Kan. Admin. Regs. § 82-3-407 - Mechanical integrity requirements; penalty
(a) Each injection
well shall be completed, equipped, operated, and maintained in a manner that
will prevent pollution of fresh and usable water, prevent damage to sources of
oil or gas, and confine fluids to the interval or intervals approved for
injection.
An injection well shall be considered to have mechanical integrity if there are no significant leaks in the tubing, casing, or packer and no fluid movement into fresh or usable water. Mechanical integrity shall be established on each well by one of the following:
(1) Pressure test. The annulus above the
packer, or the injection casing in wells not equipped with a packer, shall be
pressure tested at least once every five years under the supervision of a
representative of the operator. The date for this test shall be mutually agreed
upon by the operator's representative and a representative of the commission.
Test results shall be verified by the operator's representative. A minimum of
25 percent of the tests conducted each year shall be witnessed by a
representative of the commission. The test shall be conducted in accordance
with subsection (b). Injection wells within tubing shall be tested in
accordance with K.A.R. 82-3-406.
(2) Alternate tests. Alternative test methods
approved by the commission, including radioactive tracer surveys and
temperature surveys, may be used to establish mechanical integrity if
conditions are appropriate. The test shall be run at least once every five
years under the supervision of a representative of the operator. The date for
this test shall be mutually agreed upon by the operator's representative and a
representative of the commission. Test results shall be verified by the
operator's representative and shall be interpreted as specified in
commission-approved procedures. A minimum of 25 percent of the tests conducted
each year shall be witnessed by a representative of the commission.
(3) Monitoring. Once a month, the operator
shall monitor and record, during actual injection, the pressure or fluid level
in the annulus and any other information deemed necessary by the conservation
division. An annual report of information logged shall be submitted to the
conservation division in accordance with K.A.R. 82-3-409.
(4) Dually completed injection wells. For
dually completed injection wells, the testing requirements shall include the
following:
(A) The operator shall determine
the fluid level in the annular space in the production casing and the fluid
level within the injection tubing. All fluid level determinations shall be
performed under static well conditions. The minimum shut-in time shall be 24
hours before determining the fluid level. Fluid level tapes shall be submitted
as verification of measurements.
(B) The operator shall measure and report the
oil-to-water ratio of produced fluids from the well. In the case of gas wells,
the operator shall report changes in monthly production volumes.
(C) The fluid level determination and
oil-to-water ratios shall be performed once every three months during the first
year of the well's five-year test cycle, and then once a year for the next four
years. The repeat test cycle of quarterly reports for one year and annual
reports for four years shall begin on the five-year anniversary of the first
fluid level test.
(b) Before operating a well drilled or
converted to injection after December 8, 1982, an operator choosing to use a
pressure test for the initial mechanical integrity test shall perform the test
in the following manner:
(1) Wells
constructed with tubing and a packer shall be pressure tested with the packer
in place. A fluid pressure of 300 psig shall be applied. If the operator
requests a pressure in excess of 300 psig on the injection application, a test
pressure up to the requested pressure may be required. The duration of the test
shall be at least 30 minutes. Maintenance of the fluid pressure during the test
shall provide assurance of the integrity of the injection casing.
(2) For wells constructed with tubing and no
packer, a retrievable plug or packer shall be set immediately above the
uppermost perforation or open hole zone. A fluid pressure of 300 psig shall be
applied. The duration of the test shall be at least 30 minutes. Maintenance of
the fluid pressure during the test shall provide assurance of the integrity of
the injection casing.
(3) For
wells constructed with tubing and no packer, a method of pressure testing known
as fluid depression may be conducted with prior approval and under guidelines
established by the appropriate district office. The fluid in the well shall be
depressed with gas pressure to a point in the wellbore immediately above the
perforations or open hole interval. The minimum calculated pressure required to
depress the fluid in the wellbore shall be no less than 100 psig.
