Brookston Resource, Inc. v. State of Indiana Department of Natural Resources

CourtIndiana Court of Appeals
DecidedSeptember 11, 2024
Docket23A-MI-02971
StatusPublished

This text of Brookston Resource, Inc. v. State of Indiana Department of Natural Resources (Brookston Resource, Inc. v. State of Indiana Department of Natural Resources) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brookston Resource, Inc. v. State of Indiana Department of Natural Resources, (Ind. Ct. App. 2024).

Opinion

IN THE

Court of Appeals of Indiana FILED Sep 11 2024, 9:04 am

CLERK Indiana Supreme Court Brookston Resources, Inc., an Illinois Corporation, Court of Appeals and Tax Court

Appellant-Petitioner

v.

State of Indiana Department of Natural Resources, Appellee-Respondent

September 11, 2024 Court of Appeals Case No. 23A-MI-2971 Appeal from the Spencer Circuit Court The Honorable Karen A. Werner, Judge Pro Tempore Trial Court Cause No. 74C01-2211-MI-468

Opinion by Judge Tavitas Judges Crone and Bradford concur.

Court of Appeals of Indiana | Opinion 23A-MI-2971 | September 11, 2024 Page 1 of 33 Tavitas, Judge.

Case Summary [1] Brookston Resources, Inc. (“Brookston”) appeals the trial court’s denial of its

petition for judicial review regarding a decision by the Indiana Department of

Natural Resources (“Department”). The Indiana Oil and Gas Association

(“Association”) submitted an amicus curiae brief in support of Brookston.

[2] This appeal concerns Brookston’s challenge to notices of violation issued by the

Department regarding three of Brookston’s oil wells. The administrative law

judge (“ALJ”) upheld the notices of violation, and on judicial review, the trial

court denied Brookston’s petition. On appeal, Brookston argues that the

Department’s decision was in excess of statutory authority, arbitrary and

capricious, and unsupported by substantial evidence. Specifically, Brookston

argues that, because the Department determined in 1992 that abandoned wells

in the area of Brookston’s wells were adequately plugged, the Department did

not have the authority to issue notices of violation in 2019 finding that the

abandoned wells were inadequately plugged.

[3] We conclude that the relevant statutes and regulations allow the Department to

conduct file reviews of the wells at issue every five years, and those file reviews

include a consideration of the abandoned wells. Moreover, as Brookston never

obtained injection authorization regarding its wells, any change in the injection

rate as a result of the file review would not amount to a modification of the

permit. The Department’s issuance of the notices of violation was, thus, not

Court of Appeals of Indiana | Opinion 23A-MI-2971 | September 11, 2024 Page 2 of 33 arbitrary and capricious or without statutory authority. Finally, the

Department’s determination that the abandoned wells have the potential to

cause or contribute to the migration of injection fluids into underground sources

of drinking water due to inadequate construction or plugging is supported by

substantial evidence. Accordingly, we disagree with Brookston’s arguments

and affirm.

Issues [4] Brookston raises several issues, which we revise and restate as:

I. Whether Brookston waived arguments made on appeal but not made below.

II. Whether the Department’s issuance of the notices of violation was arbitrary and capricious or in excess of statutory authority.

III. Whether the Department’s notices of violation are supported by substantial evidence.

Facts A. Background

[5] According to the Association, there are 9,750 active oil and gas wells in

Indiana. In its amicus curiae brief, the Association explains the process of

recovering oil as follows:

[P]rimary recovery is the initial phase of an oil and gas well where the natural pressure of the reservoir brings oil to the

Court of Appeals of Indiana | Opinion 23A-MI-2971 | September 11, 2024 Page 3 of 33 surface. Once this pressure drops and oil production decreases, secondary recovery becomes necessary. Only 10% of a reservoir’s oil is produced during primary recovery. Secondary recovery uses techniques like waterflooding to maintain or increase reservoir pressure and stimulate oil production.

In the Illinois Basin, the water used for injection is usually water brought to the surface along with oil. The saltwater is then injected into the reservoir through injection wells. These wells must be strategically located to ensure even distribution of water pressure across the reservoir. The injection of saltwater helps maintain or increase the reservoir pressure, which has declined during the primary recovery phase. This increased pressure helps push more oil towards the production wells. The injected water acts as a sweeping mechanism, pushing the oil towards the production wells. The water essentially displaces the oil, improving the recovery rate by moving the oil that was not recoverable during the primary phase. Saltwater injection can significantly increase the total recoverable oil from a reservoir beyond what’s possible with just primary recovery methods.

Amicus Curiae Br. pp. 11-12.

[6] Certain Class II wells located in Spencer County, which are used for secondary

recovery efforts, are at issue here. A “Class II well” is defined as:

[A] well that injects fluids:

(1) that are brought to the surface in connection with conventional oil or gas production and can be commingled with wastewaters (other than wastewaters classified as hazardous waste at the time of injection) from gas plants that are an integral part of production operations;

Court of Appeals of Indiana | Opinion 23A-MI-2971 | September 11, 2024 Page 4 of 33 (2) for the enhanced recovery of oil or gas; or

(3) for the storage of hydrocarbons that are liquid at standard temperature and pressure.

Ind. Code § 14-8-2-41.

[7] On August 19, 1991, the Department obtained approval from the United States

Environmental Protection Agency (“EPA”) to administer the Class II Well

Underground Injection Control (“UIC”) Program. See 40 C.F.R. § 147.750, 56

Fed. Reg. 41072 (Aug. 19, 1991). The program consisted of several “elements,”

which were “submitted to the EPA in the State’s program application.” Id.

One of those elements is the “Program Description.” Id. The Program

Description provided, in part:

D. Plugging and Abandonment. Permanent abandonment of wells is conducted in accordance with the provisions of 310 IAC 7-1-33 and includes either:

* Placement of [American Petroleum Institute (“API”)] approved slurry cement plugs at the following intervals:

a. From either total depth or fifty (50) feet below, to one hundred (100) feet above all injection zones and,

b. From fifty (50) feet below the lowest identified [Underground Source of Drinking Water (“USDW”)] to the surface.

Court of Appeals of Indiana | Opinion 23A-MI-2971 | September 11, 2024 Page 5 of 33 OR

* Placement of an appropriate mechanical plug at the top of the uppermost injection zone in conjunction with the placement of API approved slurry cement plugs at the following intervals:

a. From the top of the mechanical plug to a point fifty (50) feet above the mechanical plug; and,

b. From fifty (50) feet below the lowest identified USDW to the surface.

Appellant’s App. Vol. III pp. 57-58. Inadequate plugging of wells can result in

contamination of a USDW.

B. Subject Wells

[8] These proceedings concern three wells that were converted to Class II wells and

have been operated by various companies in Spencer County since the mid-

1960s—Curtis Mills No. 4 Well; A. & L. Leistner No. 3 Well; and Leistner No.

W-1 Well (“the Subject Wells”). In 1992, shortly after the Department

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