CLASS Is, CLASS IIs, CLASS IIIs, & CLASS V

CLASS Is, CLASS IIs, CLASS IIIs, & CLASS V

Class I, Salt Cavern & Class V Wells Louisiana Department of Natural Resources Office of Conservation Injection and Mining Division CLASS I, SALT CAVERN & CLASS V Wells Statewide Order Permit Applicatio n Form Class I NonHazardous Waste Injection

Class I Hazardous Waste Injection Class II Hydrocarbo n Storage Class II E&P Waste Disposal in a Salt Cavern Class III 29-N-1

29-N-2 29-M 29-M-2 29-N-1 29-N1 LAC 43: XVII.10 3 Chapter 1 UIC-25 Solutio n

Mining LAC 43: XVII.103 Chapter 1 LAC 43: XVII.201 Chapter 2 LAC 43: XVII.301 Chapter 3 LAC 43: XVII.3101 Chapter 31 LAC 43:

XVII.103 Chapter 1 UIC-1 UIC-1 UIC-2 HSW UIC-43 UIC-3BR Class V The Application should only refer to the regulations of the specific Class of well for which you are applying.

Note: Class V wells will be discussed separately towards the end of the presentation. OVERVIEW OF WELL CLASS COMPARISONS OVERVIEW OF WELL CLASS COMPARISON S Statewide Order Three copies Financial Responsibility AOR radius Artificial penetrations Class I Class I

Class II Class III Class V Non-Haz Hazardous STORAGE SOLUTION MINING 29-N-1 29-N-2 29-M 29-N-1 29-N-1 a a a a n/a a a a a

n/a 2-Mile Fresh water wells 1/4 Mile WELL CONSTRUCTION Cemented casings min. 2 Tubings min. 1 Screens n/a a Packers LOGGING AND TESTING PROGRAMS a Logging Program a

Injectivity Tests a Cement Bonding greater of 2Mile or Cone of Influence 1/4 Mile 1/4 Mile 1/4 Mile 1/4 Mile 1/4 Mile 1/4 Mile

1/4 Mile min. 2 min. 1 n/a min. 2 min. 1 n/a n/a min. 2 min. 2 n/a n/a 1 n/a 1

n/a n/a n/a n/a n/a every 5 years n/a a a a a every

6 mon. * MIT Geomechanical studies Formation Testing Injection Fluids testing Monitoring & Reporting GEOLOGY AND HYDROLOGY Cross sections Aquifer Evaluation OPERATING CONDITIONS Safety Requirements Contigency Plans Closure PERMIT PROCESS Duration of Permit Public Hearing Permit to Construct Permit to Inject

a a every 6 mon. * n/a a n/a n/a a every 5 years a

a a a a a a a n/a n/a a a a a a

a a a a a a a a a a a a a

a a a a a 10 years a a a 10 years a a a No term a

a a No term a a a ** * Commercial Class I - MITs quarterly ** Class I Hazardous Wells also with Post-Closure n/a n/a n/a n/a n/a

a n/a n/a n/a n/a 10 years n/a a n/a Permit Application content common to Class I wells and Salt Caverns Certified Plat Regional Geology Local Geology

Base of USDW Freshwater Aquifers Stratigraphy (CrossSections) Structure Maps Injection Zone Seismic Activity Flood Areas Technical Report Monitoring, Testing &

Reporting Contingency Plans Closure & Post-Closure Plans Financial Responsibility IT Questions Adjacent Property Owners Names & Addresses Regional and Local Geology Section CROSS SECTION PROFILES o Should include information from literature, seismic data, and facility records. o Must be prepared to professional geological standards (vertical and horizontal scales, orientation, legend, preparers name and date of preparation)

o Include an index map to show the cross sections lines o If logs are available, include the closest wells to the proposed well o The Operators name, Well Name and Number, Well Serial Number, and Well Status should be identified above each one of the wells used to construct the cross section s o Distance between the wells o Electrical log copies scaled and included in the cross sections CROSS SECTION PROFILES (Continued) oIndicate the extent of the AOR and property lines oIndicate the USDW, Aquifer Systems, Age of Major geological units oStratigraphic correlations based on particular stratigraphic units should be marked clearly throughout the cross sections oProposed perforated interval needs to be marked oThe proposed top and bottom of the injection zone should be

marked clearly oThe Confining zone should be marked clearly oIndicate the horizontal extent of major surface features For a complete list of features to include on cross sections, please see the cross section standards list. Well information Legen d LOCAL GEOLOGY INDEX MAP FOR CROSSSECTIONS Some areas of Discussion that are specific to each Class of well Class I Injection Wells isolate hazardous,

industrial and municipal, or radioactive wastes from the lowermost formation containing, within mile radius of the well bore, an underground source of drinking water. CLASS I NON-HAZARDOUS AREA OF REVIEW OF ARTIFICIAL PENETRATION WELLS No less than 2-Miles AREA OF REVIEW FOR FRESH WATER WELLS Mile radius

