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Post-Permitting

1.  Annual Monitoring Report (Form H-10)

  • Every well with a valid injection permit must file an annual monitoring report unless the well is actively producing and files an annual production status report (Form W-10 or G-10) instead.

2.  Mechanical Integrity Test (Form H-5)

  • A mechanical integrity test (MIT) must be performed before any fluids are injected into the well.
  • Permits under Rule 9, 46, or 96: Once the well is converted to injection, an MIT must be performed periodically for the life of the permit.
  • Generally, an MIT must be performed after:
    • Any workover that disturbs the seal of the packer.  See the permit, and the applicable rule under which the permit was granted, for related conditions.
    • Any casing repair or workover that affects a cemented casing string or the wellhead.  See the permit, and the applicable rule under which the permit was granted, for related conditions.

3.  Completion report (Form W-2 or G-1)

  • File a completion report within 30 days:
    • After conversion to reflect the actual completion of the well.
    • Any physical change to the well as required under Rule 16(b)(2)
  • Commission staff will review the actual completion against the proposed completion in the permit application.

GUIDELINES FOR FILING COMPLETION REPORTS:

    • Fill in required dates and permit numbers. Be certain injection into a productive zone for disposal purposes is shown under injection rather than disposal authority.
    • The well location blocks are to be completed on both front and back sides of Form W-2 or G-1.
    • Casing and liner record must be completed.
    • Presence of packer and packer depth must be included.
    • The "producing" interval must be included. Show the perforated intervals here, not the permitted intervals.
    • Please include all cement squeeze information.
    • Please indicate if the well is dually completed for disposal and production.
    • Select "Active UIC" as the "well type" if the well is in injection or disposal service, brine mining service, hydrocarbon storage service, or gas storage service
    • Select "Shut-in UIC" as the well type if the well is not configured to meet the definition of active operation given in Rule 15(a)(1)(6)

4.  Groundwater Monitoring For Brine Mining Injection Wells

  1. Mechanical Integrity Test (MIT) Requirements for Brine Mining Injection Wells
    • Brine mining injection wells (or "brine mining wells") must demonstrate mechanical integrity annually. See 16 Tex. Admin. Code § 3.81(f)(16)(B).
    • An operator must demonstrate that a well has mechanical integrity as follows:
      • The operator must demonstrate that there is not a significant leak in the casing as follows (see 16 Tex. Admin. Code § 3.81(f)(16)(A)(i)):
        1. Conduct a fluid pressure test in accordance with 16 Texas Administrative Code § 3.81(f)(16)(C)(i)-(iv).
        2. In lieu of an annual fluid pressure test, the operator may monitor the pressure of a hydrocarbon pad or blanket contained in the annulus space of the well, provided the operator has obtained written approval prior to using this method. See 16 Tex. Admin. Code § 3.81(f)(16)(D).
      • The operator must also demonstrate that there is no significant fluid movement into freshwater strata through vertical channels adjacent to the wellbore. See 16 Tex. Admin. Code § 3.81(f)(16)(A)(ii). One of the following methods must be used to demonstrate the absence of significant fluid movement into freshwater strata through vertical channels adjacent to the wellbore:
        1. The results of a temperature or noise log; or
        2. Where the nature of the casing precludes the use of a temperature or noise log, Staff can review cementing records demonstrating the presence of adequate cement to prevent significant fluid movement. See 16 Tex. Admin. Code § 3.81(f)(16)(E).
    • If the operator is unable to submit evidence to demonstrate either of the above-specified requirements (i.e., no significant leak, no significant fluid movement), Staff will fail the MIT.
  2. Monitoring Wells
    • All applicants must submit a proposed groundwater monitoring plan (or an alternate plan) to demonstrate that fluids are not escaping from the permitted injection zone. 16 Tex. Admin. Code § 3.81(d)(4)(Q).
      • The monitoring program is designed to verify the absence of significant fluid movement. CFR § 146.8 (c).
    • The groundwater monitoring plan (or alternate plan) must comply with the requirements detailed in Statewide Rule 81(f)(10)(A)-(C).
    • Minimum number of monitor wells
      • New brine mining wells: Staff will include a permit condition (detailed in the last section of this document) that requires a minimum of three monitor wells to confirm groundwater gradient direction and the downgradient monitor well.
      • Existing brine mining wells:
        • Staff will review all applications for modification to existing brine mining wells to determine if additional monitor wells are required to demonstrate that fluids are not escaping from the permitted injection zone. See 16 Tex. Admin. Code § 3.81(b)(2).
        • Staff may require operators of existing brine mining wells to install a minimum of three monitor wells if it determines additional monitor wells are required to demonstrate that fluids are not escaping from the permitted injection zone. 16 Tex. Admin. Code § 3.81(f)(6) (“The permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the operator for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance does not stay any permit condition.”).

