Hopefully this clears up any confusion you may have regarding which application to choose for your Class V remediation wells, but if you still have questions, please contact me at 785-296-5554, or brandy.dearmond@ks.gov and I will be happy to provide additional guidance. Just remember, if you are injecting molasses, you most likely only need to provide an Authorization Application.

Class V Remediation Injection Wells – Do You Need to Submit an Inventory

Report, Authorization Application, or Permit Application?

by Brandy DeArmond, PG—(Continued)

Page 5 Underground News

Tulip time at Mike

Cochran’s home

Deb Biester working on a park like sitting area

GWTS Staff have outside

hobbies . . .

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TIMELINE TIGHTENS FOR THE KANSAS WATER WELL CONTRACTORS RENEWAL PERIOD 2017-2018

by Deb Biester

Kansas water well contractors renewing their water well licenses for the renewal period July 1, 2017 through June 30, 2018, will be facing stricter deadlines due to lack of resources and to ensure uniform application of the requirements for all contractors. In past renewal periods, approximately three-quarters of the water well contractors have had their renewal contractor and rig apps, along with associated fees and their Continuing Education Credits completed and turned in to KDHE before the expiration date of their license, which is June 30 each year. The remaining one fourth of the contractors do not meet this deadline.

Important deadlines for the 2017-2018 renewal period are:

May 15, 2017 Water Well Renewal Letters, Contractor Renewal Applications,

and Rig Applications will be mailed out to contractors

June 12-23 Kansas Ground Water Association (KGWA) will mail to KDHE

Completion Forms of those contractors who have completed their

Continuing Education Units

June 30, 2017 Kansas Water Well Contractor License and Drilling Rig Licenses

Expire

All contractors need to have their applications and fees into KDHE by July 1, 2017. If these

requirements are not met, the license can be revoked under K.S.A. 82a-1209. Valid, emer-

gency type situations will be considered.

July 1-31, 2017 KDHE will process renewals as quickly as possible.

If you have completed your CEUs, paid for them and submitted your applications and fees to

KDHE, you will be allowed to continue working as usual while your licenses are being pro-

cessed. Upon receiving your fees, KDHE is required to deposit them within a few days. We

will not be able to hold on to your fees (in the event we are waiting on paperwork or CEUs

etc) and the fees are not reimbursable.

August 1, 2017 KDHE will start Revocation Letters which will be mailed out in August, 2017. Please see Page 11 of this newsletter for a newly developed Procedure WWP-12, PROCE-

DURE FOR RENEWING A KANSAS WATER WELL CONTRACTOR LICENSE .

Page 7 Page 7 Underground News Page 7

Reply to: (785) 296-5524

Bureau of Water

Geology & Well Technology Section

1000 S. W. Jackson, Ste. 420

Topeka, KS 66612-1367

PROCEDURE FOR RENEWING A KANSAS

WATER WELL CONTRACTOR LICENSE Procedure #: WWP-12 (10/16)

Narrative: The purpose of this procedure document is to outline the process for renewing your Water Well Contractor’s License issued by the Kansas Department of Health and Environment. Pursuant to Kansas Statutes K.S.A. 82a-1209, after becoming a Licensed Water Well Contractor, the contractor may renew their license annually if they wish to continue drilling water wells. The term of all licenses issued under the provisions of this act shall be July 1 of each year through the following June 30. If one has access to the internet, it is recommended that one first go to the Kansas Department of Health and Environment Geology & Well Technology Section website at http://www.kdheks.gov/geo to learn more about the Geology & Well Technology Section in which the Water Well Program is located. Then, it is recommended that one go to the Water Well Program website at http://kdheks.gov/waterwell/index.html to become familiar with the information available concerning the KDHE Water Well Program. Procedure: 1. KDHE, Bureau of Water, GWTS will mail hard copies of the Water Well Contractor Renewal Letter, Renewal Application for Kansas Water Well Contractor License (WWC-1R) and Application for Kansas Water Well Contractor Drilling Rig Licenses (WWC-3) approximately May 15 or whichever date the first Monday falls on after May 15. 2. Pursuant to K.S.A. 28-30-3(c), each water well contractor or the contractor’s designated person shall earn at least eight units of continuing education approved by the Kansas Ground Water Association who administers this program for the KDHE Secretary. You will find information at their website listed below. Please register and pay for your CEU’s at the following address: Continuing Education Committee Phone: 620.548.2669 Attn: Dale Hayse E-mail: Haysemgt@Havilandtelco.com c/o KGWA, P.O. Box 107 Website: http://kgwa.org/ Mullinville, KS 67109-0107 3. Prior to July 1, please send the items mentioned above in #1 (sent to you by KDHE in May) along with $100.00 fee for contractor license and $25.00 fee for each rig you register. Please fill out the renewal application and rig application completely, show the number and what type of wells you constructed, reconstructed and plugged, list your drillers and make sure you sign your app and check. Incomplete forms and/or no signatures will delay processing your license(s). Mail applications and fees to: Kansas Department of Health & Environment Phone: 785-296-5524 Attn: Deb Biester E-mail: Debra.Biester@ks.gov 1000 SW Jackson Street, Suite 420 Website: http://kdheks.gov/geo Topeka, KS 66612-1367 4. Pursuant to K.S.A. 82a-1206(d), if you are registering as a “Corporation”, you must register with the Secretary of State and be in “Good Standing” with their office before KDHE can issue a license. http://www.kssos.org/business/business.html Once the above items have been completed and approved, KDHE will issue the contractor and drilling rig licenses. The license number is to be displayed on each drilling rig. If these requirements are not met by July 1, the license shall be revoked under K.S.A. 82a-1209. db R/Geology/Procedure WWP-12

