In addition to other statutory and regulatory requirements, the operator of any idle well is required to comply with the statutory requirements for idle wells found in Public Resources Code (PRC) sections 3206, 3206.1, 3206.3. and 3206.5 and the regulatory requirements found in the California Code of Regulations (CCR), title 14, division 2, chapter 4, subchapters 1 and 2 in the management, testing, and elimination of their idle wells.
Questions regarding ADA (Americans with Disabilities Act) accessibility of required forms should be directed to
CalGEMidlewells@conservation.ca.gov.
Statutory
An operator in possession of any idle well is required to either submit an annual idle well fee for each well that was idle at any time in the last calendar year or file an Idle Well Management Plan (IWMP) for the elimination of all of the operator’s long-term idle wells. An operator must submit their annual idle well fees or IWMP by May 1 of each year. The requirements for both can be found in PRC section 3206. Information regarding annual idle well fees and IWMPs is detailed below.
Annual Idle Well Fees
Idle well fees are due annually, no later than May 1 of each year. An operator is assessed idle well fees for each of the operator’s idle wells that was idle at any time in the prior calendar year.
Idle well fees are calculated as follows:
- One hundred fifty dollars ($150) for each well that has been an idle well for three years or longer, but less than eight years.
- Three hundred dollars ($300) for each well that has been an idle well for eight years or longer, but less than 15 years.
- Seven hundred, fifty dollars ($750) for each well that has been an idle well for 15 years or longer, but less than 20 years.
- One thousand, five hundred dollars ($1,500) for each idle well that has been an idle well for over 20 years or longer.
Failure to file the required idle well fee is conclusive evidence of desertion which permits the State Supervisor of Oil and Gas to order the well plugged and abandoned pursuant to Section 3237.
Idle Well Fee Invoices: Digital copies of all invoices can be requested by emailing
calgemfilerequest@conservation.ca.gov. When submitting a request, please include the operator code and invoice year in the email subject.
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How are the number of years idle for idle well fees calculated
The number of years a well has been idle is calculated from the idle start date to December 31 of the prior calendar year or the date that the well no longer meets the definition of idle well, whichever is lesser. The idle start date is the first month after the well has no reported production and/or injection for 24 consecutive months.
The Idle Well Fee Invoice will calculate the years idle through December 31.
- If the idle well is plugged and abandoned during the prior calendar year, then the years idle is calculated from the idle start date to the plug and abandonment date.
Example: The well has an idle start date of January 1, 2010, and a plug and abandonment date of July 1, 2018. The years idle for the 2019 Idle Well Fee is 8.50 years. The idle well fee for the well is three hundred dollars ($300.00).
- If the idle well is returned to use for 6 consecutive months during the prior calendar year, then the number of years idle is calculated from the idle start date to the date the well is no longer idle.
Example: The well has an idle start date of January 1, 2010 and achieved 6 consecutive months of production between February 2018 and July 2018. The well no longer meets the definition of idle well on August 1, 2018. The years idle for the 2019 Idle Well Fee is 8.59 years. The idle well fee for the well is three hundred dollars ($300).
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Who will receive the Annual Idle Well Fee Invoice?
The invoice will be mailed to the agent of record In WellSTAR for the operator that was in possession of the well(s) on January 1 of the current calendar year.
If a transfer involving idle wells occurs between January 1 of the current year and May 1 of the current year, it is the responsibility of the operator in possession of the well(s) on January 1 of the current year to ensure payment is made to CalGEM.
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How do I report an error in the inventory or fee calculation?
Please ensure that all production and injection records are true and complete and that all records associated with the plugging and abandonment of a well have been submitted to demonstrate that the well is no longer idle.
Email
CalGEMIdleWells@conservation.ca.gov with the information regarding the error. Please include the well(s) API number, whether the error is the “Fee” and/or “Inventory,” and a brief description of the error.
Idle Well Management Plans (IWMP)
An operator may file an IWMP, in lieu of paying idle well fees no later than May 1 of each year. By filing an IWMP, the operator is committing to eliminating a specific number of long-term idle wells per year. The IWMP and any revisions must be approved by CalGEM. The IWMP may cover a period up to 5 years and is subject to annual review by CalGEM. The required rate of elimination for an IWMP is based on the operator’s idle well inventory as of January 1 of each calendar year. The rate of elimination in an operator’s IWMP is based on the operator’s inventory as of January 1.
The rate of elimination is determined as follows:
- Operators with 250 or fewer idle wells are required to eliminate 4 percent of their long-term idle wells each year, and in no case, less than 1 long-term idle well.
- Operators with 251 - 1,250 idle wells are required to eliminate 5 percent of their long-term idle wells each year, and in no case, less than 1 long-term idle well.
- Operators with 1,251 or more idle wells are required to eliminate 6 percent of their long-term idle wells each year, and in no case, less than 1 long-term idle well.
An operator that fails to comply with their IWMP will lose the option to file a new IWMP for the next 5 years and is required to pay idle well fees for each year the operator failed to comply with their IWMP. (Pub. Resources Code, § 3206, subd. (a)(2)(B)(v).)
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What are the testing requirements for a long-term idle well in an IWMP?
If an idle well on an approved IWMP is scheduled to be plugged and abandoned and the operator is in compliance with their IWMP, then the operator is not required to meet the testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, section 1772.1.2 and 1772.1.3.
If an idle well on an approved IWMP is scheduled for return to use, then the operator must include the well on the operator's Testing Compliance Work Plan. If the well is due for testing during the six consecutive months of production for returning the well to use, the well must be tested in accordance with the requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and, if applicable, a 15-Year Engineering Analysis must be conducted in accordance with the requirements of CCR, title 14, section 1772.1.2 and 1772.1.3.