5. Pressure Monitoring and Other Handling of Inactive Storage Cavern Wells

  • In this section, the term “hydrocarbon,” will mean “liquid or liquefied hydrocarbons,” as that phrase is used in Rule 95, as well as “gas,” as that word is used in Rule 97.
  • Cavern Leaching vs. Brine Mining
    • Rules 95 and 97 regulate wells used for leaching a cavern for the underground storage of hydrocarbons. See 16 Tex. Admin. Code § 3.81(a)(3) (“The term ‘brine mining injection well’ does not include a well used to inject fluid for the purpose of leaching a cavern for the underground storage of hydrocarbons…”).
    • Staff does not consider a well that meets the following criteria to be a well used for leaching a cavern for the underground storage of hydrocarbons regulated by Rules 95 and 97:
      • A well used to inject fluid for the purpose of extracting brine by the solution of a subsurface salt formation for more than two (2) years.
    • If a well meets the criteria of subsection (b), Staff will alert the operator that additional permitting may be required as follows:
      • New hydrocarbon storage wells and/or underground hydrocarbon storage facilities: Staff will include a new permit condition (detailed in the last section of this document) to specify that any well used in leaching operations for more than two (2) years will be considered a brine mining injection well. The permittee will be required to obtain a brine mining injection permit for that well.
      • Existing hydrocarbon storage wells and/or underground hydrocarbon storage facilities:
        • If an operator has used a well for more than two (2) years in leaching operations, Staff will notify the operator that they have one (1) year to complete the leaching operations.
        • If leaching operations do not cease after one (1) year, the operator will be required to obtain a brine mining injection well permit.
          1. Staff will initiate an enforcement action under Rule 81 for any operator that fails to obtain a brine mining injection well permit as required by this subsection.

5.1 Emergency Response Drill

    • Applies to permits pursuant to Rules 95 and 97
    • A emergency response drill must conducted annually as described by the rules quoted below. Submit the report of the drill to UIC and the district office.

RULE §3.95 Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations
(h) Safety. The following safety requirements shall apply to all underground hydrocarbon storage facilities, except as specifically provided otherwise, provided, however, that the provisions of this subsection shall not apply to any hydrocarbon storage well that is out of service and disconnected from all surface piping. Notwithstanding the compliance time periods specified in this subsection, a new storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All storage facilities that are permitted on the effective date of this section must have such safety measures and equipment in place within the period of time specified. Further, until such a facility has all the safety measures and devices required by paragraphs (2) - (7) and (13) - (16) of this subsection in place, the facility must have an attendant on site at all times. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.
(11) Annual emergency drill. Annually, each operator shall conduct a drill that tests response to a simulated emergency. Written notice of the drill shall be provided to the appropriate Commission district office, the county emergency management coordinator, and the county sheriff's office at least seven days prior to the drill. Local emergency response authorities shall be invited to participate in all such drills. The operator shall file a written evaluation of the drill and plans for improvements with the appropriate district office and the county emergency management coordinator within 30 days after the date of the drill.