10-21-2016

Underground News

Can I convert a Class II injection well to a Class I injection?

By Mike Cochran, PG

The straightforward answer is - no.

There are a number of reasons for this. But first, let’s clarify what these injection wells are. The U.S. Environmental Protection Agency (EPA) established the Underground Injection Control (UIC) Program back in the late 1970’s when several incidents in different parts of the nation made it obvious that these wells can pose a threat to the public health and environment unless operated under strict controls. The EPA has authorized the Kansas Department of Health and Environment to regulate Class I injection wells and has similarly authorized the Kansas Corporation Commission to regulate Class II injection wells.

A Class I injection well is used to inject industrial wastewaters into deep formations for the purpose of disposal. There are two types of Class II injection wells. These are enhanced oil recovery injection wells which are used to inject fluids to enhance the production of oil/gas resources and the disposal wells which are used to dispose of brine brought to the surface during the production of oil/gas.

The parts of the UIC Program that establish regulations for these two classes of injection wells are two separate, distinct programs that are administered by two separate state agencies. The Class I and Class II injection wells each have their own set of specific regulations. Both programs are protective of the public health, safety, property and environment; but due to the industrial nature of the wastewater injected into the Class I wells, EPA believes these wells need additional scrutiny. Class I wells are therefore required to meet significantly more stringent requirements than the Class II injection wells. The Safe Drinking Water Act also states in part that regulations for state underground injection control programs may not prescribe requirements unless such requirements are essential to assure that underground sources of drinking water will not be endangered by such injection.

As a result, there are a number of additional requirements for Class I wells. These requirements cannot be met if the well has already been installed and operated as a Class II injection well. These include, but by no means are limited to the following requirements: the longstring must be cemented from bottom to the surface, a number of openhole logs that must be conducted, such as fracture finder logs of the confining and injection zones; a core of the confining and injection zones must be obtained and tests conducted on these; and injection must take place through injection tubing set on a packer just above the injection zone and a pressurized annulus maintained and monitored;.

In addition, there is the requirement of KDHE regulation K.A.R. 28-46-25 – Prohibition of Unauthorized Injection - which states in part: Class I injection wells shall not be constructed and underground injection shall not take place unless authorized by a permit issued by KDHE.

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ATTENTION WATER WELL CONTRACTORS

and Individuals who submit WWC-5 or WWC-5P Forms

by Deb Biester, Public Service Administrator

KDHE will no longer be providing printed hard copies of the WWC-5 and WWC-5P forms. You will be able to submit these forms by using:

1. KOLAR (Kansas On-Line Automated Reporting) system (if you are a licensed Kansas Water Well Contractor), or 2. By filling out the .pdf fillable forms on our Web site and mailing to KDHE.

Both can be found at: http://www.kdheks.gov/waterwell/index.html

NOTE: PLEASE RECYCLE ALL FORMS YOU MAY HAVE IN YOUR OFFICE OR HOUSE. THE PREVIOUS FORMS DO NOT CONTAIN ALL OF THE INFORMATION NEEDED FOR THE KANSAS GEOLOGICAL SURVEY DATABASE. NEW FORMS ARE

ON OUR WEB SITE LISTED ABOVE. If you do not have a computer, please call us at 785-296-5524 and request a copy of the form(s) and we will print off and mail to you. You may reproduce these forms for

future submittals. Please submit WWC-5 or WWC-5P forms as follows:

1. One white original to KDHE at:

KDHE, GWTS 1000 SW. JACKSON STREET, STE. 420 TOPEKA, KS 66612-1367

2. One copy to water well owner 3. One copy for your files There is a $5.00 fee for each water well constructed and your check should accompany the WWC-5 form(s) when submitted. There is no fee for re-constructed wells and plugged wells.

If you have questions, please call Deb at (785) 296-5524.