INJECTION ZONE RESERVOIR PROPERTIES Porosity and Permeability Lithology of the Injection Formation Bottomhole Temperature and Pressure Formation Fracture Pressure WASTE STREAM CHARACTERIZATION Chemical and Physical properties of the injection fluid Compatibility with Formation PERIODIC MECHANICAL TEST RTS Temperature Logs

Oxygen Activation Logs CLASS I HAZARDOUS Essentially the same requirements as Class I Non-Hazardous wells with the addition of the following: The following must be proven through modeling: That the injection zone has sufficient permeability, porosity, thickness & areal extent to prevent migration of fluids into USDWs or outside of the injection zone. That the confining zone is laterally continuous and free of transecting, transmissive faults or fractures over an area sufficient to prevent the movement of fluids into USDW or outside the injection zone; and

Contains at least one formation of sufficient thickness and with lithological and stress characteristics capable of preventing vertical propagation of fractures. CLASS I HAZARDOUS (continued) Area of Review of Artificial Penetration Wells 2-Miles around the well OR the calculated cone of influence of the well, whichever is greater For wells within Mile radius of injection well, include: Copies of casing and cementing records (including cementing affidavits)

Copies of plugging and completion records; and Schematic diagrams of each well Class II Hydrocarbon Storage Wells inject hydrocarbons in underground formations (such as salt caverns) where they are stored. Class II Hydrocarbon Storage Structure map showing Top of Salt Well Construction Requirements Two strings of casing cemented into the salt

Deepest cemented casing at least 300 feet into the salt Storage Cavern Location and Geometry Maximum development diameter of the storage chamber shall be no less than 100 feet from property lines Distance separation between cavern walls shall be no less than 200 feet as measured in any direction Distance of the cavern to the edge of the salt shall be no less than 300 feet Class II Hydrocarbon Storage Geomechanical Studies and Modeling

To determine maximum and minimum operating pressure of the storage chamber Subsidence Program including semi-annual subsidence surveys for gas storage or annual subsidence surveys for liquid storage Sonar Survey Reports of the mined cavern (every 5 years) MITs typically Nitrogen/Brine Tests (every 5 years) Must include 60-minute casing test and at a minimum a 24-hour cavern system test. Class III wells inject fluids for extraction of minerals or energy. Currently, all

permitted Class III wells in Louisiana are salt solution mining wells. Class III Solution Mining Structure map showing Top of Salt Evaluation of Groundwater (typically freshwater) Pumpage for Cavern Development Number of wells to be installed Projected volume of water needed Expected volume of cavern Time required to complete the project Contact the Environmental Division of the Office of Conservation

Groundwater analysis of the source of mining water The analysis sheet(s) must identify the freshwater well sampled At minimum include measurements of: Chloride and TDS. Sonar Survey Reports of the mined cavern (every 5 years) MITs typically Nitrogen/Brine Tests (every 5 years) Must include 60-minute casing test and at a minimum a 24-hour cavern system test. NOTE: Class III applications should not refer to regulations in 29-M or 29-M-2 even if the cavern is being developed for storage or E & P Waste Disposal purposes. Technical Report Technical Report

The purpose of the Technical Report is to describe the proposed project as a whole and must explain: Regional and Local Geology overall well operating ranges, system monitoring, safety procedures and equipment, financial responsibility, Closure and post closure plans, etc. The bulk of these application packages is located in the Technical Report. Each Class well is required to include certain content within the Technical report. We will discuss content that is specific

for the Engineering and Geological reviews for each type well. Components to include in the Technical Report for Class I Non-Hazardous (Non-Haz) Wells Technical Report for Class I Non-Haz Wells Proposed operating data: average & maximum daily rate & volume of the injection fluid; average & maximum injection pressure; source & analysis of the chemical, physical & biological characteristics of the injection fluid; Proposed formation testing program: to obtain an analysis of the physical & chemical characteristics of the receiving formation; Proposed stimulation program; Proposed injection procedures: including storage & pre-injection treatment of the waste stream, and well use schedule;

