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

2. 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

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

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

5. 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

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

7. Logging tool issues Logging tool malfunction Wireline malfunctions
Tools stuck downhole

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

9. Well Completion issues
Stuck tools
Stuck pipe
Cementing

10. 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

11. 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

12. 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

13. 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

14. Failure to provide well log interpretation
Rule 30 TAC (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

15. 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

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

17. 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

18. Failure to provide evidence of deed recordation
Rule 30 TAC (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

19. 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