La. Admin. Code tit. 43 § XIX-433

Current through Register Vol. 50, No. 9, September 20, 2024
Section XIX-433 - Disposal of E and P Wastes by Slurry Fracture Injection
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.
B. Definitions

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.

La. Admin. Code tit. 43, § XIX-433

Promulgated by the Department of Natural Resources, Office of Conservation, LR 27:1921 (November 2001), Amended by LR 461231 (9/1/2020).
AUTHORITY NOTE: Promulgated in accordance with R.S. 30:4 et seq.