Technical Report (for Class I Non-Haz Wells) continued Plans (including maps): for meeting the monitoring requirements of Lac 43:XVII.109.A.7 (209.I.1 for Class I Hazardous Wells); Construction procedures: including a cementing & casing program, logging procedures, deviation checks & a drilling, testing & coring program; Contingency plans: to cope with all shut-ins or well failures to prevent the migration of the contaminating fluids into underground sources of drinking water (USDW); Technical Report (for Class I Non-Haz Wells) continued Calculation of the pressure increase: in the proposed injection zone for a time period equal to the expected life of the well. You may use Matthews and Russell, 1967 Pressure Buildup and

Flow Tests in Wells, American Institute of Mining, Met. Eng. Monograph, Vol. 1; Calculation of expected waste front travel: a conservative value can be calculated by using the following formula (see next slide). Technical Report (for Class I Non-Haz Wells) - continued Calculation of expected waste front travel: where: r = radial distance of wastewater front from well; v = cumulative volume of injected wastewater; b = effective reservoir thickness; = average effective porosity; (Warner, D.L. and Lehr, J.H., An Introduction to the Technology of Subsurface Wastewater Injection, Robert S. Kerr Environmental Research Laboratory (EPA) Research Report, 1977)

Components to include in the Technical Report for Class I Hazardous (Haz) Wells Technical Report (for Class I Haz Wells) Essentially, the same requirements as Class I Non-Haz wells with the addition of the following: Table of data on all wells which penetrate the proposed zone within a 2-mile Area of Review (AOR) or the calculated cone of influence of the well, whichever is greater - for wells within a mile radius of the injection well - you must also include: Copies of casing & cementing records (including cementing affidavits); Copies of plugging &/or completion records; and Schematic diagrams of each well.

Technical Report (for Class I Haz Wells) - continued Proposed formation testing program: to obtain an analysis of the chemical, physical & radiological characteristics of & other information on both the injection zone and the confining zone; Construction procedures: should include a cementing and casing program (include cementers recommendation), well material specifications & their life expectancy, logging procedures, deviation checks and a drilling, testing & coring program; Financial assurance: through a performance bond or other appropriate means, the resources necessary to close, P&A the well & for post-closure care as required under LAC 43:XVII.207.C & 209.O; Applicants plans for closure (P&A) and post-closure care of the well (information required under LAC 43:XVII.209.L.1 & M.1).

Components to include in the Technical Report for Class II Hydrocarbon Storage (HSW) Wells Technical Report (for Class II HSW wells) Information on manmade structures within the salt stock regardless of use, depth of penetration, or distance to the salt cavern well or salt cavern being the subject of the application: A tabular listing of all salt caverns to include: Operator name, well name & number, state serial number & well location; Current or previous use of the salt cavern (waste disposal, hydrocarbon storage, solution mining), current status of the salt cavern (active, shut-in, P&Ad), date the salt cavern well was drilled, & the date the current salt cavern status was

assigned; Salt cavern depth, construction, completion (including completion depths), P&A data; Technical Report (for Class II HSW wells) continued A tabular listing of all conventional (dry or room and pillar) mining activities, whether active or abandoned. The list must include the following minimum items: Owner or operator name & address; Current mine status (active, abandoned); Depth & boundaries of mined levels; The closest distance of the mine in any direction to the salt cavern well & salt cavern. Corrective action plan: for wells or other manmade

structures within the AOR that penetrate the salt stock but are not properly constructed, completed or P&Ad; Technical Report (for Class II HSW wells) continued Surface site diagram(s): drawn to scale to include details & locations of the entire salt cavern hydrocarbon storage facility layout (surface pumps, piping & instrumentation, controlled access roads, fenced boundaries, hydrocarbon offloading, storage, treatment & processing areas, field office, monitoring & safety equipment & location of such equipment, required curbed or other retaining wall heights, etc.; Detailed plans & procedures to operate the salt cavern well, salt cavern & related surface facilities in accordance with the following requirements: Technical Report (for Class II HSW wells) continued

