Geothermal

Authority

The Commission regulates the exploration, development, and production of geothermal energy and associated resources on public and private land for the purpose of conservation and the protection of correlative rights. Injection wells used for the production of geothermal or geopressured water and their by-products must be permitted by the Commission prior to beginning injection. However, closed-loop geothermal wells are under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). 

Application Guideline for an Injection Permit to Produce Geothermal Energy and Associated Resources

If you are planning a geothermal energy project in Texas, it is recommended that you discuss with Injection-Storage Permits Unit staff before submitting an application to permit an injection well for your project. You can email us at UIC@rrc.texas.gov.

Rules

Generally, an applicant for a geothermal energy injection well permit will be required to submit information typical of injection/disposal well applications and information addressing the specific nature of the proposed operation. The applicant must abide by all applicable RRC rules. Oil and Gas Division rules regarding administration, oil and gas well construction and operation, and injection will generally be considered applicable to the proposed injection well unless specifically stated otherwise. If you do not believe an oil and gas rule is applicable to your operation, you must identify the specific rule(s) or rule sections, and state why.

Confidentiality

If you believe that any of the information requested below is confidential, contact the Commission's Injection-Storage Permits Unit Manager or Office of General Counsel prior to submitting any potentially confidential information. Our applications are Open Records under the Texas Public Information Act (Texas Government Code, Chapter 552)

Application Checklist

1. You must have an active Form P-5, Organization Report.
2. You must be the Form P-4 (leaseholder) of an on-schedule well.
3. You must have a drilling permit.

Forms

1. Complete and submit: Forms GT-5 (Application to Inject Fluid into a Reservoir Productive of Geothermal Resources), H-1A (Injection Well Data for H-1 Application), W-2/G-1 Completion Report, P-4 (Producer's Transportation Authority and Certificate of Compliance), and P-5 (Organization Report).
   1. Form GT-5 does not include a space for Operator Number or Field Number. Please include those numbers and other reference information on the forms where applicable.
2. Do not submit: Forms H-1 (Application to Inject Fluid into a Reservoir Productive of Oil & Gas), GT-2 (Producer's Monthly Report of Geothermal Wells), GT-4 (Producer's Certificate of Compliance and Authorization to Transport Geothermal Energy and/or Natural Gas and/or Other Materials), or GT-5 Injection Well Data Page
3. Provide all the applicable information required by the Forms required above with applicable fees and surcharges, including fees for exceptions if applicable.
   1. All injectate components and sources
   2. Safety Data Sheets for chemicals

Common Attachments

1. Provide all the applicable attachments typically required to be submitted with the Forms H-1/H-1A, including:
   1. Well Log
   2. Groundwater Letter (Form GW-2)
   3. AOR (1/4 mile)
      1. Include water well survey in AOR
   4. Historic Seismicity data across AOI (9.08 km radius), including
      1. Perpendicular cross-sections with formations and zones annotated
      2. Structure maps on top and bottom of proposed zone(s)
      3. Isopach map of proposed zone(s)
   5. A map and accompanying list showing the names, address and locations of adjacent landowners within one-half mile of the proposed geothermal well or facility; the location of water wells within one mile of the proposed geothermal well or facility; the names, addresses and locations of operators within ½ mile of the proposed geothermal well or facility.
   6. Proof of notice of application
      1. Published Notice
      2. Notice of application to all Operators within one-half mile
      3. Notice of application to all adjacent surface owners
   7. Freshwater Injection questionnaire & Form H-7 (Fresh Water Data Form), if applicable.
   8. Provide detailed information on why freshwater must be used for injection and how much will be used, including water quality analysis.

Well Construction

1. Provide information regarding compatibility of the casing and the injectate. All casing materials shall be suitable for the proposed operating design stresses and temperatures.
2. Provide a well diagram.
   1. Detailing the size, type, depth of casing strings and cement behind the casing strings.
   2. How Usable-Quality Water (UQW, ≤ 3,000 ppm TDS) will be protected.
   3. How Underground Sources of Drinking Water (USDW, ≤ 10,000 ppm TDS) will be protected.
   4. Whether the completion is open hole or cased.
3. If tubing and packer or surface casing is not used, provide an:
   1. Explanation as to why tubing and packer or surface casing cannot be used
   2. Explanation of how safety and protection of natural resources will be maintained without typical well construction
   3. Explanation of how the mechanical integrity of the well will be determined without tubing and packer

Well Completion

1. Provide a description of the planned completion program for the well, including:
   1. The proposed well treatment, acid job, hydraulic fracture, etc.
   2. Proposed monitoring during completion.

Operations

1. Provide a discussion of injection purpose and procedures.
2. Provide a surface facility diagram with purpose, dimensions and capacities of storage.
   1. See pit permitting information on the Pits webpage.
3. Provide a proposed Maximum Surface Injection Pressure (MSIP) or procedure for determining the MSIP. For example: “A Step-Rate Test (SRT) will be performed to determine fracture pressure of the reservoir. The Maximum Surface Injection Pressure (MSIP) will be no greater than 90% of the fracture pressure. The proposed MSIP will be submitted to the Commission within 10 days of completion of the SRT.”
4. Provide a description of the expected lifetime of the facility and conditions for closure.
5. Provide a description of proposed Facility closure procedures.

Monitoring

1. Mechanical Integrity Test (MIT)
   1. Initial MIT must be performed before injection and the results filed on Form H-5 (Online)
   2. Annual MIT must be performed
   3. The operator must provide a description of the MIT procedure, which should include, at a minimum:
      1. Initial and annual annulus pressure tests, and
      2. The results of a temperature or noise log.
2. The wellhead must have all gauges required by rule. Provide a description of the gauges you will have on the wellhead and your procedures for monitoring well head pressure.
3. Provide a description of the methods, procedures, and frequency for injectate water quality testing, and frequency of reporting to the Commission.
4. Well testing and logging data required within 30 days:
   1. An electric log as defined by SWR 16 from surface
   2. Cement Bond Log (CBL)

Reporting

1. The operator must file an online completion packet (Form W-2/G-1), including GT-1, within 30 days of completion
2. Provide proposed Annual Reporting, including:
   1. Tabulated Monthly Injected & Produced Volumes & Injection Pressures
      1. Maximum Daily Injection Volume (MDIV) for each month
      2. Maximum Injection Surface Pressure (MSIP) for each month
      3. Maximum daily production volume for each month
      4. Maximum daily volume of water added for each month
      5. Average daily injection volume for each month
      6. Average daily production volume for each month
      7. Average daily surface injection pressure for each month
      8. Average daily volume of water added for each month
      9. Total injection volume for the year
      10. Daily records to support each of the items above must be kept and provided if asked, but do not have to be submitted with annual reports.