(4) For simultaneous injection wells, the
following requirements shall be met:
(A)
Mechanical integrity shall initially be demonstrated at a pressure of 300 psig
before installation of downhole simultaneous injection equipment and shall be
demonstrated in the same manner each time that the downhole simultaneous
injection equipment is removed; and
(B) after the initial mechanical integrity
test, the operator shall monitor the well once each month and record the
oil-to-water or gas-to-water ratio. The operator shall report the oil-to-water
or gas-to-water ratio to the commission within 30 days for the first month and
then annually at the time of filing the annual report according to K.A.R.
82-3-409. The operator shall immediately report an oil-to-water or gas-to-water
ratio at or in excess of 10% over the prior month's ratio to the appropriate
district office.
(5) In
lieu of paragraph (b)(3), the casing may be tested before perforating, upon
approval of the conservation division. A fluid pressure of 300 psig shall be
applied. If the operator requests a pressure in excess of 300 psig on the
injection application, a test pressure up to the requested pressure may be
required. The duration of the test shall be at least 30 minutes. Maintenance of
the fluid pressure during the test shall provide assurance of the integrity of
the injection casing.
(c) The operator of any well failing to
demonstrate mechanical integrity by one of the above methods shall have no more
than 90 days from the date of initial failure in which to perform one of the
following:
(1) Repair and retest the well to
demonstrate mechanical integrity;
(2) plug the well; or
(3) isolate the leak or leaks to demonstrate
that the well will not pose a threat to fresh or usable water resources or
endanger correlative rights.
(d) Mechanical failures or other conditions
indicating that a well is not, or may not be, directing the injected fluid into
the permitted or authorized zone shall be cause to shut in the well. The
operator shall orally notify the conservation division of any of these failures
or conditions within 24 hours of knowledge of any failure or condition. The
operator shall submit written notice of a well failure to the conservation
division within five days of the occurrence together with a plan for testing
and repairing the well. Results of the testing and well repair shall be
reported to the conservation division, and all information shall be included in
the annual monitoring report to the conservation division. Any mechanical
downhole well repair performed on the well that was not previously reported
shall also be included in the annual report.
(e) If the district office has approved the
use of any chemical sealant or other mechanical device to isolate the leak
before use, the injection pressure into the well shall not exceed the maximum
mechanical integrity test pressure. Additionally, the well shall demonstrate
mechanical integrity on an annual basis for the duration the well is completed
in this manner.
(f) Each operator
choosing a pressure mechanical integrity test on a well permitted for injection
before December 8, 1982 or on a well having passed an initial pressure
mechanical integrity test as specified in subsection (b) shall conduct the test
in the following manner:
(1) Wells located in
areas having saltwater-bearing zones with sufficient bottom-hole pressure to
sustain a static fluid level at or above fresh or usable water bearing zones
shall be pressure tested as specified in paragraphs (b)(1) and (2), except that
the maximum required test pressure shall be limited to 300 psi.
(2) Wells located in areas without
saltwater-bearing zones with sufficient bottom-hole pressure to sustain a
static fluid level at or above fresh or usable water bearing zones shall be
pressure tested as specified in paragraphs (b)(1) and (2), except that the
maximum required test pressure shall be limited to 100 psi.
(3) For wells constructed with tubing and no
packer, a method of pressure testing known as fluid depression may be conducted
with prior approval and under guidelines established by the commission. The
fluid in the well shall be depressed with gas pressure to a point in the
wellbore immediately above the perforations or open-hole interval. The minimum
calculated pressure required to depress the fluid in the wellbore shall be no
less than 100 psi unless otherwise approved by the appropriate district office.
(g) No injection well
shall be operated before having passed a mechanical integrity test. The
operator's failure to test a well to show its mechanical integrity or to report
the oil-to-water or gas-to-water ratio as required under paragraph (b)(4)(B)
above shall be punishable by a $1,000 penalty, and these wells shall be shut in
until the required test has been passed or the reports have been furnished.
Notes
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