Current through Register Vol. 50, No. 9, September 20, 2024
A.
Closure. The owner or operator shall close the salt cavern well, salt cavern,
surface facility or parts thereof as approved by the Office of Conservation.
Closure shall not begin without written authorization from the Office of
Conservation.
1. Closure Plan. Plans for
closure of the salt cavern well, salt cavern, and related surface facility
shall be submitted as part of the permit application. The closure plan shall
meet the requirements of these rules and regulations and be acceptable to the
Office of Conservation. The obligation to implement the closure plan survives
the termination of a permit or the cessation of salt cavern waste disposal
operations or related activities. The requirement to maintain and implement an
approved plan is directly enforceable regardless of whether the requirement is
a condition of the permit. The Office of Conservation may modify a closure plan
where necessary.
2. Closure Plan
Requirements. The owner or operator shall review the closure plan annually to
determine if the conditions for closure are still applicable to the actual
conditions of the salt cavern well, salt cavern, or surface facility. Any
revision to the plan shall be submitted to the Office of Conservation for
approval. At a minimum, a closure plan shall address the following:
a. assurance of financial responsibility as
required in
§3109. B.1 All
instruments of financial responsibility shall be reviewed each year before its
renewal date according to the following process:
i. a detailed cost estimate for adequate
closure of the entire salt cavern waste disposal facility (salt cavern well,
salt cavern, surface appurtenances, etc.) shall be prepared by a qualified,
independent third party and submitted to the Office of Conservation by the date
specified in the permit;
ii. the
closure plan and cost estimate shall include provisions for closure acceptable
to the Office of Conservation and shall reflect the costs for the Office of
Conservation to complete the approved closure of the facility;
iii. after reviewing the closure cost
estimate, the Office of Conservation may increase, decrease or allow the amount
to remain the same;
iv.
documentation from the operator showing that the required financial instrument
has been renewed shall be received each year by the date specified in the
permit. When an operator is delinquent in submitting documentation of financial
instrument renewal, the Office of Conservation shall initiate procedures to
take possession of funds guaranteed by the financial instrument and suspend or
revoke the operating permit. Permit suspensions shall remain in effect until
renewal documentation is received and accepted by the Office of
Conservation;
b. a
prediction of the pressure build-up in the salt cavern following
closure;
c. an analysis of
potential pathways for leakage from the salt cavern, cemented casing shoe, and
wellbore. Consideration shall be given to site specific elements of geology,
waste characteristics, salt cavern geometry and depth, salt cavern pressure
build-up over time due to salt creep and other factors inherent to the salt
stock and/or salt dome;
d.
procedures for determining the mechanical integrity of the salt cavern well and
salt cavern before closure;
e.
removal and proper disposal of any waste or other materials remaining at the
facility;
f. closing, dismantling,
and removing all equipment and structures located at the surface (including
site restoration) if such equipment and structures will not be used for another
purpose at the same disposal facility;
g. the type, number, and placement of each
wellbore or salt cavern plug including the elevation of the top and bottom of
each plug and the method of placement of the plugs;
h. the type, grade, and quantity of material
to be used in plugging;
i. a
description of the amount, size, and location (by depth) of casing and any
other well construction materials to be left in the salt cavern well;
j. any proposed test or measurement to be
made before or during closure.
3. Notice of Intent to Close
a. The operator shall review the closure plan
before seeking authorization to begin closure activities to determine if the
conditions for closure are still relevant to the actual conditions of the salt
cavern well, salt cavern, or surface facility. Revisions to the method of
closure reflected in the plan shall be submitted to the Office of Conservation
for approval no later than the date on which the notice of closure is required
to be submitted as shown in the subparagraph below.
b. The operator shall notify the Office of
Conservation in writing at least 30 days before the expected closure of a salt
cavern well, salt cavern, or surface facility. Notification shall be by
submission of a request for a work permit. At the discretion of the Office of
Conservation, a shorter notice period may be allowed.
