Louisiana Administrative Code › Title 43 - NATURAL RESOURCES › Part XVII - Office of Conservation-Injection and Mining › Subpart 1 - Statewide Order No. 29-N-1 › Chapter 1 - Class I, III, IV and V Injection Wells › Section XVII-109 - Technical Criteria and Standards

Current through Register Vol. 50, No. 6, June 20, 2024
A. Class I Wells
1. Applicability. This Subsection establishes
				  technical criteria and standards for regulation of Class I wells which possess
				  a permit or are authorized by rule.
2. Area of Review
a. The area of review for each Class I
				  injection well shall be a fixed radius around the well of not less than 2
				  miles.
b. All known unplugged or
				  improperly plugged and abandoned wells in the area of review which penetrate
				  the injection zone are subject to the corrective action requirements of
				  §109. A 3
3.
				  Corrective Action
a. Coverage. Applicants for
				  Class I injection well permits shall identify the location of all known wells
				  within the area of review which penetrate the injection zone. For such wells
				  which are improperly sealed, completed or abandoned, the applicant shall also
				  submit a plan consisting of such steps or modifications as are necessary to
				  prevent movement of fluid into underground sources of drinking water
				  ("corrective action"). Where the plan is adequate, the commissioner shall
				  incorporate it into the permit as a condition. Where the commissioner's review
				  of an application indicates that the permittee's plan is inadequate (based on
				  the factors in §109. A.3.c the commissioner shall require the applicant
				  to revise the plan, prescribe a plan for corrective action as a condition of
				  the permit under §109. A.3 b, or deny the application.
b. Requirements
i. Existing Injection Wells. Any permit
				  issued for an existing injection well requiring corrective action shall include
				  a compliance schedule requiring any corrective action accepted or prescribed
				  under §109. A.3.a to be completed as soon as possible.
ii. New Injection Wells. No permit for a new
				  injection well may authorize injection until all required correction action has
				  been taken.
iii. Injection Pressure
				  Limitation. The commissioner may require as a permit condition that injection
				  pressure be so limited that pressure in the injection zone does not cause the
				  movement of fluids into a USDW through any improperly completed or abandoned
				  will within the area of review. This pressure limitation shall satisfy the
				  corrective action requirement. Alternatively, such injection pressure
				  limitation can be part of a compliance schedule and last until all other
				  required corrective action has been taken.
c. In determining the adequacy of corrective
				  action proposed by an application for a well requiring such action and in
				  determining the additional steps needed to prevent fluid movement into
				  underground sources of drinking water, the following criteria and factors shall
				  be considered by the commissioner:
i. nature
				  and volume of the injected fluid;
ii. nature of native fluids or by-products of
				  injection;
iii. potentially
				  affected population;
iv.
				  geology;
v. hydrology;
vi. history of the injection
				  operation;
vii. completion and
				  plugging records;
viii. abandonment
				  procedures in effect at the time the well was abandoned; and
ix. hydraulic connections with underground
				  sources of drinking water.
4. Construction Requirements
a. Siting. All Class I wells shall be sited
				  in such a fashion that they inject into a formation which is beneath the lower
				  most formation containing an underground source of drinking water within 1/4
				  mile radius of the well bore.
b.
				  Casing and Cementing
i. All Class I wells
				  shall be cased and cemented to prevent the movement of fluids into or between
				  USDWs.
ii. Cementing shall be by
				  the pump and plug or other method approved by the commissioner and sufficient
				  amount of cement shall be used to fill the annular space between the hole and
				  casing and between casing strings to the surface of the ground.
iii. The casing and cement used in the
				  construction of each new injection well shall be designed for the life
				  expectancy of the well.
iv. Surface
				  casing shall be set to a minimum subsurface depth determined by the
				  commissioner to properly protect underground sources of drinking water and
				  cemented to the surface. If the long string or intermediate casing is to be
				  perforated, the approved casing shall be set to a depth below the injection
				  zone and cemented to the surface. If an approved alternate method is used, such
				  as the setting of a screen, the casing shall be set to the top of the injection
				  zone and cemented back to the surface.
v. In determining and specifying casing and
				  cementing requirements, the following factors shall be considered:
(a). depth to the injection zone;
(b). injection pressure, external pressure,
				  internal pressure, and axial loading;
(c). hole size;
(d). size and grade of all casing strings
				  (wall thickness, diameter, nominal weight, length, joint specification, and
				  construction material);
(e).
				  corrosive effects of injected fluid, formation fluids, and
				  temperatures;
(f). lithology of
				  injection and confining intervals; and
(g). types and grades of cement.
