Are injection disposal wells subject to well stimulation treatment requirements?
Injection disposal wells necessarily support and enhance oil and gas production because they provide an often crucial disposal method for produced water and other fluids attendant to and integrally associated with production. Treatments that increase the downhole formation permeability of injection disposal wells improve the capacity and functionality of such wells, in turn enhancing production, and may therefore trigger well stimulation treatment requirements (Cal. Code Regs. Title 14, 1761).
Does an injection well that exceeds pore pressure need to report the pressure per Cal. Code Regs., title 14, § 1777.4?
All injection wells need to exceed pore pressure in order to inject. Can CalGEM consider the Project Approval Letter (PAL) for injection projects as a blanket permit for the injection wells covered by the PAL?
The regulations provide that operations regulated under Cal. Code Regs., Title 14, § 1724.6 through 1724.10 the Underground Injection Control (UIC) regulations, are not subject to reporting under Cal. Code Regs., Title 14, §1777.4. This would include injection operations approved under an injection project approval letter (PAL), as well as testing required under the PAL or the UIC regulations, such as step rate tests, or injectivity tests.
However, a PAL is not a "blanket permit" that necessary excuses operators from reporting under Cal. Code Regs., Title 14, § 1777.4. If an operation is performed that is not addressed by the PAL or the UIC regulations (i.e. an extra step rate test that is not required), and the operator is not otherwise intending to send the results to CalGEM, then it would need to be reported under Cal. Code Regs., Title 14, § 1777.4.
Is it necessary to submit a maintenance form for acid dumps on injection wells? Does this include injection well acid dumps?
An acid dump, or any other acid treatment, would need to be reported regardless of the type of well. As explained in the previous answer, injection wells are not "per se" or automatically exempt from the reporting requirements of Cal. Code Regs., Title 14, § 1777.4.
We need to report within 60 days whenever well maintenance exceeds formation pore pressure. Does this include operations that penetrate beyond the perforations in the casing and exceed the pore pressure (i.e., if it didn’t exceed the pore pressure, then it wouldn't leave the casing)? If so, it seems like CalGEM will receive thousands to hundreds of thousands of reports from operators. Does this only apply to producing wells?
Well operations that are already authorized by a permit from CalGEM do not need to be reported under Cal. Code Regs., Title 14, § 1777.4 for the reason that those operations are already being captured in the well history. However, operations where pore pressure is exceeded and there is no permit to cover those specific operations must be reported under Cal. Code Regs., Title 14, §1777.4.
Are gravel pack operations subject to reporting under Cal. Code Regs., Title 14, § 1777.4?
Yes. Placement of gravel packs involving application of pressure to the formation that exceeds formation pore pressure, even though it is below formation fracture gradient, should be reported under Cal. Code Regs., Title 14, §1777.4 as well maintenance unless the gravel pack operation is explicitly covered by an existing permit. The operator should use the
WellSTAR Maintenance Form to report detailed data regarding the operation.