In November 2017, the Texas Railroad Commission (RRC), which regulates the state’s oil and gas operations, submitted a report on its Class II Underground Injection Well Control (UIC) program to EPA. This report, which Clean Water Action received via an open records request, has not been published on either agency's web page. Though far from the complete description of the RRC's UIC program that we had hoped for, the report nevertheless contains information that is vital to the public's understanding of how this program works.
For example, the report documents 54 instances where the RRC authorized injection of oil and gas wastewater into Underground Sources of Drinking Water without first securing approval from EPA. This is a violation of its 1982 Memorandum of Understanding with EPA. The report is also noteworthy for what it fails to provide: it includes no maps or lists of oil fields that were exempted from the aquifer exemption program in1982, even though the RRC promised to provide those.
The report is in part a response to Clean Water Action's 2016 report which documented the failure of the RRC to follow the terms of its 1982 agreement. Clean Water Action and Clean Water Fund will be releasing a follow-up report soon.