RULE §3.97 Underground Storage of Gas in Salt Formations
(h) Safety. The following safety requirements shall apply to all underground gas storage facilities, provided, however, that the provisions of this subsection shall not apply to any natural gas storage well that is out of service and disconnected from surface piping. Notwithstanding the compliance time periods specified in this subsection, a new underground gas storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All existing storage facilities must have such safety measures and equipment in place within the period of time specified. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.
(9) Annual emergency drill. Annually, each operator shall conduct a drill that tests response to a simulated emergency. Written notice of the drill shall be provided to the appropriate Commission district office, the county emergency management coordinator, and the county sheriff's office at least seven days prior to the drill. Local emergency response authorities shall be invited to participate in all such drills. The operator shall file a written evaluation of the drill and plans for improvements with the appropriate district office and the county emergency management coordinator within 30 days after the date of the drill.

5.2 Emergency Response Plan

    • Applies to permits pursuant to Rules 95, 96, and 97
    • Submit the plan (or updated plan) to UIC when the plan changes or is updated. The operator is responsible for maintaining an emergency response plan pursuant to the following rules:

RULE §3.95 Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations
(h) Safety. The following safety requirements shall apply to all underground hydrocarbon storage facilities, except as specifically provided otherwise, provided, however, that the provisions of this subsection shall not apply to any hydrocarbon storage well that is out of service and disconnected from all surface piping. Notwithstanding the compliance time periods specified in this subsection, a new storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All storage facilities that are permitted on the effective date of this section must have such safety measures and equipment in place within the period of time specified. Further, until such a facility has all the safety measures and devices required by paragraphs (2) - (7) and (13) - (16) of this subsection in place, the facility must have an attendant on site at all times. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.
(8) Emergency response plan. Each storage facility shall submit to the Commission a written emergency response plan. The plan shall address spills and releases, fires, fire suppression capability, explosions, loss of electricity, and loss of telecommunication services. The plan shall describe the storage facility's emergency response communication system, procedures for coordination of emergency communication and response activities with local emergency planning committees and other local authorities, use of warning systems, procedures for citizen and employee emergency notification and evacuation, and employee training. The initial plan must be designed based upon the existing safety measures at the facility. The plan shall be updated as changes in safety features at the facility occur, or as the Commission or its designee requires. The plan shall include a plat of the facility that shows the location of wells, processing areas, loading racks, brine pits, and other significant features at the site. A copy of the plan shall be provided to the local emergency response planning committee and to any other local governmental entity that submits a written request for a copy of the plan to the operator. Copies of the plan shall also be available at the storage facility and at the company headquarters.

RULE §3.97 Underground Storage of Gas in Salt Formations
(h) Safety. The following safety requirements shall apply to all underground gas storage facilities, provided, however, that the provisions of this subsection shall not apply to any natural gas storage well that is out of service and disconnected from surface piping. Notwithstanding the compliance time periods specified in this subsection, a new underground gas storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All existing storage facilities must have such safety measures and equipment in place within the period of time specified. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.
(7) Emergency response plan. Each storage facility shall submit to the Commission a written emergency response plan. The plan shall address gas releases, fires, fire suppression capability, explosions, loss of electricity, and loss of telecommunication services. The plan shall describe the facility's emergency response communication system, procedures for coordination of emergency communication and response activities with local authorities, use of warning systems, procedures for citizen and employee emergency notification and evacuation, and employee training. The plan shall also include a plat of the facility showing the locations of wells, processing areas, and other significant features at the facility. The initial plan must be designed based upon the existing safety measures at the facility. The plan shall be updated as changes in safety features at the facility occur, or as the Commission or its designee requires. A copy of the plan shall be provided to the local emergency response committee and to any other local governmental entity that submits a written request for a copy of the plan to the operator. Copies of the plan shall also be available at the storage facility and at the company headquarters.

RULE §3.96 Underground Storage of Gas in Productive or Depleted Reservoirs
(i) Safety requirements for gas storage projects.
(3) Emergency response plan. Within six months of the effective date of this section, each operator shall submit to the commission a safety plan that includes emergency response procedures, provisions to provide security against unauthorized activity, and gas release detection and prevention measures. The plan shall include a description of and be designed for the residential, commercial, and public land use in the proximity of the gas storage project. The initial plan must be designed based upon the existing safety measures at the facility. The plan shall be updated as changes in safety features at the facility occur, or as the commission or its designee requires. Copies of the plan shall be available at the storage facility and at the company headquarters.

