Kansas Administrative Regulations
Agency 28 - DEPARTMENT OF HEALTH AND ENVIRONMENT
Article 45a - UNDERGROUND NATURAL GAS STORAGE WELLS IN BEDDED SALT
Section 28-45a-13 - Monitoring

Universal Citation: KS Admin Regs 28-45a-13

Current through Register Vol. 43, No. 12, March 20, 2024

(a) Each permittee shall ensure that each underground natural gas storage well is equipped with pressure sensors to continuously monitor wellhead pressures on the product line at the wellhead. The following requirements shall apply:

(1) The pressure sensor shall be capable of recording the maximum and minimum operating pressures during a 24-hour period.

(2) The pressure sensor shall be capable of recording operating pressures at an interval approved by the secretary.

(3) The permittee shall provide pressure data, including historic continuous monitoring, to the secretary upon request.

(b) Each permittee shall submit a plan for any monitoring activity, including logging and sonar surveys, to the secretary for review and consideration for approval to ensure the protection of public health, safety, and the environment, at least 60 days before the commencement of these monitoring activities.

(c) Each permittee shall submit a summary and the results of the monitoring activity to the secretary within 30 days after completion of the monitoring activity.

(d) Each permittee shall monitor the thickness of the salt roof for each cavern with gamma ray and density logs or other log specified in K.A.R. 28-45a-4 (k) as follows:

(1) Every five years;

(2) at any time that the secretary determines that cavern integrity is suspect; and

(3) before plugging the well.

(e) Each permittee shall determine the cavern storage capacity and the cavern geometry with a sonar survey. The sonar survey shall be conducted as follows:

(1) Before placing the natural gas storage cavern in service;

(2) for determining the capacity of the natural gas storage cavern, if the capacity determined by the volume of gas injected into and withdrawn from the storage cavern does not correspond with the reported cavern capacity;

(3) before plugging the well, if a sonar survey has not been run in the past five years;

(4) for determining the stability of the cavern and the overburden, if the salt roof thickness and cavern geometry indicate that the stability of the cavern or overburden is at risk; and

(5) after any solutioning that results in a solution volume increase of 20 percent or more of cavern capacity.

(f) Any permittee may use an alternative method for the sonar survey if the secretary determines that the alternative method is substantially equivalent to the method specified in subsection (e). The permittee shall submit the following information:

(1) A description of the proposed method and the theory for its operation;

(2) a description of the storage well and cavern conditions under which the log can be used;

(3) the procedure for interpreting the survey results; and

(4) an interpretation of the capacity and stability of the cavern upon completion of the survey.

(g) Each permittee of an underground natural gas storage well equipped with a production casing and a tubing and packer assembly shall monitor the annular space. Each permittee shall submit the following to the secretary for review and consideration for approval:

(1) A diagram of the well construction; and

(2) a plan for monitoring the annulus that includes the following:
(A) A diagram of the instrumentation for monitoring the annular pressure and fluid levels;

(B) a description of how the annular pressure and fluid levels will be recorded; and

(C) a description of, and justification for, the testing methods to demonstrate the mechanical integrity of the system.

(h) Each permittee shall submit a survey plan for monitoring ground subsidence, with the permit application, to the secretary for review and consideration for approval.

(1) The survey plan shall include the following information:
(A) A description of the method for conducting the elevation survey; and

(B) the criteria for establishing monuments, benchmarks, and wellhead survey points.

(2) The criteria for subsidence monitoring shall be the following:
(A) Level measurements to the accuracy of 0.01 foot shall be made.

(B) Surface elevation changes in excess of 0.10 foot shall be reported within 24 hours to the department.

(C) No established benchmark shall be changed unless the permittee submits a justification that the change is protective of public health, safety, and the environment.

(D) If a benchmark is changed, the elevation change from the previous benchmark shall be noted in the elevation survey report.

(E) Each permittee shall submit the elevation before and after any wellhead work that results in a change in the survey point at the wellhead.

(3) The survey shall be conducted by a licensed professional land surveyor.

(4) Biennial survey results, including certified and stamped field notes, shall be submitted to the department within 30 days after completion of the survey.

(i) Each permittee shall submit an inventory balance plan for measuring the volume of natural gas injected or withdrawn from each underground natural gas storage well, including methods for measuring and verifying volume, to the secretary for review and consideration for approval.

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