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Class I Well Operation, Maintenance, and Reporting Requirements May 7, 2014

Class I Well Operation, Maintenance, and Reporting Requirements May 7, 2014. Rich Heitzenrater/Elizabeth Murphey UIC Inspection and Compliance Team TCEQ Region 14 Corpus Christi (361) 825-3119 (361) 825-3128. Operational Problems.

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Class I Well Operation, Maintenance, and Reporting Requirements May 7, 2014

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  1. Class I Well Operation, Maintenance, and Reporting RequirementsMay 7, 2014 Rich Heitzenrater/Elizabeth Murphey UIC Inspection and Compliance Team TCEQ Region 14 Corpus Christi (361) 825-3119 (361) 825-3128

  2. Operational Problems • Any problems that could potentially affect the mechanical integrity of the well or reported data should be explained on the operating reporting forms. • Malfunctions of equipment • Faulty gauges (recalibrated or replaced) • Power outages

  3. Annulus Differential Pressure • Differential Pressure must be maintained at a minimum of 100 psi at all times • If it falls below 100 psi for more than 15 minutes the well must be shut in and TCEQ must be notified. • Any instances when this occurred should be noted and explained on reporting forms even if they did not exceed 15 minutes.

  4. Maintenance Issues • Maintenance is scheduled not reactionary. • If well maintenance would require exceedances in permit parameters (i.e. annulus differential) or the well to be disassembled (replacing seals or piping) prior approval by TCEQ is required. • Submit plans prior to work • May help avoid violations

  5. MIT Issues • Flow rates during stationary RAT surveys should be as close as possible to the normal operating average flow rate. • If any anomalies are seen during a stationary survey, a repeat survey should be run. We would like to see two clean runs for each well’s RAT survey. • Any anomalies on any of the logs should be fully explained in the report. • Extension requests for MIT deadlines must be made prior to the MIT anniversary date. There should be no more than 15 months nor less than 9 months between routine MITs.

  6. Workover Issues • Remedial workovers for wells that fail mechanical integrity tests • Should be performed as soon as possible. • A timeline should be submitted to show when the workover should be completed and when the well is expected to return to operation. • When planning a workover it may be necessary to make modifications or amendments to the well’s permit. These will be need before work can begin. • Some workovers on hazardous waste disposal wells may require modifications to the “No Migration” petition issued by USEPA

  7. Workover Issues • A well can’t be temporarily abandoned when it lacks mechanical integrity. • Acid stimulations and Coil tubing clean outs are not considered workovers. They should be reported on page 2 of the operating reporting forms. • Written approval from TCEQ is required to resume well operations.

  8. Quarterly and Monthly Reporting Forms • Quarterly Forms should be submitted within 20 days after the last day of the months of March, June, September, and December • Monthly forms shall be submitted within 30 days after the last day of each month

  9. Quarterly and Monthly Reporting Forms • Exceedences • Need to be marked on page 1, page 2-D, and then explained on page 2-F • Calculation of Average Flow Rate • (total volume / # of hours operated) / 60 • Annulus Fluid Usage • 40 CFR 146.69(a)(5) • Report net amount of fluid added to the annulus for each month.

  10. Reporting Issues • Reports should include a dated cover letter. (Who prepared it and when was it submitted) • All MIT reports, Workover reports, and Workover procedures should be submitted with a PE or PG stamp. • All reports must be submitted within 30 days of the completion of work. Any requests for extensions must be submitted prior to the due date of the report. • Annual Injection Zone Reports should follow the guidance document dated September 16, 2009.

  11. UIC 2014 Mailing List Austin (Permits) • Applications for Minor Mods or Amendments • Permit Corrections • Permit Revocations • Reports and Correspondence Concerning Well Construction or Plugging

  12. UIC 2014 Mailing List Austin (Permits Administrative Review Section) • Applications for UIC Permits • New Permits • Renewals • Major Amendments

  13. UIC 2014 Mailing List Austin (Critical Infrastructure Division) • Annual Reports • MIT Reports • Workover Reports

  14. UIC 2014 Mailing List TCEQ Regional Offices • MIT Procedures • Workover Procedures • Monthly & Quarterly Operating Reports • Annual Reports, MIT Reports, Workover Reports • Any other non-permitting related UIC correspondence

  15. UIC Field Operations Staff Region 14 Rich Heitzenrater Richard.Heitzenrater@tceq.texas.gov (361) 825-3119 Elizabeth Murphey Elizabeth.Murphey@tceq.texas.gov (361) 825-3128

  16. UIC Field Operations Staff Region 1 David Durst David.Durst@tceq.texas.gov (806) 468-0535

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