State Regulations: Arkansas

The Arkansas Pollution Control and Ecology Commission (APC&E Commission) is the environmental policy-making body for Arkansas. The APC&E Commission determines the environmental policy for the state. Other agencies are entrusted with the actual implementation of the policies. The Arkansas Oil and Gas Commission (AOGC) administers the oil and gas regulations. It has the responsibility to prevent waste, encourage conservation, and protect the correlative rights of ownership associated with the production of oil, natural gas, brine, and associated products. The State of Arkansas Department of Environmental Quality (ADEQ) administers the protection of the natural resources of the state, including air, water, and land, from the threat of pollution.

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Produced Water Management Practices and Applicable Regulations

The AOGC is the lead agency for disposal through injection wells. The statewide regulations of the AOGC can be found in Commission Rules and Regulations.

• Disposal of Salt Water by Injection (Commission Rules and Regulations, Rule C-7). Salt water or other water-containing minerals in such amounts as to be unfit for domestic, stock, irrigation, or other general uses, upon application to, and approval by the AOGC, may be disposed of by injection. The regulations include requirements governing the receiving formations; well casing, cementing, and mechanical integrity testing; trial testing, public involvement; notice of commencement and discontinuance; and commercial facilities.
  • AOGC/ADEQ Application to Inject Salt Water/Enhanced Recovery Fluid
  • For Class II injection wells in general, in Regulation 17 Arkansas Underground Injection Control Code promulgated by the Arkansas Pollution Control and Ecology Commission states that the AOGC exercises responsibility.
     
• Fluid Pressurizing and Water Flooding of Oil and Gas Properties (Commission Rules and Regulations, Rule C-8). The owner or operator of any well may inject water or other liquids under pressure into the formation containing oil or gas for the purpose of obtaining oil or gas from the reservoir, upon application to and approval by the AOGC. The regulations include requirements governing the receiving formations; well casing, cementing, and mechanical integrity testing; public involvement; and notice of commencement and discontinuance.
  • AOGC/ADEQ Application to Inject Salt Water/Enhanced Recovery Fluid
     
• Requirements for Pumping Reserve Pits in Wells. The Commission Rules and Regulations (at the end of "General Rules and Regulations") provide the requirements for pumping reserve pit fluids into wells.
  • Surface casing must be set at least 250' below the last known fresh water sand.
  • All bottom hole plugs must be set as required before pumping operations can begin.
  • Finally, AOGC Form 20 (Request for Disposal of Reserve Pit Fluids) must be submitted.

The ADEQ is the lead agency for other disposal methods. The regulations adopted by the APC&E are the basis for ADEQ's permitting, monitoring and enforcement programs, public involvement activities and other services.

• The discharge of any fluids generated from any activity associated with oil and gas exploration or production to any surface or ground waters of the State is strictly prohibited (Regulation 1 Regulation for Prevention of Pollution by Salt Water and Other Oil Field Wastes Produced by Wells in All Fields or Pools promulgated by the Arkansas Pollution Control and Ecology Commission).
  • The ADEQ has the responsibility for regulating the construction and operation of surface facilities associated with a disposal system for injection of saltwater.
    • Notice of Intent — Application for Saltwater Disposal Permit

• ADEQ Oilfield Waste and Reserve Pit Requirements. Each reserve pit must comply with all applicable requirements governing construction, operations, and closure. The discharge of any fluids generated from any activity associated with oil and gas exploration or production to any surface or ground waters of the State is strictly prohibited. Reserve pit fluids generated or transported in State shall be disposed of in a manner approved by the ADEQ and be disposed of by only those companies that have obtained a valid Disposal Permit from the ADEQ. Land application can only be conducted by companies permitted through the ADEQ.