c. Tubing and Packer
i. All Class I injection wells shall inject
				  fluids through tubing with either a packer set above the injection zone or a
				  fluid seal system approved by the commissioner. In determining and specifying
				  requirements for tubing, packer or fluid seal system, the following factors
				  shall be considered:
(a). depth of
				  setting;
(b). characteristics of
				  injection fluid;
(c). injection
				  pressure;
(d). annular
				  pressure;
(e). rate, temperature,
				  and volume of injected fluid; and
(f). size of casing.
ii. The use of other alternatives to a packer
				  may be allowed with the written approval of the commissioner. To obtain
				  approval, the operator shall submit a written request to the commissioner,
				  which shall set forth the proposed alternative and all technical data
				  supporting its use. The commissioner shall approve the request if the
				  alternative method will reliably provide a comparable level of protection to
				  underground sources of drinking water. The commissioner may approve an
				  alternative method for an individual well or for general use.
iii. A corrosion resistant fluid shall be
				  placed under pressure into the tubing-long string casing annulus. The annulus
				  pressure shall be monitored in accordance with §109. A.7 d
d. Logs and Tests.
				  Appropriate logs and other tests shall be conducted during the drilling and
				  construction of new Class I wells. All logs and tests shall be interpreted by
				  the service company which processed the logs or conducted the test, or by other
				  qualified persons. A minimum of the following logs and tests shall be
				  conducted.
i. Deviation checks on all holes
				  constructed by first drilling a pilot hole, and then enlarging the pilot hole
				  by reaming or another method. Such checks shall be at sufficiently frequent
				  intervals to assure that avenues for fluid migration in the form of diverging
				  holes are not created during drilling.
ii. For surface casing:
(a). spontaneous potential, resistivity or
				  gamma-resistivity, and caliper logs before the casing is installed;
				  and
(b). a cement bond,
				  temperature, or density log after the casing is set and cemented.
iii. For intermediate and long
				  string casing:
(a). spontaneous potential,
				  resistivity or gamma-resistivity, and caliper logs before the casing is
				  installed;
(b). a fracture finder
				  log when applicable; and
(c). a
				  cement bond log, a gamma-ray (full hole) log, and an inclination survey after
				  the casing is set and cemented.
iv. All casing strings shall be pressure
				  tested at conditions specified by the commissioner and reported on form
				  CSG.T.
v. If core data is not
				  available from nearby wells full-hole cores shall be taken from selected
				  intervals of the injection zone and lowermost confining zone; or, if full-hole
				  coring is not feasible or adequate core recovery is not achieved, side-wall
				  cores shall be taken at sufficient intervals to yield representative data for
				  selected parts of the injection zone and lowermost confining zone. Core
				  analysis shall include a determination of permeability, porosity, bulk density,
				  and other necessary tests.
e. Injectivity Tests. After completion of the
				  well, injectivity tests shall be performed to determine the well capacity and
				  reservoir characteristics. Surveys shall be performed to establish preferred
				  injection zones. Prior to performing injectivity tests, the bottom hole
				  pressure, bottom hole temperature, and static fluid level shall be determined,
				  and a representative sample of formation fluid shall be obtained for chemical
				  analysis.
f. Construction
				  Supervision. All phases of well construction and all phases of any well
				  workover shall be supervised by a person who is knowledgeable and experienced
				  in practical drilling engineering and who is familiar with the special
				  conditions and requirements of injection well construction.
5. Pre-Operation Requirements. In
				  order to receive approval to start operation of a new well, the permittee must
				  supply the following to the commissioner within 30 days of well completion.
a. A completion report containing, at a
				  minimum, the following:
i. the drilling and
				  complete and accurate record of the depth, thickness, and character of the
				  strata penetrated;
ii. casing and
				  cement records;
iii. well
				  logs;
iv. injectivity test
				  data;
v. measured bottomhole
				  temperature and pressure;
vi. core
				  sample testing results;
vii.
				  formation fluid analysis;
viii.
				  compatibility testing results;
ix.
				  test data which provides a demonstration of mechanical integrity pursuant to
				  §109. A 9;
x. a descriptive
				  report interpreting the results of all logs and tests;
xi. a revised formation pressure build-up
				  calculation in accordance with §105. E.3 l;
xii. a revised waste front travel calculation
				  (§105. E.3 m); and
xiii.
				  revised cross sections of the injection zone using pertinent data
				  above.
b. For commercial
				  Class I wells, written notification that a copy of the permit has been filed
				  with the appropriate authorities where the well is located.
c. Written Notification of the Anticipated
				  Well Startup Date. Compliance with all pre-operation terms of the permit must
				  occur and approval to start operation must be received from the commissioner
				  prior to beginning injection operations (see §107 L)
d. The commissioner may give permission to
				  commence injection for an interim period of 30 days following the inspection
				  required in §107. L.2.b Final permission to inject will be given only
				  upon receipt and approval of the completion report required in §109.
