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California Underground Injection Control Permit (14-CA-c)

The injection of spent (cooled) geothermal fluids and in some cases supplemental waters from other sources are regulated under the EPA’s Underground Injection Control, Class V Regulatory Program. The California Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR) has a Memorandum of Understanding with the EPA to administer the program for geothermal resources on non-federal lands (i.e. state and private lands). DOGGR regulates geothermal wells under Division 3, Chapter 4 of the California Public Resources Code, Title 14, Division 2, Chapter 4 of the California Code of Regulations and the Federal Safe Drinking Water Act. California’s Underground Injection Control Program includes permitting, inspection, and enforcement, among other aspects. Many specific aspects of the geothermal underground injection control program are specified in the Memorandum of Agreement Between State Water Resources Control Board and DOGGR.

Underground Injection Control Permit Process

14-CA-c.1 to 14-CA-c.2 - Is the Waste Water Associated Only with Geothermal Operations?

Waste Discharge Permit:

14-CA-c.3 - Application for Proposed Underground Injection Project

Under the Memorandum of Agreement Between State Water Resources Control Board and DOGGR geothermal operators must file an application for underground geothermal wastewater injection with the appropriate DOGGR district office. The application must include:

  • A chemical analysis to characterize the proposed injection fluid;
  • A chemical analysis from the proposed zone of injection considering the characteristics of the zone; and
  • The depth, location, and injection formation of the proposed well.

14-CA-c.4 to 14-CA-c.5 - Review Application Materials for Completeness

14-CA-c.6 - Comment on Application (Optional)

The DOGGR Regional Board receives the option to comment on the application prior to the issuance of a Draft Project Approval Letter for review. The DOGGR Regional Board shall furnish any comments to the DOGGR State Board within 14 days of the applicant submitting the application.

14-CA-c.7 - Draft Project Approval Letter

The DOGGR State Board prepares a Draft Project Approval Letter, including monitoring requirements for the injection in accordance with applicable laws and regulations.

14-CA-c.8 to 14-CA-c.9 - Public Notice and Comment on Draft Project Approval Letter and Public Hearing (If Significant Amount of Comments)

The State Board posts the Draft Project Approval Letter for public comment. If the State Board receives a significant amount of comments on the Draft Project Approval Letter, the State Board will hold a public hearing on the Draft Project Approval Letter.

14-CA-c.10 - Propose Revisions

The Regional Board determines whether the draft requirements provide protection to ground and surface waters with present or anticipated beneficial use. If the Regional Board determines the draft requirements are not adequate, the Regional Board has 30 days to propose revisions which satisfy the Regional Board's concerns.

14-CA-c.11 - Updated Draft Project Approval Letter

The DOGGR State Board prepares an Updated Draft Project Approval Letter, reflecting the public comments and Regional Board's proposed revisions.

14-CA-c.12 - Does the DOGGR Approve the Underground Injection Project

After the end of the comment period and after reviewing any proposed revisions furnished by the Regional Board, the State Board decides whether to approve the Underground Injection Project.

14-CA-c.13 - Project Approval Letter

If the DOGGR State Board finds the draft requirements provide protection and ground and surface waters, the State Board issues the applicant an Underground Injection Project Approval Letter.

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