Louisiana Administrative Code › Title 43 - NATURAL RESOURCES › Part XVII - Office of Conservation-Injection and Mining › Subpart 6 - Statewide Order No. 29-N-6 › Chapter 6 - Class VI Injection Wells › Section XVII-625 - Testing and Monitoring

Current through Register Vol. 50, No. 6, June 20, 2024
A. Testing
				  and Monitoring Requirements. The owner or operator of a Class VI well must
				  prepare, maintain, and comply with a testing and monitoring plan to verify that
				  the geologic sequestration project is operating as permitted and is not
				  endangering USDWs. The requirement to maintain and implement an approved plan
				  is directly enforceable regardless of whether the requirement is a condition of
				  the permit. The testing and monitoring plan must be included with the permit
				  application and must include a description of how the owner or operator will
				  meet these requirements- including accessing sites for all necessary monitoring
				  and testing during the life of the project. Testing and monitoring associated
				  with geologic sequestration projects must include, at a minimum:
1. analysis of the carbon dioxide stream with
				  sufficient frequency to yield data representative of its chemical and physical
				  characteristics;
2. installation
				  and use of continuous recording devices to monitor injection pressure, rate,
				  and volume; the pressure on the tubing-casing annulus; and the annulus fluid
				  volume added. Continuous monitoring is not required during well workovers as
				  defined in §621.A 5;
3.
				  corrosion monitoring of the well materials for loss of mass, thickness,
				  cracking, pitting, and other signs of corrosion, which must be performed on a
				  quarterly basis to ensure that the well components meet the minimum standards
				  for material strength and performance set forth in §617.A 2, by:
a. analyzing coupons of the well construction
				  materials placed in contact with the carbon dioxide stream; or
b. routing the carbon dioxide stream through
				  a loop constructed with the material used in the well and inspecting the
				  materials in the loop; or
c. using
				  an alternative method approved by the commissioner;
4. periodic monitoring of the ground water
				  quality and geochemical changes above the confining zone(s) that may be a
				  result of carbon dioxide movement through the confining zone(s) or additional
				  identified zones including:
a. the location
				  and number of monitoring wells based on specific information about the geologic
				  sequestration project, including injection rate and volume, geology, the
				  presence of artificial penetrations, and other factors; and
b. the monitoring frequency and spatial
				  distribution of monitoring wells based on baseline geochemical data that has
				  been collected under §607.C.2.e and on any modeling results in the area of
				  review evaluation required by §615.B 3
5. a demonstration of external mechanical
				  integrity pursuant to §627.A.3 at least once every 12 months until the
				  injection well is permanently plugged and abandoned; and, if required by the
				  commissioner, a casing inspection log pursuant to requirements at §627.A.4 at a frequency established in the testing and monitoring plan;
6. a pressure fall-off test at least once
				  every five years unless more frequent testing is required by the commissioner
				  based on site-specific information;
7. testing and monitoring to track the extent
				  of the carbon dioxide plume and the presence or absence of elevated pressure
				  (e.g., the pressure front) by using:
a. direct
				  methods in the injection zone(s); and
b. indirect methods (e.g., seismic,
				  electrical, gravity, or electromagnetic surveys and/or down-hole carbon dioxide
				  detection tools), unless the commissioner determines that such methods are not
				  appropriate, based on site-specific geology;
8. The commissioner may require surface air
				  monitoring and/or soil gas monitoring to detect movement of carbon dioxide that
				  could endanger a USDW.
a. Design of Class VI
				  surface air and/or soil gas monitoring must be based on potential risks to
				  USDWs within the area of review;
b.
				  The monitoring frequency and spatial distribution of surface air monitoring
				  and/or soil gas monitoring must be decided using baseline data, and the
				  monitoring plan must describe how the proposed monitoring will yield useful
				  information on the area of review delineation and/or compliance with standards
				  under §603 D;
c. If an owner
				  or operator demonstrates that monitoring employed under
				  40 CFR
				  98.440 to
				  98.449 accomplishes
				  the goals of §625.A.8.a and b., and meets the requirements pursuant to
				  §629.A.1 v, a regulatory agency that requires surface air/soil gas
				  monitoring must approve the use of monitoring employed under
				  40 CFR
				  98.440 to
				  98.449. Compliance
				  with
				  40 CFR
				  98.440 to
				  98.449 pursuant to
				  this provision is considered a condition of the Class VI permit;
9. Any additional monitoring, as
				  required by the commissioner, necessary to support, upgrade, and improve
				  computational modeling of the area of review evaluation required under
				  §615.B.3 and to determine compliance with standards under
				  §619;
10. The owner or
				  operator shall periodically review the testing and monitoring plan to
				  incorporate monitoring data collected under §625, operational data
				  collected under §621, and the most recent area of review reevaluation
				  performed under §615.C.2 In no case shall the owner or operator review the
				  testing and monitoring plan less often than once every five years. Based on
				  this review, the owner or operator shall submit an amended testing and
				  monitoring plan or demonstrate to the commissioner that no amendment to the
				  testing and monitoring plan is needed. Any amendments to the testing and
				  monitoring plan must be approved by the commissioner, must be incorporated into
				  the permit, and are subject to the permit modification requirements at
				  §613, as appropriate. Amended plans or demonstrations shall be submitted
				  to the commissioner as follows:
a. within 12
				  months of an area of review reevaluation;
b. following any significant changes to the
				  facility, such as addition of monitoring wells or newly permitted injection
				  wells within the area of review, on a schedule determined by the commissioner;
				  or
c. when required by the
				  commissioner.
11. a
				  quality assurance and surveillance plan for all testing and monitoring
				  requirements.