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Texas Underground Injection Control Permit (14-TX-c)

The Safe Drinking Water Act requires Texas to implement technical criteria and standards to protect underground sources of drinking water from contamination. In Texas, under Tex. Water Code § 27 , the Railroad Commission of Texas (RRC) or the Texas Commission on Environmental Quality (TCEQ) regulate and permit underground injection wells. Under the Memorandum of Understanding between the Railroad Commission of Texas and the Texas Commission on Environmental Quality 16 TAC 3.30, the RRC has jurisdiction to regulate and permit injection wells for industrial geothermal projects. RRC regulations and application procedures vary depending on the class of the injection well. The Environmental Protection Agency (EPA) categorizes injection wells into 6 classes.


Underground Injection Control Permit Process

14-TX-c.1 to 14-TX-c.2 – Class V Injection Wells

If the project uses a Class V geothermal injection well then the developer will need to contact the RRC for application forms and procedures.

14-TX-c.3 to 14-TX-c.5 – Class II Injection Well Applications

The RRC divides class II injection well applications into two categories; injection into productive reservoirs and injection into non-productive reservoirs. Under 16 TAC 3.9, the RRC requires a developer to file Form W-14 for injection into formations that are non-productive of oil, gas , or geothermal resources. Under 46 TAC 3.46, the RRC requires a developer to file Form H-1 and Form H-1A for injection into formations that are productive of oil, gas, or geothermal resources. A reservoir is considered to be in a productive reservoir if there is any current or past production of oil, gas, or geothermal resources within 2 mile radius of the proposed well site. If and part of the proposed injection zone is or ever has been productive, then the developer should file forms H-1 and H-1A.

14-TX-c.6 to 14-TX-c.7 – Application Requirements

RRC underground injection control applications are submitted to technical review and administrative review. Required items for all class II applications include but are not limited to:

  • Documentation verifying that the proposed injection well meets construction and operation standards for groundwater protection and confinement of injected fluids.
  • Documentation verifying that the proposed injection zone is adequately isolated by relatively impermeable strata to confine injected fluids to the proposed zone. Documentation includes a well log to identify the top and bottom of the proposed injection zone and overlying formations.
  • Documentation verifying that all wells within the area of review are adequately plugged to ensure that injected fluids are confined to the proposed injection zone.
  • The appropriate non-refundable fee or fees.
  • Notice to affected parties and the public:
A) Mail or deliver a copy of the application form(s), both front and back, to:
1. The owner "of record" of the surface of the tract on which the well is located. Owner "of record" means the owner that is listed on deed and tax records.
2. Each RRC designated operator of any well within one-half mile of the proposed disposal/injection well (excluding permanently plugged wells).
3. The county clerk for the county where the well is located.
4. The city clerk if the well is located within corporate city limits.
B) Notice of the application must be published by the developer in a newspaper of general circulation in the county where the well is located. The following information must be submitted with the application:
1. Affidavit of publication. The affidavit must be notarized and must state that the newspaper has general circulation in the county where the well is located.
2. A newspaper clipping of the published notice.
  • A Water Letter from the TCEQ or it successor:
For Forms H-1/H-1A, the developer shall use Form TCEQ-0051 stating the depth to which usable quality groundwater must be protected.
For Form W-14, a letter stating that the proposed injection will not endanger usable quality groundwater. The developer may request this letter from the TCEQ by filing two copies of Form W-14, a plat showing the location of the well with surveys marked, and a representative electric log.
  • A map of all wells of public record within a 1/4-mile radius of the proposed injection/disposal well showing the total depth of each well.
  • A Table of wells within the 1/4-mile radius that penetrate the top of the injection/disposal zone. For each well, show the well name and number, date drilled, and current status, including the date plugged if applicable.
  • Note: The injection of fresh water is restricted to cases where there is no technically or economically viable alternative. The developer must verify that all alternatives have been investigated. By statute the RRC is required to forward a copy of an application involving injection of fresh water to the TCEQ for further review. The TCEQ has 30 days to complete its review of fresh water use.

If an application is not complete or deficient the RRC will notify the developer and request additional information. If the RRC has not received the requested information in 30 days it will send the developer a second request. The RRC has 30 days to evaluate the any additional data received.

14-TX-c.8 - Notice of Administrative Completeness or Denial

If the application is complete the RRC will notify the developer of administrative completeness. The RRC has 30 days to complete its initial review. After the initial review the RRC has 15 days to complete a final review and either issue or deny the permit application.

14-TX-c.9 – Public Comments and Protest

Following notice by the developer the public and affected persons have a minimum of fifteen days to comment on the application or protest it.

The 15 day public comment period starts at the latest of three dates:

1. the date the application is received by the RRC with the appropriate fee;
2. the date notice is mailed or delivered to the surface owner, offset operators, and city/county clerks; and
3. the date public notice is published.

Any local government or affected person may formally protest the application at any time before the permit is issued. An affected person is defined as - a person who has suffered or will suffer actual injury or economic damage other than as a member of the general public, and includes surface owners of record of property on which the well is located and adjoining offset operators.

14-TX-c.10 to 14-TX-c.14 - Appeal and Hearing Proceedings

If an application is protested or denied the developer must request a hearing with the RRC. Following a request for a hearing the RRC will notify affected parties and the public of the hearing and its date. Following the hearing the RRC may require that the application be modified.

14-TX-c.15 to 14-TX-c.16 – Underground Injection Control Permit and Completions Report

Following the RRC’s final review, the RRC will issue an Underground Injection Control Permit. Following the completion of a new injection well the developer is required to submit a Completion Report to the RRC within 30 days

The developer is required to comply with all monitoring and testing requirements during the well’s life.




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Injection-Storage Permit and Support
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