September 27, 2017
10 Things You Should Know About Kentucky’s New UIC Program
POSTED BYScott R. Smith
- Kentucky’s Primacy Date for the UIC program was March 21, 2017. 90 days after that date, operators were required to submit to the Ky. Division of Oil & Gas (DOG) the following information:
- A plugging and abandonment plan as required by 805 KAR 1:110(10);
- A demonstration of adequate financial responsibility to plug and abandon a well as required by 805 KAR 1:110 (8-9);
- A copy of all documents showing approval by EPA of the well’s mechanical integrity and a copy of all forms, test data and logs required by and submitted to EPA.
- Who will continue to work with EPA and which operators will be subject to the Kentucky Program?
- Class II permit applications under review by EPA will be transferred to DOG;
- Any permit subject to EPA enforcement action will be maintained by EPA until resolution;
- All wells permitted at the date of primacy by EPA will be permitted by rule by DOG;
- Area permits permitted by EPA at the date of primacy will be maintained by DOG;
- Current MIT schedule will be maintained.
- If the existing bond posted with EPA meets the requirements of Section 8 of this administrative regulation and is transferable to the Division, the transfer of the bond shall be accepted by the Division.
- An application for a wells(s) must be on the ED-14 (Class II Permit Application) with a fee of $400. Area of review (AOR) extends a ¼ mile radius circle around the proposed injection well. Information required within the AOR includes well logs and completion report (ED-3) on all producing, abandoned, plugged and dry wells; known faults, surface and underground mines and water wells.
- Injection can only commence after submitting Form ED-25 (Casing and Cementing Plan
- The IMIT pressure test must be witnessed by DOG inspector. 15-day written notification must be made to DOG.
- A list of the standard analysis of fluid to be injected can be found at 805 KAR 1:110 (11)(g)(2).
- Some of the more common types of violations include: Failure to obtain a Class II permit; Injection of a non-authorized fluid; mechanical integrity test failure and failure to maintain Class II Financial Responsibility.
- Lots of paperwork is associated with this program. Well organized files and readily available information can shorten an inspection and make violations less likely to occur. 3rd party paperwork assessments can be a good way to insure your information is in good order.
Questions can be directed to:
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- Karen Thompson Karent@smithmanage.com
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