On March 7, 2018, the California Division of Oil, Gas and Geothermal Resources (“DOGGR,” or “Division”) published a notice to operators (“NTO”) regarding updated guidelines for oilfield water quality data. The NTO outlines procedures for submission of oilfield water quality data by operators, including required notices, injectate samples, formation water samples, documentation and final report and certification processes.
Notably, the “Division requires that all sources of injection water be identified in a chemical analysis of the injection water and each receiving formation water in the area of the injection project be performed with the results submitted to the Division and the [local Regional] Water [Quality Control] Boards:
- Prior to injection of a new or expansion of an existing project, or
- Whenever the source of the injection water is changed, or
- As directed by the Division or the Water Boards.”
Operators are required to conduct water quality testing in support of underground injection control project applications, aquifer exemption proposals, and certain other technical reports. The NTO merely clarifies and revises the guidelines required for submission of this data. Operators should be sure to comply with the requirements of the NTO in order to avoid potential violations or penalties from DOGGR.