Current through Register Vol. 50, No. 9, September 20, 2024
A. Applicability. The regulations in this
Section shall apply to all onsite or offsite Class II injection wells which
inject RCRA exempt E and P Waste at pressures which exceed the fracture
pressure of the injection interval.
Confining Zone- the impermeable geologic
formation that is located below the base of the USDW and which directly
overlies and is contiguous with the injection zone.
Containment Zone-the geologic formation or
formations intended to serve as a barrier to fracture height growth, but
allowed to be partially penetrated by fractures created during authorized
injection. The containment zone directly overlies and is contiguous with the
injection interval.
Injection Interval-the geological
formation targeted to receive the injected fluids. This interval is contained
within the injection zone.
Injection Zone-that group of geologic
formations which extend from the bottom of the lowermost injection interval to
the top of the containment zone.
Slurry Fracture Injection-a process by
which solid waste is ground, if necessary, and mixed with water or another
liquid. The resulting slurry is then deposited into fractures created in the
receiving formation by the hydraulic force of injection.
Source Water Protection Area-the surface
and subsurface area surrounding a source of drinking water (a water well, a
well field, or a surface intake), supplying a public water system, through
which contaminants are reasonably likely to move toward and reach the source of
drinking water. The Source Water Protection Program is under the jurisdiction
of the Louisiana Department of Health and Hospitals and the Louisiana
Department of Environmental Quality.
Zone of Endangering Influence-a defined
area around an injection well, the radius of which is the lateral distance for
which the pressures in the injection interval(s) may cause the vertical
migration of injection and/or formation fluid out of the injection zone.
C. Application Requirements for Slurry
Fracture Injection Wells
1. Each application
for approval of a new slurry fracture injection well shall be filed on Form
UIC-2 SFI (or latest revision) and shall be developed under the supervision of
person(s) knowledgeable in all phases of slurry fracture injection permit
application preparation. The original, signed by the operator, and one copy of
the application with two complete sets of attachments shall be furnished to the
commissioner.
2. The application
for approval of a slurry fracture injection well shall be accompanied by:
a. a completed Form UIC-2 SFI (or latest
revision);
b. a completed Form
MD-10-R (or latest revision);
c. a
map showing the disposal well for which a permit is sought, the Area of Review
(AOR), and the following information:
i. the
number or name and location of all existing producing wells, injection wells,
abandoned wells, and dry holes within the AOR;
ii. identification of the surface owner of
the land on which disposal is to be located within the AOR;
iii. identification of each operator with a
producing leasehold within the AOR;
iv. surface bodies of water, mines (surface
and subsurface), quarries, water wells (public and private), public water
systems, and other pertinent surface features including residences and
roads;
d. a schematic of
the well showing:
i. the total depth, drilled
out depth or plugged back depth of the well;
ii. the depth of the top and bottom of the
perforated interval;
iii. the size
of the casing, borehole and tubing, and the depth of the packer and bottom hole
pressure sensor;
iv. the depths of
the tops and bottoms of the casings and the amounts, formulation, and yields of
the cement slurries used to cement each string of casing;
v. the depth of the base of the
USDW;
vi. the depths of the tops
and bottoms of the injection interval, the containment zone, the injection
zone, and confining zone;
e. if the well has been drilled, a copy of
the Well History and Work Resume Report (WH-1) and an electric log of the well.