Cavern & surface facility design requirements: including but not limited to cavern spacing requirements & cavern coalescence; Operating requirements: including but not limited to cavern roof restrictions, blanket material, remedial work, well recompletion, multiple well caverns, cavern allowable operating pressure & rates and cavern displacement fluid management; Technical Report (for Class II HSW wells) continued

Safety requirements: including but not limited to an emergency action plan, controlled site access, facility identification, personnel, wellhead protection & identification, valves & flowlines, alarm systems, emergency shutdown valves, vapor monitoring & leak detection, gaseous vapor control, fire detection & suppression, systems test & inspections & surface facility retaining walls & spill containment, as well as contingency plans to cope with all shut-ins or well failures to prevent the migration of contaminating fluids into underground sources of drinking water; Technical Report (for Class II HSW wells) continued

Monitoring requirements including but not limited to equipment requirements such as pressure gauges, pressure sensors and flow sensors, continuous recording instruments, leak detection, subsidence monitoring, as well as a description of methods that will be undertaken to monitor salt cavern growth due to undersaturated fluid injection; Pre-operating requirements specifically the submission of a completion report & the information required therein, prior to accepting, storing or otherwise initiating storage activities; Technical Report (for Class II HSW wells) continued

Mechanical integrity pressure and leak test requirements including but not limited to frequency of tests, test methods, submission of pressure & leak test results, notification of test failures; Cavern configuration & capacity measurement procedures including but not limited to sonar caliper surveys, frequency of surveys & submission of survey results; Technical Report (for Class II HSW wells) continued Requirements for inactive caverns;

Closure requirements including but not limited to closure plan requirements, standards for closure; and, Any other information pertinent to operation of the salt cavern storage facility. Components to include in the Technical Report for Class III Wells Technical Report (for Class III wells) Proposed operating data: average & maximum daily rate & volume of fluid to be injected; average & maximum injection pressure; and qualitative analysis &

ranges in concentrations of all constituents of injected fluids; Proposed formation testing program: to obtain the info required by LAC 43:XVII.109.B.4.c & d; Proposed stimulation program; Proposed injection procedure; Technical Report (for Class III wells) - continued Plans (including maps): for meeting the monitoring requirements of LAC 43:XVII.109.B.7; Expected changes in pressure, native fluid displacement and the direction of movement of injection fluid; Financial assurance: through a performance bond or

other appropriate means, the resources necessary to close or P&A the well as required by LAC 43:XVII.109.B.10 & 107.C; and, Corrective action proposed to be taken under 109.B.3: for wells within the AOR which penetrate the injection zone but are not properly completed or plugged. A Brief Discussion on Class V Wells Safe Drinking Water Act Underground Injection Control (UIC) Program Protecting Public Health and Drinking Water Class V wells Resources Manage the shallow injection of all other fluids to prevent

contamination of drinking water resources In March 23, 1982 EPA delegated the State of Louisiana with full permitting and enforcement authority of the States UIC Program Class V Permitting Class V Statewide Order 29-N-1 LAC 43: XVII.103 Chapter 1 Permit Application Form

UIC-25 USDW MUST BE PROTECTED Safe Drinking Water Act Underground Injection Control (UIC) Program Protecting Public Health and Drinking Water Resources There are over 20 subtypes of Class V Wells , nationwide In Louisiana, most Class V wells are permitted to inject non-hazardous fluids to remediate soil and/or groundwater conditions

Class V Well Applications Should Include: LOCATION PLAT FOR A SINGLE WELL OR GROUP OF WELLS WELL CONSTRUCTION DETAILS DESCRIPTION OF INJECTION FLUIDS (i.e.,Ozone, OxyTek-L, Organicide, etc.) PROOF THAT THE REMEDIATION SITE IS UNDER MANAGEMENT OF LDEQ AGENCY CLASS V Well Construction Well Casing

above OR below ground with flush mount protective cover Well Depth between 2 to 40 feet below ground CLASS V REQUIREMENTS Injection without a permit is a violation of Statewide Order No. 29-N-1, and is subject to enforcement action and fines Operator Name, Serial Number and Well Name should be inscribed, stamped or otherwise permanently affixed to the well An original signed completed Well History & Work Resume Report (FORM UIC-42) must be submitted after completing the injection well

A work permit (FORM UIC-17) must be approved before any work is performed on the well

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