				  A 5
6. Operating
				  Requirements
a.
i. Except during well stimulation, the
				  Maximum Surface Injection Pressure (MSIP) shall not exceed the surface
				  injection pressure needed to initiate fracture of the injection or confining
				  zone(s) and shall be calculated by following the formula:
MSIP = 0.85 [BHPF - H] + TF +
					 SE
where:
BHPF  = bottomhole fracture pressure
					 established by gradients for the area the well is located in or actual
					 testing
H = hydrostatic pressure
TF = frictional loss in the tubing during maximum injection
					 rate
SE = skin effects as established by accepted engineering
					 test procedures as described in "Pressure Buildup and Flow Tests in Wells", by
					 C.S. Matthews and D.G. Russell or approved alternate tests (optional
					 variable)
ii. In no case
				  shall the calculated maximum surface injection pressure exceed the surface
				  injection pressure needed to initiate fractures in the confining or injection
				  zone(s) or cause movement of injection or formation fluids into a USDW.
b. Injection between the
				  outermost casing protecting underground sources of drinking water and the well
				  bore is prohibited.
c. Unless an
				  alternative to a packer has been approved by the commissioner, the tubing-long
				  string casing annulus shall be filled with a corrosion resistant fluid approved
				  by the commissioner. A positive pressure, also approved by the commissioner,
				  shall be maintained on the annulus to detect well malfunctions.
d. A protective barrier shall be maintained
				  around the wellhead and related appurtenances during all normal in-service and
				  out-of-service periods for protection against mechanical damage.
e. A sign shall be maintained on the
				  protective barrier of each injection well identifying the well class (Class I)
				  operator, well name and/or number, UIC permit number, and any other information
				  required by the commissioner.
f.
				  Approval by the commissioner shall be obtained before the permittee may begin
				  any workover operation (see §109. A.8.b.i All fluids and materials
				  (sand, etc.) removed from a well during any workover operation shall be
				  contained and disposed of properly.
7. Monitoring Requirements
a. Samples and measurements taken for the
				  purpose of monitoring shall be representative of the monitored
				  activity.
b. Records of monitoring
				  information shall include:
i. the date, exact
				  place, and time of sampling or measurements;
ii. the individual(s) who performed the
				  sampling or measurements;
iii. the
				  date(s) analyses were performed;
iv. the individual(s) who performed the
				  analyses;
v. the analytical
				  techniques or methods used; and
vi.
				  the results of such analyses.
c. Injection fluids shall be sampled and
				  analyzed with a frequency sufficient to yield data representative of their
				  characteristics.
d. Pressure gauges
				  shall be installed and properly maintained on the injection tubing and on the
				  annulus at the wellhead.
e.
				  Continuous recording devices shall be installed and maintained in proper
				  operating condition at all times to monitor and record injection tubing
				  pressures, injection flow rates, injection volumes, tubing-long string casing
				  annulus pressure, and any other specified data. The instruments shall be housed
				  in weatherproof enclosures.
f. Any
				  wells within the area of review selected for the observation of water quality,
				  formation pressure, or any parameter, shall be monitored at a frequency
				  sufficient to protect USDWs.
g.
				  Mechanical integrity shall be demonstrated and reported according to the
				  procedures, and at the frequency, specified in §109. A 9
8. Reporting Requirements
a. Quarterly Reports to the Commissioner
i. This report shall include:
(a). the physical, chemical, and other
				  relevant characteristics of the injection stream;
(b). monthly average, maximum, and minimum
				  values for injection pressure, flow rate and volume, cumulative volume, and
				  annular pressure;
(c). the results
				  of any mechanical integrity tests performed during the quarter;
(d). the results of any other well test
				  performed during the quarter;
(e).
				  the results of monitoring prescribed in §109. A.7 f; and
(f). the results of any well workover
				  performed during the quarter including minor well maintenance.
ii. This report shall be filed
				  four times a year within 30 days after the quarter end and if not received as
				  required, the commissioner may commence appropriate enforcement
				  action.
b. Workover
				  Reports
i. Notification of Workover. The
				  permittee shall notify the commissioner by telephone at (225) 342-5515 before
				  commencing any workover operation which requires the use of a rig. In addition,
				  the operator must obtain a work permit prior to any workover operation such as
				  plug and abandon, deepen, perforate, squeeze, plugback, side-track, pull
				  casing, pull tubing, or change zone of completion (disposal).
ii. Completed Workover Report. The first
				  quarterly report after the completion of a workover shall include the reason
				  for the well workover and the details of all work performed.
iii. Bottom Hole Pressure Report. During
				  major workovers, the bottom hole pressure shall be determined either by direct
				  measurement by conventional techniques or by calculation using specific gravity
				  of fluid in the well bore and the static fluid level as specified by the
				  commissioner.