In the case of undrilled wells, a descriptive statement of the proposed
injection interval giving its approximate depth, along with an electric log or
radioactivity log of a nearby well, if available;
f. maps and cross sections that detail the
local geology and hydrology. All maps shall be constructed on a 1:2000 scale
and contain a legend and a north arrow. All control points and fault cuts shall
be shown on all cross sections. At a minimum, the following maps and cross
sections shall be submitted:
i. isopach maps
of the injection interval or intervals, the containment zones, and the
confining zone;
ii. a structure map
of the top of the injection zone and confining zone;
iii. two structural cross sections
transecting the AOR and extending from below the base of the injection zone to
above the base of the USDW. The cross sections shall be at approximate right
angles and extend beyond the limits of the AOR;
iv. a regional map contoured on the base of
the USDW;
v. a map of all fault
planes within the AOR;
vi. any
other information required by the commissioner;
g. a tabulation of data on all wells that
penetrate the proposed confining zone. Such data shall include a description of
each well's type, construction, date drilled, location, depth, record of
plugging and/or completion, and any additional information the commissioner may
require;
h. a tabulation of all
freshwater wells of record within the AOR. Each freshwater well shall be
identified by owner, type of well, depth and current status of the well.
Include a laboratory analysis for pH, chloride (mg/l) and total dissolved
solids (mg/l) of a water sample from each freshwater well. A DEQ certified
laboratory must perform the required analyses. As deemed appropriate,
additional test parameters may be required by the commissioner;
i. the following proposed operating data
shall be submitted as part of the operator's application:
i. the average and maximum daily rate and
volume of slurry to be injected;
ii. the average and maximum injection
pressure;
iii. the proposed
injection procedures (including storage and pre-injection treatment of the
waste stream, and the well use schedule);
j. schematic or other appropriate drawings of
the surface (well head and related appurtenances) and subsurface construction
details of the system;
k.
construction procedures including cementing and casing program, logging
procedures, deviation checks, and a drilling, testing and coring
program;
l. description of the
bottom hole pressure sensor required in
§433. G 4, which
includes installation procedures and equipment specifications;
m. detailed discussion of the logging and
testing programs required in
§433 H;
n. a detailed description of the monitoring
program proposed in order to meet the requirements of
§433. I and if
applicable,
§433. E 4;
o. contingency plans to cope with all
shut-ins or well failures so as to prevent the migration of fluids out of the
injection zone;
p. for wells within
the AOR (as defined in
§433. D) which penetrate
the proposed confining zone, but are not properly completed or plugged, the
proposed corrective action to be taken under
§433 F;
q. any additional information necessary to
demonstrate that injection into the proposed injection interval or intervals
will not initiate fractures in the confining zone that could allow fluid
movement out of the injection zone, pursuant to
§433 BConfining
Zone.
r. any other
information required by the commissioner to evaluate the proposed
well.
3. Unless the
application is for a commercial slurry fracture injection well and subject to
the public notice requirements of
§519. A and §529, all
applications for slurry fracture injection must be advertised at least once by
the applicant in a format acceptable to the commissioner in the official state
journal, in the official journal of the affected parish and in the journal of
general circulation in the area where the proposed well is to be located, if
different from the official parish journal. Interested parties shall have at
least 15 days to provide comments and/or request a hearing.
4. Unless the application is for a commercial
slurry fracture injection well and subject to the provisions for adequate
closure in
§519. C 14, all
applications for slurry fracture injection wells shall contain a closure plan
cost estimate in a format acceptable to the commissioner. If the well is
permitted, the applicant shall provide a bond, letter of credit, certificates
of deposit issued by and drawn on Louisiana banks, or any other evidence of
equivalent financial security acceptable to the commissioner. The amount of
financial security will be determined upon review of the closure cost estimate
and will be reviewed annually.
D. Area of Review (AOR). The AOR for each
slurry fracture injection well shall be the greater of the two following
methods:
1. calculation of the zone of
endangering influence, which is that area the radius of which is the lateral
distance for which the pressures in the injection interval(s) may cause
vertical migration of the injection and/or formation fluid out of the injection
zone. The zone of endangering influence shall be calculated using an acceptable
model designed for this purpose; or
2. a fixed radius of 2 miles from the
injection well.
E.
