Recent UIC Class I Well Construction Issues Andy Trevino P.E. TCEQ Underground Injection Control

TCEQ is currently experiencing high levels of UIC activity Permit Renewals New Permit Applications Permit Amendments and Modifications New well completions Well sidetracks Completion Report submittals

Recent UIC Class 1 well construction issues include: Drilling issues Well construction and completion issues Completion report issues

Drilling Issues: Mechanical breakdowns Hole washouts Stuck pipe Logging tool issues Core recovery problems Lost circulation

Recent mechanical breakdowns include: Electrical problems with equipment Mechanical problems with pumps Drawworks issues Top drive problems Shaker motor repairs Wireline equipment failures Service company equipment failures

Recent downhole issues Hole washouts - Could contribute to poor cementing later - Hole collapse - Stuck pipe

Logging tool issues Logging tool malfunction Wireline malfunctions Tools stuck downhole

Core Recovery problems Coring “Gumbo” shales Coring friable sands Recovering cut cores Sidewall coring wireline recovery

Well Completion issues Stuck tools Stuck pipe Cementing

Stuck tools Stuck tools delay completion time Delays have been between hours to a week Fishing operations adds to the delay, adds to complexity and adds to costs

Stuck pipe Stuck pipe delay completion time Delays have been from hours to weeks Techniques used to free the pipe include pulling on the pipe, use of jars and overshot tools

Cementing Cementing issues are not always obvious in the field We have seen both excessive and insufficient cement returns at the surface Insufficient cement below DV tool

Common Completion Reports Deficiencies Failure to provide well log interpretations Failure to provide final well location plat Failure to provide proper report certification by a licensed engineer or geoscientist Failure to do all required tests on core samples Failure to provide evidence of deed recordation

Failure to provide well log interpretation Rule 30 TAC 331.62(a)(7)(A) requires logs be interpreted by the service company which processed the log or other qualified persons It is not enough just to submit the logs In my experience, all completion reports have been deficient in providing the interpretation initially

Failure to provide final well location plat Commonly a “Proposed” location plat is submitted as opposed to a “Final” location plat Must have latitude and longitude of the well on the plat Resurveying not necessary unless location is significantly different

Failure to provide proper report certification Report must be “prepared and sealed” by a licensed professional engineer or licensed professional geoscientist Rule 30 TAC 331.65(b)(1) requires this Additionally, the certification must state the well’s construction meets the construction standard in 30 TAC 331.65(b)(1) Past submittals have not stated these requirements exactly but only vaguely

Failure to do all required tests on core samples Core analysis should determine permeability, porosity, Poisson’s ratio, formation compressibility, etc… Compatibility tests of waste fluids with formation fluids, minerals of both injection & confining zone Analysis must determine if gases will be generated Typically, Poission’s ratio, compatibility with confining zone minerals and gas generation determination are not done

Failure to provide evidence of deed recordation Rule 30 TAC 331.65(b)(1) requires proof of deed recordation on the deed stating the well’s location, well permit number and permitted wastes streams Typically proof of deed recordation is left out

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