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KDHE/Bureau of Water/Geology & Well Technology Section Water Well Program

Upcoming Opportunities for CEUs

By Pam Chaffee, PG

There are a number of upcoming opportunities for Kansas Water Well Contractors to get some last minute training to help meet their eight (8) continuing education units (CEUs) required to renew their license beginning with the first full year of licensure or the renewal period. CEUs must be processed through the Kansas Ground Water Association (KGWA). Information is available on the KGWA website at http://www.kgwa.org/ceu.htm. Contact Dale Hayse, KGWA Executive Director, at Hayse Management Services, P.O. Box 107, Mullinville, KS, 67109, or at 620-548-2669, or at ksgroundwater@gmail.com.

The Private Well Conference will be held 23-25 May 2017 in Champaign, IL. The first of its kind, the conference is both national in scope and exclusively focused on private drinking water supplies. Visit: http://privatewellclass.org/conference?mc_cid=a5d900bd1f&mc_eid=9f001fde8e for more information and the full conference agenda.

For members of the National Groundwater Association, updates on upcoming groundwater events and education are provided frequently by email and are available on their website. For more information, visit http://www.ngwa.org/Pages/default.aspx.

The WorldWide Drilling Resource Magazine is available both by email and in print. Upcoming educational events are provided at e-news@worldwidedrillingresource.com and www.worldwidedrillingresource.info/Planning3-17.pdf.

KDHE Certified Laboratories Listing can be found at the following website:

http://www.kdheks.gov/envlab/disclaimer.html

Pag Page 11

KDHE OFFICE CLOSINGS FOR THE 2017 CALENDAR YEAR

The following changes have recently been made to the Geology and Well

Technology Section Web site:

Geology (http://kdheks/gov/geo) Updated Index Page Updated Organizational Chart Added Seminar Announcement and Forms

UHS (http://kdheks.gov/uhs) Updated Index Page Brine Pond Inspection & Brine Spill Reporting

Training Ten Year Compliance Audit Added Seminar Announcement and Forms

UIC (http://kdheks.gov/uic) Updated Index Page Added Seminar Announcement and Forms

Water Well (http://kdheks.gov/waterwell) Updated Index Page Updated Active KS Water Well Contractor List New WWP-12 Updated WWP-4 Procedure for Requesting In

active Status for Water Wells Updated WWP-9 Procedure for Obtaining a Kan-

sas Water Well Contractor License Updated Standard Monitoring Well Design

Did You Know… ???

U.S. energy-related CO2 emissions fell

1.7% in 2016:

U.S. energy-related carbon dioxide (CO2) emissions in 2016 totaled 5,170 million metric tons (MMmt), 1.7% below their 2015 levels, after dropping 2.7% between 2014 and 2015. These recent decreases are consistent with a decade-long trend, with energy-related CO2 emissions 14% below the 2005 level in 2016. – U.S. En-ergy Information Administration.

Something to think about: We often take the amount of fresh water for granted. As the world’s population in-creases, water consumption increases. Preventing water contamination and con-serving water are important to ensure a continued abundance of water.

Underground News

May 29 - Memorial Day November 10 - Veterans Day

July 4 - Independence Day November 23 - Thanksgiving

September 4 - Labor Day November 24 - Thanksgiving

December 25 - Christmas

1000 SW Jackson St. Suite 420

Topeka, KS 66612

785.296.5524 Office 785.296.5509 Fax

KANSAS

DEPARTMENT OF

HEALTH AND

ENVIRONMENT

Web:

http://kdheks.gov/geo

KDHE STAFF Please note NEW e-mails Mike Cochran, Section Chief, Geologist 785.296.5560 Mike.Cochran@ks.gov Geology & Well Technology Section Debra Biester, Public Service Administrator 785.296.5524 Debra.Biester@ks.gov Pam Chaffee, Unit Chief, Geologist 785.296.3565 Pam.Chaffee@ks.gov Water Well and Technical Support Brandy DeArmond, Unit Chief, Geologist, 785.296.5554 Brandy.DeArmond@ks.gov Underground Injection Control (UIC) Jessica Crossman, Unit Chief, Geologist 785.296.7254 Jessica.Crossman@ks.gov Underground Hydrocarbon Storage (UHS) Doug Doubek, Unit Chief, Geologist 785.296.7265 Doug.Doubek@ks.gov Field Operations, Permitting, and Compliance Logan Walker, Geologist 785.296.1544 Logan.Walker@ks.gov Rachael Berg, Part-Time Administrative Assistant 785.296.8565 Rachael.Berg@ks.gov

Page Underground News

UNDERGROUND NEWS

Kansas Department of Health and Environment

Prepared & Distributed by Bureau of Water - Geology & Well Technology Section

Direct inquiries and opinions to: KDHE - BOW

Underground News 1000 SW Jackson, Suite 420

Topeka, KS 66612-1367