Geologic Criteria of the Injection and Confining Zones
1. A confining zone which is impermeable and
laterally continuous throughout the injection well's AOR shall immediately
overlie the containment zone. The confining zone is to have a minimum thickness
of 50 feet and be capable of preventing any upward fluid movement from the
injection zone. Therefore, applicants/operators of SFI wells must provide
information showing that injection into the injection zone will not initiate
fracturing of the confining zone or the extension of existing fractures into
the confining zone.
2. A
containment zone may consist of either a single impermeable layer with a
minimum thickness of 500 feet, or be comprised of alternating impermeable and
permeable layers with a net thickness of impermeable strata of at least 500
feet.
3. The injection zone and
confining zone shall be free of any fault planes or other geological
discontinuities which could serve to transmit the injected waste out of the
injection zone. The area is to be adequately mapped with sufficient controls
and resolution to identify these geologic discontinuities.
4. If the AOR lacks adequate well control
points to map the geologic features of the injection, containment, and
confining zones, seismic surveys with acceptable interpretation shall be
required encompassing an area inclusive of the AOR plus an additional one mile
in order to acquire the necessary information needed to verify that injected
waste will not migrate out of the injection zone. If seismic data is inadequate
for this purpose, the commissioner shall require the operator to implement a
suitable monitoring program capable of tracking the lateral and vertical
extension of fractures caused by injection and to detect possible movement of
fluids out of the containment zone. Such monitoring programs may incorporate
the use of monitor wells, surface and subsurface tiltmeters, microseismic
monitoring techniques, logging programs, or other technologies suitable for
this purpose and which are acceptable to the commissioner.
F. Corrective Action. Applicants shall
identify all known wells within the injection well's AOR which penetrate the
confining zone. For 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 the movement of fluid out of the
injection zone (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
applicant's plan is inadequate, the commissioner shall require the applicant to
revise the plan, prescribe a plan for corrective action as part of the permit,
or deny the application. No owner or operator of a well may begin injection
until all required corrective action has been taken.
G. Construction Requirements
1. Siting. All slurry fracture injection
wells shall be sited in such a fashion that they inject into a formation which
is beneath the lower most formation containing a USDW within a 2 mile radius of
the well bore and meets the geologic criteria of the injection zone and
confining zone prescribed in
§433. E above. Location
of a slurry fracture injection well so that its AOR extends into a Source Water
Protection Area is prohibited.
2.
Casing and Cementing. All slurry fracture injection wells shall be cased and
cemented in accordance with the following criteria.
a. The operator shall install casing
necessary to withstand collapse, bursting, tensile, and other stresses and
shall be cemented in a manner which will anchor and support the casing. Safety
factors in casing program design shall be of sufficient magnitude to provide
optimum well control while drilling and to assure safe operations for the life
of the well. New pipe or used pipe reconditioned and tested to assure that it
will meet or exceed American Petroleum Institute (API) standards for new pipe
shall be used in all casing strings.
b. Surface casing and long string casing
strings shall be centralized by means of a sufficient number of centralizers
spaced in a manner as to provide proper centralization of the casing string in
the borehole prior to cementing.
c.
Surface casing shall be set a minimum of 100 feet below the base of the USDW
and cemented to surface. Cemented to surface shall be considered in this
Section as having actual cement returns noted at the surface. If cement returns
are not observed, the operator shall contact the Injection and Mining Division
and obtain approval for the procedures to be used to perform any required
additional cementing operations.
d.
Cement shall be allowed to stand a minimum of 12 hours under pressure before
initiating pressure test or drilling plug. Under pressure is complied with if
one float valve is used or if pressure is held otherwise.
e. A minimum of 12 hours prior notification
shall be given to the appropriate Injection and Mining Division Conservation
Enforcement Agent for the purpose of witnessing all required casing pressure
tests. If the Conservation Enforcement Agent fails to appear within the 12-hour
notification period, the operator may proceed with the pressure test and file
an affidavit of casing test (Form Csg-T) with the Injection and Mining Division
within 20 days of reaching total depth.
f. Surface casing shall be tested at a
surface pressure not less than the test pressure required in
§109. B (or successor
regulations). If at the end of 30 minutes the pressure gauge shows a drop in
excess of 5 percent of test pressure, the operator shall be required to take
such corrective measures as will ensure that such surface casing will hold said
pressure for 30 minutes without a drop of more than 5 percent of the test
pressure.
g. Long string casing
shall be set through the injection zone and cemented at least to the top of the
confining zone.
