La. Admin. Code tit. 43 § XVII-3719

Current through Register Vol. 50, No. 11, November 20, 2024

Section XVII-3719 - Operating Requirements

A. Cavern Roof. Without exception or variance to these rules and regulations, no cavern shall be used for storage if the cavern roof has grown above the top of the salt stock. The operation of an already permitted storage cavern shall cease and shall not be allowed to continue if information becomes available that shows this condition exists. The Office of Conservation may order the storage well and cavern removed from storage service according to an approved closure and post-closure plan.

B. Remedial Work. No remedial work or repair work of any kind shall be performed on the storage well or cavern without prior authorization from the Office of Conservation. The provision for prior authorization shall also extend to doing mechanical integrity pressure and leak tests, sonar caliper surveys, and all logs, and all logs, including casing inspection logs and through tubing logs; however, a work permit is not required in order to conduct routine interface surveys. The owner, operator, or its agent shall submit a valid work permit request form (Form UIC-17 or successor). Before beginning well or cavern remedial work, the pressure in the cavern shall be relieved, as practicable.

C. Well Recompletion-Casing Repair. The following applies to storage wells where remedial work results from well upgrade, casing wear, or similar conditions. For each paragraph below, a casing inspection log shall be performed on the entire length of the innermost cemented casing in the well before doing any casing upgrade or repair. Authorization from the Office of Conservation shall be obtained before beginning any well recompletion, repair, upgrade, or closure. A storage well that cannot be repaired or upgraded shall remain out-of-service and be closed according to an approved closure and post-closure plan.

1. Liner. A liner may be used to recomplete or repair a well with severe casing damage. The liner shall be run from the well surface to the base of the innermost cemented casing. The liner shall be cemented over its entire length and shall be successfully pressure tested.

2. Casing Patch. Internal casing patches shall not be used to repair severely corroded or damaged casing. Casing patches shall only be used for repairing or covering isolated pitting, corrosion, or similar localized damage. The casing patch shall extend a minimum of 10 feet above and below the area being repaired. The entire casing shall be successfully pressure tested.

D. Multiple Well Caverns. No newly permitted well shall be drilled into an existing cavern until the cavern pressure has been relieved, as practicable, to 0 PSI measured at the surface.

E. Cavern Allowable Operating Pressure

1. The maximum and minimum allowable surface injection pressures shall be calculated at a depth referenced to the well's deepest effective cemented casing seat. The injection pressure at the wellhead shall be calculated to ensure that the pressure induced within the salt cavern during injection does not initiate fractures or propagate existing fractures in the salt. In no case shall the injection pressure initiate fractures in the confining zone or cause the migration of injected fluids out of the salt stock or into an underground source of drinking water.

2. When measured at the surface and calculated with respect to the appropriate reference depth, the maximum allowable cavern injection pressure shall not exceed a pressure gradient of 0.90 PSI/FT of vertical depth.

3. The storage well shall not be operated at pressures above the maximum allowable injection pressure defined above, exceed the maximum allowable pressure as may be established by permit, or exceed the rated burst or collapse pressure of all well tubulars (cemented or hanging strings) even for short periods, including pressure pulsation peaks, abnormal operating conditions, well or cavern tests, etc.

5. No storage cavern shall be converted to store a material described in §3703.A.1 without prior approval by the Office of Conservation. Conversion to alternate material storage may require additional geomechanical modeling to establish allowable operating pressures.

F. Solution Mining Under Gas (Smugging)

1. Within 30 days of a planned cavern enlargement while storing product, the operator shall submit written notice to the Injection and Mining Division with a description and timeline of the planned event.

2. Unless specifically exempted by the commissioner, after the completion of the smugging period, a sonar survey shall be conducted of the cavern and submitted to the Injection and Mining Division in accordance with §3729.B 4

La. Admin. Code tit. 43, § XVII-3719

Promulgated by the Department of Natural Resources, Office of Conservation, LR 482337 (9/1/2022).

AUTHORITY NOTE: Promulgated in accordance with R.S. 30:4 et seq. and R.S. 30:23 et seq.