Railroad Commission of Texas - Seismic Review Process for Operators

On March 26, 2020, a 5.0 magnitude earthquake was recorded in West Texas. Centered approximately 27 miles from the city of Mentone, the activity was located about 3 miles deep, was felt as far as El Paso, and is now the largest recorded earthquake in West Texas. The Mentone area recorded an additional 5 smaller earthquakes in the 4 days prior to the 5.0 being felt. As of the date of this writing, the West Texas area recorded 10 earthquakes over the past week and 28 over the last 30 days, all registering between four to eight (4 to 8) km deep.¹

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West Texas is home to extensive oil and gas development with many operators targeting the Permian Basin, as well as the Delaware Basin, during the recent shale revolution. Due to various operational restraints and industry stressors, saltwater disposal remains the common way of handling postproduction wastewater. With the increase in wastewater injection, as well as seismic activity, the Railroad Commission of Texas (“RRC”) has developed a “seismic review process” for injection wells near a recorded earthquake. Many factors come into play with the seismic review, with events that “can be triggered by complex geology (for example, injection into basement or near basement strata with known faulting).”³

For operators, these new review procedures may require extra attention. Now, in addition to an application for the permit of a new disposal well, or an amendment to a permit on an existing disposal well, operators must also include a “survey of historical seismic events within 5.64 miles, the Area Of Interest (AOI).”⁴ If the AOI has a fault, the RRC also requires a fault hazard analysis to be performed. Operators should also maintain a “Seismic Monitoring Plan,” evidencing monitoring methods, locations of equipment used, etc. Additionally, operators should also have an Earthquake Response Plan. This Plan should be filed with the RRC before injection activities start.

If a seismic event is 2.0 magnitude or higher, the seismic review is triggered and the RRC may adjust conditions to lower injection rates, lower injection pressure, require bottom-hole pressure tests, etc. The RRC may also modify, suspend or termination an injection well permit, balancing a number historical and geological factors in the review process.

If the seismic event is 3.5 magnitude, the RRC’s earthquake response plan is triggered. For this, operators are required to notify the RRC within twenty-four (24) hours of the event, and within thirty (30) days of the event, the operator must also file a report with the RRC that documents the seismic activity and response.

As earthquakes continue in West Texas, it is recommended that operators who are dealing with new or existing injection wells should inspect and review their records to ensure compliance. It is further recommended that operators have proper response plans in place for swift action in the event that seismic activity occurs around or near injection well sites.

If you have questions regarding changing rules and regulations related to your oil and gas operations, reach out to us at 405-701-5355.

¹ https://earthquaketrack.com/r/western-texas/recent
² Id.
³ Railroad Commission of Texas, Seismicity Review: Information for Permitting Disposal Wells in Areas of Seismicity (August 12, 2019).
⁴ Id.