3. All
slurry fracture injection wells shall be equipped with injection tubing and a
packer. The packer shall be set in the long string casing no higher than 150
feet above the perforated interval.
4. The well shall be equipped with a
down-hole sensor that directly measures the fluid pressure at depth no higher
than 50 feet above the packer setting depth. The pressure sensor must be
connected to a device at the surface which will enable a continuous recording
of the well's bottom hole pressure information in digital format.
H. Logging and Testing
Requirements. In addition to conformance with the logging and testing criteria
contained in LAC 43:XIX.419.A or successor regulations, slurry fracture
injection wells shall meet the following logging and testing requirements.
1. Open Hole Logging Requirements: A
neutron/density porosity log of the injection and confining zone is required.
An induction log shall be run to determine salinity levels. A spectral gamma
ray log shall be run to determine baseline lithology of the subsurface prior to
injection. All logs are to be run from surface to at least 50 feet below the
injection zone.
2. Acoustic Logging
Requirements: On a well that is to be completed with the intent for it to be
used for slurry fracture injection, acoustic logs shall be required. An open
hole acoustic log showing acoustic porosity and formation travel time shall be
run from the surface to at least 50 feet below the injection zone. A synthetic
seismogram is required to be submitted in order to predict fracture parameters
and as a link to subsequent seismic interpretation (time based or four
dimensional). VSP (Vertical Seismic Profiling) shall be run for lateral effect.
Acoustic data may be run in various formats to identify reservoir and fracture
parameters and to show containment of the waste stream within the containment
and injection zones. The various formats may be surface-to-surface, well to
surface, cross well, 2-dimensional, 3-dimensional and 4-dimensional data. All
monitor wells shall be used for lateral offset of the VSP and the depth of
investigation must match the dimensions of the disposal domain. Acoustic data
must be obtained pre-injection, during injection and post-injection (after
disposal operations cease and prior to plugging and abandoning the well) in
order to show long term containment.
3. Cement Bond Logging Requirements
a. At the time of the initial completion,
after long-string casing (to below the injection zone) has been set and
cemented, a suitable, interpretable cement quality (bond) log shall be run. In
an existing well, the tubing must be pulled and a suitable cement quality log
run prior to permit approval. The log is to be run from surface to 50 feet
below the base of the injection zone. The log must define both vertical and
lateral cement quality.
b. The log
is to have sufficient vertical, horizontal and radial resolution to identify
the location of cement channels, micro-channels, bonding index, gas cut cement,
voids or any other cement/bond problem that may exist. The log must show
transit time, amplitude, variable density and radial bond quality (from
interpretation). Log quality control must show cement type, additives, setting
time and compressive strength (used in variable density log generation), proper
tool centering, proper casing centering and sufficient cement sheath thickness,
borehole fluids type, density, viscosity, pressure and temperature. In deviated
wellbores, for adequate interpretation, effective tool centering must be seen.
Matching casing size and weight must be correct on all interpretations. Where
possible, the log must be correlated to shape and rugosity of the borehole
(from open hole caliper and porosity/lithology logs). The log must also show
line weight, line speed, casing collar locator and gamma ray for depth
correlation.
c. A repeat section,
showing good repeatability, must be run from the base of the injection zone to
the base of the confining zone. Wellsite and shop tool calibrations are to be
included on all logs.
4.
A temperature and gamma ray base log shall be run prior to the initiation of
any fractures. Subsequent radioactive tracer or temperature logs are to be run
using a method approved by the Injection and Mining Division.