4. Standards for Closure. The following are
minimum standards for closing the salt cavern well or salt cavern. The Office
of Conservation may require additional standards prior to actual closure.
a. After permanently concluding waste
disposal operations into the salt cavern but before closing the salt cavern
well or salt cavern, the owner or operator shall:
i. observe and accurately record the shut-in
salt cavern pressures and salt cavern fluid volume for an appropriate time or a
time specified by the Office of Conservation to provide information regarding
the salt cavern's natural closure characteristics and any resulting pressure
buildup;
ii. using actual
pre-closure monitoring data, show and provide predictions that closing the salt
cavern well or salt cavern as described in the closure plan will not result in
any pressure buildup within the salt cavern that could adversely effect the
integrity of the salt cavern well, salt cavern, or any seal of the
system.
b. Before
closure, the owner or operator shall do mechanical integrity pressure and leak
tests to ensure the integrity of both the salt cavern well and salt
cavern.
c. Before closure, the
owner or operator shall remove and properly dispose of any free oil or blanket
material remaining in the salt cavern well or salt cavern.
d. Upon permanent closure, the owner or
operator shall plug the salt cavern well with cement in a way that will not
allow the movement of fluids into or between underground sources of drinking
water or outside the salt stock. Placement of cement plugs shall be
accomplished by using standard petroleum industry practices for downhole well
abandonment. Each plug shall be appropriately tagged and pressure tested for
seal and stability before closure is completed.
e. Upon successful completion of the closure,
the owner or operator shall identify the surface location of the abandoned well
with a permanent marker inscribed with the operator's name, well name and
number, serial number, section-township-range, date plugged and abandoned, and
acknowledgment that the well and salt cavern were used for disposal of E&P
waste.
5. Closure
Report. The owner or operator shall submit a closure report to the Office of
Conservation within 30 days after closure of the salt cavern well, salt cavern,
surface facility, or part thereof. The report shall be certified as accurate by
the owner or operator and by the person charged with overseeing the closure
operation (if other than the owner or operator). The report shall contain the
following information:
a. detailed procedures
of the closure operation. Where actual closure differed from the plan
previously approved, the report shall include a written statement specifying
the differences between the previous plan and the actual closure;
b. all state regulatory reporting forms
relating to the closure activity; and
c. any information pertinent to the closure
activity including test or monitoring data.
B. Post-Closure. Plans for post-closure care
of the salt cavern well, salt cavern, and related surface facility shall be
submitted as part of the permit application. The post-closure plan shall meet
the requirements of these rules and regulations and be acceptable to the Office
of Conservation. The obligation to implement the post-closure plan survives the
termination of a permit or the cessation of salt cavern waste disposal
operations or related activities. The requirement to maintain and implement an
approved post-closure plan is directly enforceable regardless of whether the
requirement is a condition of the permit. The Office of Conservation may modify
a post-closure plan where necessary.
1. The
owner or operator shall review the post-closure plan annually to determine if
the conditions for post-closure are still applicable to actual conditions. Any
revision to the plan shall be submitted to the Office of Conservation for
approval. At a minimum, a post-closure plan shall address the following:
a. assurance of financial responsibility as
required in
§3109. B.1 All
instruments of financial responsibility shall be reviewed each year before its
renewal date according to the following process:
i. a detailed cost estimate for adequate
post-closure care of the entire salt cavern waste disposal facility shall be
prepared by a qualified, independent third party and submitted to the Office of
Conservation by the date specified in the permit;
ii. the post-closure care plan and cost
estimate shall include provisions acceptable to the Office of Conservation and
shall reflect the costs for the Office of Conservation to complete the approved
post-closure care of the facility;
iii. after reviewing the post-closure cost
estimate, the Office of Conservation may increase, decrease or allow the amount
to remain the same;
iv.
documentation from the operator showing that the required financial instrument
has been renewed must be received each year by the date specified in the
permit. When an operator is delinquent in submitting documentation of financial
instrument renewal, the Office of Conservation shall initiate procedures to
take possession of the funds guaranteed by the financial instrument and suspend
or revoke the operating permit. Any permit suspension shall remain in effect
until renewal documentation is received and accepted by the Office of
Conservation;
b. any
plans for monitoring, corrective action, site remediation, site restoration,
etc., as may be necessary.
2. Where necessary and as an ongoing part of
post-closure care, the owner or operator shall continue the following
activities:
a. complete any corrective action
or site remediation resulting from the operation of a salt cavern waste
disposal facility;
b. conduct any
groundwater monitoring or subsidence monitoring required by the permit until
pressure in the salt cavern displays a trend of behavior that can be shown to
pose no threat to salt cavern integrity, underground sources of drinking water,
or other natural resources of the state;
c. complete any site restoration.
3. The owner or operator shall
retain all records as required in
§3139 for five years following
conclusion of post-closure requirements.
AUTHORITY NOTE:
Promulgated in accordance with
R.S.
30:4 et
seq.