5.3 Casing Inspection Log

    • Applies to permits pursuant to Rules 95 and 97
    • If the casing inspection accompanies an MIT report, include the casing inspection log as an attachment to the MIT report. Otherwise, submit the casing inspection log via email to cavern_reports@rrc.texas.gov. For each well, the schedule for the casing inspection log is determined by the rules cited below.
    • UIC may grant up to a five-year extension on the regular casing inspection requirement if sufficient information is available to establish that a well has not experienced noticeable casing degradation that may increase the risk of casing failure. Information necessary to establish that a well has not experienced noticeable casing degradation must include at least two comparable casing inspection logs run at separate times over a period of not less than ten years and indicating that the condition of the casing has not noticeably changed during the interval of time between inspections. Information necessary to waive the regular casing inspection requirement must also establish that there is competent cement coverage throughout the caprock interval and into the next outer casing. Requests for extension to the casing inspection log must be submitted via email to cavern_reports@rrc.texas.gov. The request will be reviewed within 45 days.

RULE §3.95 Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations
(o) Testing and maintenance.
(1) ... Each hydrocarbon storage well drilled into a salt dome and having a single casing string cemented to the surface shall have the casing inspected by mechanical, ultrasonic, or magnetic methods at least once every five years and after each workover that involves physical changes to the cemented casing string.
(3) Storage wellhead and casing. Storage wellhead components and casing shall be inspected at least once every 10 years for corrosion, cracks, deformations or other conditions that may compromise integrity and that may not be detected by the five-year test. The operator may request an extension of up to five years from the Commission for good cause. Factors the Commission may consider in determining good cause pursuant to this paragraph include by are not limited to the age, location, and configuration of the well; well and facility history; operator compliance record; operator efforts to comply with this subsection; and accuracy of inventory control.

RULE §3.97 Underground Storage of Gas in Salt Formations
(o) Testing and maintenance.
(3) Storage wellhead and casing. Storage wellhead components and casing shall be inspected at least once every 15 years for corrosion, cracks, deformations, or other conditions that may compromise integrity and that may not be detected by the five-year test. The operator may request an extension of up to five years from the Commission for good cause. Factors the Commission may consider in determining good cause pursuant to this paragraph include by are not limited to the age, location, and configuration of the well; well and facility history; operator compliance record; operator efforts to comply with this subsection; and accuracy of inventory control.

    • Barbers Hill special field rules, established under Oil and Gas Docket No. 03-0223293, effective March 6, 2001, applicable to wells reported to the Barbers Hill field
    • Rule 5. Cavern and Well Inspections and Special Investigations
      At least once every five years, commencing with the next mechanical integrity testing required by Statewide Rule 95(o), the operator of each active underground hydrocarbons storage well shall perform the following logs and surveys of the hydrocarbon storage well shall perform the following logs and surveys of the hydrocarbon storage well and cavern:
      (3) downhole casing inspection logging of the final cemented casing (to determine the condition of the casing) using a commercially available electromagnetic, ultrasonic, or other similar logging technology suited for identifying and determining corrosion, pitting, crimping, or ovality of the particular wellbore.

5.4 Roof Monitoring Log

    • Applies to permits pursuant to Rules 95 and 97 for bedded salt formations.
    • A sonar survey may substitute for a roof monitoring log.
    • If the roof monitoring log accompanies an MIT report, include the roof monitoring log as an attachment to the MIT report. Otherwise, submit the roof monitoring log via email to cavern_reports@rrc.texas.gov. For each well, the schedule for the sonar survey is determined by the following rules:

RULE §3.95 Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations
(i) Cavern capacity and configuration.
(4) Bedded salt. The configuration of the roof of each hydrocarbon storage cavern in bedded salt shall be determined by downhole log or an alternate method approved by the Commission or its designee at least once every five years.
(6) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

RULE §3.97 Underground Storage of Gas in Salt Formations
(i) Cavern capacity and configuration.
(3) Bedded salt. The configuration of the roof of each gas storage cavern in bedded salt shall be determined by downhole log or an alternate method approved by the Commission, or its designee, at least once every five years.
(5) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any such cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

