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CLICK TO EDIT MASTER TITLE STYLE Railroad Commission of Texas RICK BEHAL MECHANICAL INTEGRITY TESTS ON INJECTION AND DISPOSAL WELLS (FORM H-5)

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Mechanical Integrity Tests (aka: MITs, H-5 Tests, Pressure Tests) On Injection & Disposal Wells Form H-5 Timing, Testing, & Reporting Injection and Disposal Well Testing 2

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When Are Mechanical Integrity Tests Required? Prior to beginning injection At least every 5 years by Statewide Rules 9 & 46 More frequently by Permit Special Conditions (e.g. Annually for wells with short surface casing) After a work over Whenever mechanical integrity is in doubt Injection and Disposal Well Testing 3

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Test Due Dates RRC Computer Mails the Operator a Friendly Reminder Letter Six months before a Five Year test is due Three months before an Annual test is due Operator is responsible for testing timely!! Injection and Disposal Well Testing 4

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RRC Computer Mails the Operator a Delinquency Notice: Mailed to the operator 60 days after the test due date if no test is received. Injection and Disposal Well Testing 5

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Certified Letter Notice of Intent to Cancel P-4 Certificate of Compliance. Mailed 30 days after the Delinquency Notice if no test is received. States lease to be Severed or well to be Sealed 30 days from the date of the Certified Letter. Injection and Disposal Well Testing 6

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Notification & Filing of the H-5 Test Give 48 hour notice to the District Office. If test is not witnessed by RRC, submit the Pressure Recording Chart & H-5 and a copy to the District Office. If test is witnessed, submit H-5 to District Office. A Pressure Recording Chart is not required but may be requested. File with District Office within 30 days. Injection and Disposal Well Testing 7

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Inspection Report Also called the Witness Report. It is completed by the District Representative who witnessed the H-5 pressure test. When the District receives the Form H-5, they attach this Witness Report to it and send it to Austin for review. 8

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Form H-5 Top Half Be sure to fill in all the Blanks ! Injection and Disposal Well Testing No name Petroleum UIC # 19625 13579 123 North Main St Midland, Texas 12345 8A Yoakum Wasson 9359700142-501-32579 Boulder Unit 12345 15 X 03/17/2013 9-5/8 200 5-1/2 4950 2-7/8 4800 Baker Locset 4800 2425 4850 4950 4850 4950 9

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ExampleApplied Braiden head 15005400 Produced WaterTreated Water X Bryan Turner X X Sign Name Here Print Name Here Regulatory Tech Phone # 04/03/2013 Form H-5 Bottom Half State any repairs to well, liner, reason for retest etc., here. 10

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Resources for H-5 Testing Info Injection/Disposal Well Permit, Testing & Monitoring Seminar Manual RRC Home Page 1.Click 2.Click Injection and Disposal Well Testing Click Forms To find & print a blank H-5 Form, 11

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Click Injection and Disposal Well Testing 12

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Continues on Next Slide (Recommended Reading) 13

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Continued from Previous Slide 14

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Test Equipment Requirements Pressure Recorder- Instruction 4(a) One-pen recorder for casing test pressure Test pressure within 30-70% of chart Will accept 20-80% only on 1000 psi chart with 1000 psi spring Clock rotation must not exceed 24 hours Chart must be signed by operators field representative Injection and Disposal Well Testing 15

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Test Equipment Requirements Pressure Gauges Gauges required on tubing and on each casing annulus Gauges to agree chart recorder Test pressure within 30-70% of gauge range Injection and Disposal Well Testing 16

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Test Pressure Requirements Permitted pressure 200 psig or less: Test at 200 psig or more Permit pressure between 200 & 500 psig: Test at the permitted pressure Permitted pressure 500 psig or more: Test at a minimum of 500 psig At least 200 psi pressure differential: Test pressure 200 psi higher or lower than tubing Injection and Disposal Well Testing 17

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Standard Pressure Test Injection and Disposal Well Testing To help visualize: The Test Pressure in Dark Blue The Tubing Pressure in Light Blue/Green 18

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Explain the Two Part Test Option Injection and Disposal Well Testing Example: Tubing pressure close to the required test pressure: Run first part at the required pressure Run second part at a pressure either 200 psi higher or 200 psi lower than the tubing pressure 19

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Example of Two Part Test (Lets assume tubing pressure is at 500 psig & authorized injection pressure is 1500 psig) Injection and Disposal Well Testing First part of test run at 540 psig Second part of test run at 240 psig 20

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Injection and Disposal Well Testing The initial test pressure was at 540 psig for 30 minutes. This satisfied the 500 psig minimum test pressure. The pressure was then dropped to 240 psig for another 30 minutes. This satisfied the 200 psi between the 520 psig tubing pressure and the casing test pressure. Indicating Two Part Test Pressures On H-5 Form 21

