How Well is Your Well? UIC Class I Well Construction Standards Andy Trevino P.E. TCEQ Underground Injection Control

TCEQ UIC Requirements for : Drilling Cementing Testing Changes to Approved Drilling and Completion Plans Daily Communications Completion Reports

Drilling Requirements Step by Step Drilling plan Objective: - To use sound practices to minimize deviated holes, washouts, lost circulation and stuck pipe to minimize well cementing issues and maximize successful well completions.

Drilling Plan should: Address site specific drilling hazards Fracture zones Lost circulation zones High or Under Pressured zones Potential for drilling thru existing waste plumes.

Drilling Plan should include: Frequent deviation checks Fluid loss preventative measures Mud weights proposed for each stage of drilling Circulation pressures and pump rates that will keep the circulated mud in laminar flow and prevent formation fracturing Drilling mud should be reconditioned commensurate with proper cementing practices.

Cementing Requirements Cementing Plan - Cementing procedures - Type of cement - Volumes - Additives - Slurry weight - Cementing equipment

Cementing Requirements Cementing should be pump and plug method Cementing volume required: - 120% with 2 dimensional caliper or 150% without Cementing Objective: - Prevent movement of fluids into or between USDW or FW aquifers - Prevent movement of fluids out of the injection zone

Cementing Plans should Discuss suitability of cement based on injection fluid properties, BH temperature, pressures Discuss procedures to be taken to prevent cement channeling - For example, use of centralizers, scratchers, reciprocating the casing, maintaining pump rates, mud conditioning, preflushing and use of wiper plugs. Discuss procedures to be taken to prevent formation fracturing

Cementing Plans should Discuss any site specific cementing issues anticipated - Such as loss of circulation, over or under pressured zones or formation breakdowns Include contingency cementing plan to be implemented if 100% of the annular space is not filled

Testing and Logging Requirements 30TAC 331.62(a)(7) During drilling: - Frequent deviation checks Prior to setting surface casing: - Triple combo log run, SP, Resistivity, Gamma Ray - Caliper log, to determine hole volume After setting surface casing and cementing: - CBL with variable density log - Temperature log - Pressure test surface casing to 1,000 psig

During Drilling 30TAC 331.62(a)(7)(c) – Core sampling Full cores shall be taken from selected intervals from the lowermost overlying confining zone and selected sections of injection zone. If not able, sufficient sidewall cores shall be at selected intervals.

Core and Fluid analysis Core analysis should determine perm, porosity, Poisson’s ratio, formation compressibility, etc… Collect formation fluid to determine chemical, physical and radiological properties Compatibility tests of waste fluids with formation fluids, minerals of both injection & confining zone Determine if gases will be generated

After Drilling is completed Prior to setting longstring: - Run SP, Resistivity, Gamma ray, compensated density and/or neutron porosity, Dipmeter/Fracture finder and caliper logs After cementing longstring: - CBL w/ variable density log, casing inspection log, temperature log and inclination survey

Prior to operating the well After Well Completion Mechanical integrity testing of well Annular pressure test, radioactive tracer survey, temperature or noise log Prior to operating the well Conduct injectivity/falloff test to determine well capacity and verify reservoir characteristics

Injectivity and Falloff tests Test results should be used to determine bottom hole pressure, bottom hole temperature, static fluid level, fracture pressure, permeability, faulting boundary (if any), dual porosity, skin factor and any completion anomalies

Changes to Approved Drilling & Completion Plans 30TAC 331.62(a)(3) – provides for the requirement for changing plans and specifications for well construction and well workover Any changes from approved plans and specifications from permit application must be requested as a minor modification or amendment Changes during drilling may be granted by oral approval

Daily Communication during Well Construction 30TAC 331.62(a)(10) – Executive Director shall have opportunity to witness all cementing of casing strings, logging and testing. Need to provide a 30 day schedule and a 24hr notice It is recommended that daily reports are provided by e-mail during well construction, logging and testing Rule requires 24hr updated notice to allow personnel to make travel plans

Completion Reports 30TAC 331.45 – Requires report submittal within 90 days As built drawings All logging and test data Injectivity and falloff test results Waste compatibility results with reservoir fluids and minerals Recalculation of AOR and cone of influence if needed A copy of the checklist we use to review completion reports will be provided

TCEQ’s “Construction Guidance for Class I Injection Wells” Link to guidance documents are available at: https://www.tceq.texas.gov/assets/public/permitting/ waste/uic/Well%20Construction%20Guidance.docx Or search for “Construction Guidance for Class I Injection Wells” on our website at: www.tceq.texas.gov

Thanks for your Attention Andy Trevino P.E. Engineer Texas Commission on Environmental Quality Office of Waste Radioactive Materials Division Underground Injection Control Permits Section 512-239-6172 andy.trevino@tceq.texas.gov