9. Mechanical Integrity Testing
a. Mechanical integrity of Class I injection
				  wells shall be defined as:
i. no significant
				  leak(s) in the casing, tubing or packer; and
ii. no significant fluid movement into an
				  underground source of drinking water through vertical channels adjacent to the
				  injection well bore.
b.
				  One of the following tests must be used to demonstrate the absence of
				  significant leaks in §109. A.9.a.i above:
i. a fluid pressure test of the annular space
				  witnessed by an Office of Conservation representative; or
ii. review of the continuous monitoring
				  records required in §109. A.7 by an Office of Conservation
				  representative.
c. One
				  of the following tests may be used to demonstrate absence of significant
				  vertical fluid movement in §109. A.9.a ii above:
i. radioactive tracer survey;
ii. high resolution temperature
				  survey;
iii. audio Log;
				  and/or
iv. other test accepted by
				  the industry may be allowed with prior written approval from the
				  commissioner.
d.
				  Frequency of Mechanical Integrity Tests
i.
				  Mechanical integrity tests under §109. A.9.b shall be performed on an
				  alternative basis unless otherwise ordered by the commissioner or his
				  representative. The frequency of this mechanical integrity testing shall be
				  quarterly for commercial Class I wells and semiannually for on-site Class I
				  wells.
ii. For new wells,
				  mechanical integrity tests under §109. A.9.c shall be performed annually
				  during the first two years of the well permit period and no less than once
				  every five years thereafter. For existing wells, mechanical integrity tests
				  under §109. A.9.c shall be performed at the time of repermitting and no
				  less than once every five years thereafter.
e. The commissioner or his representative
				  reserves the right to specifically require more frequent integrity testing as
				  well as the right to specify the method of testing in specific
				  instances.
f. Except during
				  workovers or routine maintenance, any well which is not operational shall
				  conform to the mechanical integrity requirements of this Section and shall
				  sustain a positive pressure on the annulus during the period of non-use. When
				  an operator plans to take a well out of operation, he shall submit a plan to
				  the commissioner to assure the mechanical integrity of the well during non-use.
				  If a well cannot meet the mechanical integrity requirements of this Section,
				  the operator shall submit a plan to the commissioner within 30 days of the
				  test, to properly bring the facility into compliance. If a plan is not
				  submitted within 30 days or if the plan is considered inadequate, the operator
				  will be given six months to plug and abandon the well as required in §109.
				  A 10.
10. Plugging and
				  Abandonment
a. Prior to plugging and
				  abandoning a Class I well, the permittee shall submit to the commissioner a
				  plan of plugging and abandonment which will include location, depth of plugs,
				  type of cement and the general procedure for plugging. After receipt of this
				  information, the commissioner may approve, modify or deny the plan of
				  abandonment; the commissioner additionally may require the applicant to revise
				  the plan.
b. Any Class I permit
				  shall include conditions to ensure that plugging and abandonment of the well
				  will not allow the movement of fluids either into an underground source of
				  drinking water or from one USDW to another.
11. Recordkeeping Requirements
a. The permittee shall keep complete and
				  accurate records of:
i. all monitoring
				  required by the permit, including:
(a).
				  continuous records of surface injection pressures;
(b). continuous records of the tubing-long
				  string annulus pressures;
(c).
				  continuous records of injection flow rates; and
(d). monthly total volume of injected
				  fluids.
ii. all periodic
				  well tests, including but not limited to:
(a).
				  injection fluid analyses;
(b).
				  bottom hole pressure determinations; and
(c). mechanical integrity.
b. The permittee shall
				  retain records of all information resulting from any monitoring activities for
				  a period of at least three years from the date of the sample or measurement.
				  This period may be extended by request of the commissioner at any
				  time.
c. In addition to Paragraph
				  11.b above, the permittee shall retain all records concerning the nature,
				  composition, and volume of injected fluids until three years after completion
				  of any plugging and abandonment procedures. The commissioner may require the
				  owner or operator to deliver the records to the Office of Conservation at the
				  conclusion of the retention period.
d. All records shall be made available for
				  review upon request from a representative of the commissioner.
12. Waiver of Requirements
a. When injection does not occur into,
				  through, or above an underground source of drinking water, the commissioner may
				  authorize a Class I well with less stringent requirements for area of review,
				  construction, mechanical integrity, operation, monitoring and reporting than
				  required in this Section, to the extent that the reduction in requirements will
				  not result in an increased risk of movement of fluids into a USDW.
b. When reducing requirements under this
				  Section, the commissioner shall issue an order explaining the reasons for the
				  action.
13. Additional
				  Requirements. The commissioner may prescribe additional requirements for Class
				  I wells in order to protect underground sources of drinking water.