5.5 Sonar Survey

    • Applies to permits pursuant to Rules 95 and 97
    • If the sonar survey accompanies an MIT report, include the sonar survey as an attachment to the MIT report. Otherwise, submit the sonar survey via email to cavern_reports@rrc.texas.gov. For each well, the schedule for the sonar survey is determined by the following rules:

RULE §3.95 Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations
(i) Cavern capacity and configuration.
(1) Crude oil storage. The provisions of this subsection shall not apply to underground hydrocarbon storage facilities where only crude oil is stored.
(2) Before storage operations begin. The capacity and configuration of each hydrocarbon storage cavern (both salt domes and bedded salt) shall be determined by sonar survey before storage operations begin in a newly completed cavern.
(3) Salt domes. The capacity and configuration of each salt dome hydrocarbon storage cavern shall be determined by sonar survey at least once every 10 years.
(6) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

RULE §3.97 Underground Storage of Gas in Salt Formations
(i) Cavern capacity and configuration.
(1) Before storage operations begin. The capacity and configuration of each gas storage cavern (both salt domes and bedded salt) shall be determined by sonar survey before storage operations begin in a newly completed cavern.
(2) Salt domes. The capacity and configuration of each salt dome gas storage cavern shall be determined by sonar survey before a cavern that has been out of service is returned to service, provided, however, that a sonar survey shall not be required on a cavern that is being returned to service if a sonar survey of that cavern has been run at any time during the previous 10 years.
(5) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any such cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

5.6 Directional Survey

    • Applies to permits pursuant to Rules 95 and 97 that are reported to the Barbers Hill field. Directional surveys must be submitted via the RRC online directional surveys system pursuant to Rule 12. For each well, the schedule is determined by the following rules:
    • Rule 5. Cavern and Well Inspections and Special Investigations
      a. At least once every five years, commencing with the next mechanical integrity testing required by Statewide Rule 95(o), the operator of each active underground hydrocarbons storage well shall perform the following logs and surveys of the hydrocarbon storage well shall perform the following logs and surveys of the hydrocarbon storage well and cavern:
      (2) gyroscope or directional survey (to determine the position of the wellbore)

5.7 Alternative monitoring for out-of-service or permanently deactivated hydrocarbon storage wells

    • MIT
      • An operator of an out-of-service storage well may request approval to conduct storage well pressure monitoring in lieu of an MIT. See 16 Tex. Admin. Code §§ 3.95(o)(5) and 3.97(o)(2).
      • A well must be tested for integrity before it is returned to service. See 16 Tex. Admin. Code §§ 3.95(o)(5) and 3.97(o)(2).
    • Plugging
      • An operator must apply for and receive approval from Staff before converting a permanently deactivated hydrocarbon storage well into a monitor well in lieu of plugging the well. See 16 Tex. Admin. Code §§ 3.95(p)(2) and 3.97(p)(2).
        • An H-10H is not an application to convert a permanently deactivated hydrocarbon storage well into a monitor well.
      • The operator must submit a pressure monitoring plan to the Commission with its request to convert the well to a monitor well. 16 Tex. Admin. Code §§ 3.95(p)(2) and 3.97(p)(2).
      • Inactive well status
        • An inactive well is defined as “an unplugged well that has had no reported production, disposal, injection, or other permitted activity for a period of greater than 12 months.” Tex. Nat. Res. Code § 89.002(a)(12).
        • An out-of-service or permanently deactivated hydrocarbon storage well will be considered “inactive,” and subject to the Commission’s inactive well requirements, including, but not limited to, Rule 14(b)(2), if the well meets the definition of an inactive well. See 16 Tex. Admin. Code §§ 3.95(r) and 3.97(r) (“The owner or operator of an underground gas storage facility is not relieved by this section of compliance with any other requirements of Chapters 3, 4, 7, or 8 of this title (relating to Oil and Gas Division; Environmental Protection; Gas Services Division; or Pipeline Safety Regulations).”).
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