5. The operator shall conduct a step
rate/pressure falloff test on the injection well prior to the initiation of
injection operations in order to establish the initial fracture closure and
extension pressures of the injection interval.
6. A pressure falloff test shall be performed
on the well prior to the initiation of any fracturing in order to establish the
reservoir transmissivity. The Injection and Mining Division shall be consulted
on the procedure for running this test.
7. An extended falloff shall be conducted at
least once every 7-day cyclic injection period. The falloff period shall be
maintained until the measured pressure has essentially stabilized.
8. The logging requirements for existing
wells converted to slurry fracture injection are the same as those required for
newly drilled wells.
9. Any other
well logs or tests required by the commissioner.
I. Monitoring Requirements
1. A monitoring program that ensures that the
injection activity does not cause the migration of fluids above the confining
zone shall be approved by the commissioner. This monitoring program may be
inclusive of or in addition to the monitoring program required in
§433. E 4
2. All approved monitoring programs shall
include the continuous monitoring and recording of bottom hole pressures,
injection rates, the tubing and casing annulus pressure, injected fluid density
and the cumulative volume of waste injected using a method approved by the
commissioner. The origination, type and components of all injected waste
streams are to be recorded and made available when requested.
3. The operator shall analyze the bottom hole
pressure data daily to ensure that the pressure in the injection interval is
not becoming abnormally pressurized as a result of injection. Also, abnormal
extrapolated pressures (net losses) that cannot be associated with the
injection volumes must be investigated immediately to ensure that fluids are
not migrating out of the injection zone. Depending on the injected volumes, the
formation pressure log must be history matched to predicted
pressures.
4. Fracture height and
length shall be evaluated by the operator on a minimum three month rotation, or
as directed by the commissioner, utilizing a method approved by the
commissioner.
5. The operator shall
conduct periodic step-rate tests at least every three months. The commissioner
may require more frequent step-rate tests in order to evaluate changes in
formation parting pressures and in-situ stress conditions.
6. A cement bond log having the same
presentation as the initial cement bond log shall be run annually to evaluate
the effects of the previous years injection on the cement column. If it is
evident that the cement bonding is losing integrity, injection will be
prohibited until such time the integrity of the cement column is
restored.
J. Operational
Requirements
1. Based on the results of the
step rate/pressure falloff test outlined in
§433. H.5 above, the
maximum and minimum injection pressures and corresponding injection rates will
be determined. Using the fracture extension pressure derived from the step rate
test, the minimum allowed bottom hole injection pressure shall be assigned a
value of 150 psi below the extension pressure. The maximum allowed bottom hole
injection pressure shall be no greater than 75 percent of the burst pressure of
the casing.
2. The initial maximum
authorized injection rate (at the start up of operations) shall be limited to
no more than 20 percent over the rate required to maintain fracture extension
pressure. However, if the operator can demonstrate conclusively that a higher
injection rate will not cause excessive fracture growth, a higher injection
rate may be authorized by the commissioner. If an increase in injection rate is
authorized, the maximum and minimum bottom hole injection pressures shall be
adjusted accordingly.
3. If at any
time the bottom hole injection pressure or injection rate varies from the
authorized range, the operator shall immediately cease injection and notify the
Injection and Mining Division.
4.
Should any of the periodic step rate/pressure fall off tests indicate a change
in parting pressures or fracture extension pressures has occurred, the
commissioner shall have to option to amend the well's minimum and maximum
bottom hole injection pressures and maximum allowed injection rate or to
require that the well cease injection until such time that the operator has
proven that fluids are not migrating above the containment zone.
5. If monitoring indicates possible
communication between the tubing and the tubing and casing annulus, the
operator shall immediately cease injection and notify the Injection and Mining
Division. Injection may not commence until the mechanical integrity of the well
is restored and verified by the Injection and Mining Division.
6. Injection is to be conducted on a cyclic
basis.