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Test Requirements Length of Test Liquid-filled annulus: required for wells that inject liquids. Test pressure must stabilize (within 10% of initial test pressure) at or above required test pressure for at least 30 minutes Gas-filled annulus: test pressure must stabilize (within 10% of initial test pressure) at or above required test pressure for at least 60 minutes Use of high viscosity packer fluids is prohibited. Injection and Disposal Well Testing 22

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Example of Good Test Injection and Disposal Well Testing Note how the red recorder line is stabile on the 580 psig line of the chart. Note the Test Date, Clock Rotation, and the Well ID written on the chart. --30% -- --70% -- 23

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Inconclusive Test If the pressure will not stabilize for 30 minutes but stays within 10% of the test pressure, it does not Pass. It is considered Inconclusive and must be repaired and re-tested within 60 days. Injection and Disposal Well Testing 24

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Example: Inconclusive Test Result Pressure Failed to Stabilize but stayed within 10% of Original Note 6% psi pressure increase If pressure had risen or dropped 10% or more, the test would have Failed. Note high tubing pressure Injection and Disposal Well Testing 25

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Additional Common Causes of Inconclusive Tests Results Injection and Disposal Well Testing Test pressure was less than required Pressure differential less than 200 psi Test pressure not within 30-70% of chart Test conducted for less than required time District Office not notified 48 hours in advance Test pressure never stabilized Packer depth shallower than that Permitted Item on Form H-5 either blank or incorrect 26

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What Defines a Failed Test? If the test pressure rises or drops more than 10% of the original test pressure, the pressure test is given a FAIL result. Injection and Disposal Well Testing 27

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Example of Failed Test Two attempts to pressure up on casing failed Note final test pressure equal to the tubing pressure, suggests a hole in tubing Injection and Disposal Well Testing 28

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When the Test Fails Operator receives a Fail Letter stating: Repair & successfully Retest or Plug the well & submit W-3. If this is not done within 60 days: Operator receives a Certified Letter stating that in 30 days, lease will be Severed or well will be Sealed and a $750 fee is imposed. Injection and Disposal Well Testing 29

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Possible Strategies for Compliance For a Packer set Too High: Either reset packer at correct depth or Amend Injection Interval up to the packer depth For a casing leak: Amend Injection Interval to include the casing leak Repair leak with cement squeeze or Cement a liner from TD to ground surface Injection and Disposal Well Testing 30

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Shut In/ Temporarily Abandoned Wells Must perform H-5 test as scheduled to stay in compliance Can be tested without tubing & packer if Status is not Active (next slide) Underground Injection Well Testing 31

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Pressure Testing the Casing String Without Tubing & Packer Injection and Disposal Well Testing Pressure up on a retrievable bridge plug set within 100 feet of the Permitted Injection Interval to test the integrity of the casing. If the well is re-equipped with tubing & packer in preparation for injection, it must be retested. Well Status: Shut-in or TAd 32

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TCAM (Tubing-Casing-Annulus- Monitoring) Credit Eligibility To delay a 5 year test for one year Well is eligible for TCAM Credit if: Annual report Form H-10 monitoring data complete & correct Operator requests the District Office to perform a well inspection prior to the test due date Wellhead monitoring equipment approved This can be repeated up to 4 more years & then another pressure test is required. Injection and Disposal Well Testing 33

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Schedule Letter with well qualified for TCAM Credit Basic text for all schedule letters 34

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Schedule Letter showing TCAM Credit Well Note: Asterisk * indicates well qualifies for TCAM Credit. 35

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Injection Permit Cancelation/Suspension The injection/disposal permit can be canceled within the test schedule time of its last good H-5 test by submitting a request to the H-5 department at the Austin RRC Office The permit can be voluntarily suspended by submitting a request within 3 months of a successful H-5 test A suspended permit can be re-instated with another good H- 5 test and a request Before Injection Authority can be canceled or suspended, the well must be classified as something other than Active, e.g. Shut-in, Inactive Underground Injection Well Testing 36

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Testing Hydrocarbon Storage Wells, Rule 95, 96, & 97 Hydrocarbon Storage These types of Injection Wells are special cases that require the operator to contact: David Hill 512-463-3011 david.hill@rrc.state.tx.us Injection and Disposal Well Testing 37

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Testing Hydrocarbon Storage Wells, Rule 96 Gas Storage into Depleted Reservoirs Minimum test pressure is 500 psi for tubing/packer injectors Casing injectors must test at the permitted maximum injection pressure Notify the District Office at least 48 hours prior to the test File a complete record of the test (on Form H-5) within 30 days Injection and Disposal Well Testing 38

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Underground Injection Control H-5 Testing Staff Dave Hill, Manager512-463-3011 David.hill@rrc.state.tx.us Julie Requejo, Admin512-463-6821 julie.requejo@rrc.state.tx.us Steve Schmidt512-463-6767 steven.schmidt@rrc.state.tx.us Cheryl Burns512-463-6454 cheryl.burns@rrc.state.tx.us Darren Tjepkema512-463-2259 darren.tjepkema@rrc.state.tx.us Injection and Disposal Well Testing 39