CLICK TO EDIT MASTER TITLE STYLE Railroad Commission of Texas
RICK BEHAL MECHANICAL INTEGRITY TESTS ON INJECTION AND DISPOSAL
WELLS (FORM H-5)
Slide 2
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
Slide 3
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
Slide 4
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
Slide 5
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
Slide 6
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
Slide 7
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
Slide 8
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
Slide 9
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
Slide 10
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
Slide 11
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
Slide 12
Click Injection and Disposal Well Testing 12
Slide 13
Continues on Next Slide (Recommended Reading) 13
Slide 14
Continued from Previous Slide 14
Slide 15
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
Slide 16
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
Slide 17
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
Slide 18
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
Slide 19
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
Slide 20
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
Slide 21
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
Slide 22
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
Slide 23
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
Slide 24
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
Slide 25
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
Slide 26
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
Slide 27
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
Slide 28
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
Slide 29
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
Slide 30
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
Slide 31
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
Slide 32
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
Slide 33
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
Slide 34
Schedule Letter with well qualified for TCAM Credit Basic text
for all schedule letters 34
Slide 35
Schedule Letter showing TCAM Credit Well Note: Asterisk *
indicates well qualifies for TCAM Credit. 35
Slide 36
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
Slide 37
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
[email protected] Injection and Disposal Well Testing
37
Slide 38
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