7. If in the commissioner's
determination, over- pressurization of the reservoir may cause the movement of
fluid out of the injection zone, the commissioner shall suspend or revoke the
well's permit to inject. Also, if the average reservoir pressure is subjected
to any net decrease in pressure, the commissioner may suspend the well's permit
until such threat is resolved.
K. Reporting Requirements
1. The operator shall maintain daily records
for the following:
a. the bottom hole pressure
at the start of injection;
b. the
minimum and maximum injection pressures;
c. the injection rates at one hour
intervals;
d. the composition of
injected waste stream (random sampling) on a daily or batch basis;
e. the densities and viscosities of the waste
stream at one hour intervals of injection;
f. the minimum and maximum pressures on the
casing and tubing annulus.
2. In addition, the operator shall provide an
explanation for any discrepancies in the bottomhole or surface pressures,
densities, viscosities and injection rates in a comments column. If an
acceptable explanation for any discrepancy in this data is not provided, the
commissioner may suspend the well's permit to inject until the operator
provides this information.
3. This
information, in addition to that required under
§433. I.2 above, shall
be maintained as a permanent record in the operator's files and shall be
provided to the Injection and Mining Division upon request.
4. The operator shall provide to the
Injection Mining Division weekly summary reports of:
a. the minimum and maximum pressures recorded
during injection;
b. the minimum
and maximum pressures recorded during falloffs;
c. the minimum and maximum pressures on the
casing and tubing annulus;
d. the
daily and weekly injected volumes;
e. the average density and viscosity of
injected waste stream.
5. The operator shall provide the Injection
and Mining Division each by no later than the third working day of each week
the results of an analysis of all extended falloff periods occurring during the
previous week's reporting period. Each analysis report shall include a log-log
derivative plot of the falloff period with the different flow regimes
identified thereon. A comprehensive analysis of the linear and radial flow
regimes is required if present. A summary of the properties of the injected
fluids used in the analysis and the injection rates observed during each
injection period must be included in the report, in addition to any other
information which may be pertinent to the results of the falloff
analysis.
6. The operator shall
provide a diskette or compact disk of the well's continuous bottom hole
pressure and rate data for the reporting period in a format specified by the
commissioner.
7. In addition, the
operator shall provide an explanation for any discrepancies in the bottomhole
or surface pressures, densities, viscosities and injection rates in a comments
column of the report. If an acceptable explanation for any discrepancy in this
data is not provided, the commissioner may suspend the well's permit to inject
until the operator provides this information.
8. All records required in this Section shall
be maintained by the operator for the life of the well and shall be made
available for review or submitted to the Office of Conservation upon
request.
L. Permitting
Requirements
1. Applicants and applications
for slurry fracture injection wells must comply with the applicable public
notice requirements of this Chapter.
2. Applications for slurry fracture injection
of E and P Waste shall comply with the following two-part permitting
procedures:
a. Part I-Permit to Construct
i. The initial application shall be reviewed
for completeness, processed and upon meeting the permit requirements, a "Permit
to Construct" shall be issued.
ii.
"Permit to Construct" shall become null and void one year from the date of
issuance.
iii. The commissioner may
grant a one year extension from mitigating circumstances.
b. Part II-Permit to Inject
i. Upon completion of construction, the
documentation required by the "Permit to Construct" shall be submitted to the
Office of Conservation.
ii. If the
submitted documentation indicates compliance with the "Permit to Construct" and
that the well has been constructed as permitted and indicated in the
application, a "Permit to Inject" shall be issued.
3. Slurry fracture injection wells
permitted under the authority of this Section must comply with the applicable
general requirements, public notice requirements, work permit requirements,
legal permit conditions, permit transfer requirements, mechanical integrity
pressure testing requirements, confinement of fluid requirements, and plugging
and abandonment requirements of LAC 43:XIX.Chapter 4.
AUTHORITY NOTE:
Promulgated in accordance with
R.S.
30:4 et seq.