If an idle well was initially scheduled to be plugged and abandoned as part of an approved IWMP, but the operator has amended its IWMP to schedule the well to return to use, and CalGEM has approved the amendment, the operator must submit a revised Testing Compliance Work Plan with the well included. The well must be scheduled for testing in accordance with the requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and a 15-Year Engineering Analysis must be conducted in accordance with the requirements of CCR, title 14, sections 1772.1.2 and 1772.1.3.
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When is a well eliminated?
A well is eliminated under an IWMP if the well is abandoned in accordance with PRC section 3208 or if the well maintains production of oil or gas or been used for injection for a continuous 6-month period. (PRC §§ 3008, subd. (d); 3206, subd. (a)(2)(A).)
Transferring idle wells to another operator does not eliminate the well.
Converting an idle well to an observation well does not eliminate the well.
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When must elimination be completed?
Elimination must be completed within the calendar year, January 1 through December 31. CalGEM’s annual review is conducted at the end of each yearly cycle.
Wells being returned to production or injection must achieve 6 consecutive months of service within the IWMP calendar year - meaning the latest a well can be returned to production or injection and achieve the required 6 consecutive months of service within the IWMP calendar year is July.
How do I submit an IWMP?
There are three ways an operator may submit a completed IWMP form. The preferred method is to submit the completed form electronically through WellSTAR using the ‘Idle Well’ form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at CalGEMIdleWells@conservation.ca.gov, or paper copies may be submitted to:
Geologic Energy Management Division
Attn: Idle Well Program
715 P Street, MS 1803
Sacramento, CA 95814
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What if I need to change my IWMP?
With CalGEM’s approval, changes may be made to the wells scheduled for elimination during the year. Please contact the Idle Well Program at
CalGEMIdleWells@conservation.ca.gov with the well(s) to be removed, added, or elimination method changed. When submitting a request to add or remove well(s), please include the API, well designation (lease name and well number combination), and the elimination method, either plugging and abandonment or return to use. Changes will be reviewed on a case-by-case basis and must be approved by CalGEM. Please be prepared to submit a revised Testing Compliance Work Plan.
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How do I identify wells I want to plug and abandon in future years of my IWMP?
CCR, title 14, section 1772.3, subdivision (b) requires operators to specify whether the long-term idle well(s) on an IWMP are being eliminated through plugging and abandonment or return to use. An operator may schedule long-term idle wells (LTIW) for elimination via plugging and abandonment for up to five years into the future. An operator who is using the IWMP form, may identify these wells and the proposed year of elimination on Tab ‘1D-Elimination Bank.’
An idle well that is projected to become a LTIW may be included on the ‘1D-Elimination Bank.’ However, the well must be a LTIW as of January 1 of the year the well is scheduled for elimination. An idle well eliminated before it becomes a long-term idle well does not count towards the elimination requirements for an IWMP.
A well scheduled on tab ‘1D-Elimination Bank’ must be scheduled for plugging and abandonment, and will not be required to meet the testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, sections 1772.1.2 and 1772.1.3. Wells scheduled for elimination through return to use must meet testing requirements and may not be scheduled on tab ‘1D-Elimination Bank’.
Regulatory
PRC section 3206.1 mandated CalGEM review, evaluate, and update its regulations pertaining to idle wells. Revised idle well regulations became effective April 1, 2019. These regulations implement new testing requirements for idle wells and provide specific parameters for testing. The regulations provide a 6-year compliance period for testing wells idle as of April 1, 2019 and a Testing Waiver Plan for those wells an operator commits to plugging and abandoning within eight years. Operators are also required to submit an idle well inventory and evaluation for each of their idle wells. The regulations also provide requirements for monitoring and mitigating inaccessible idle wells, a regulatory definition for partially plugging idle wells, and requirements for operators to submit a 15-Year Engineering Analysis for each idle well idle for 15 years or more.
Idle Well Testing
Fluid-Level Test
For all wells that became idle on or before April 1, 2019, operators must conduct a fluid-level test to determine whether the fluid level is above the base of an Underground Source of Drinking Water (USDW) before April 1, 2021. All wells that became idle after April 1, 2019 are required to have a fluid-level test within 24 months of becoming an idle well. The fluid-level test must be repeated every 24 months for as long as the well is idle. The fluid-level test may be performed using acoustical, mechanical, or other reliable methods.
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What if the well does not penetrate a USDW?
A fluid-level test is not required if the operator demonstrates to CalGEM that the wellbore does not penetrate a USDW. Until an operator successfully demonstrates to CalGEM that the well does not penetrate a USDW, the well is presumed to penetrate a USDW.
Casing Pressure Test
Within 24 months of a well becoming an idle well, an operator must conduct a casing pressure test on the well to demonstrate mechanical integrity. The test must be conducted from the surface to a depth that is within 100 feet (MD) above the uppermost perforation, immediately above the casing shoe of the deepest cemented casing, or immediately above the top of the landed liner, whichever is highest. The frequency at which the casing pressure test must be repeated is dependent on the type of test used and the pressure at which the test was conducted.
If the casing pressure test is conducted with liquid:
- If the test is conducted at 200 psi above surface pressure, then testing is repeated within 48 months.
- If the test is conducted at 500 psi above surface pressure, then testing is repeated within 72 months.
- If the test is conducted at 1,000 psi above surface pressure, then testing is repeated within 96 months.
A casing pressure test is successful if the pressure gauge does not show more than a 3 percent change from the initial test pressure over a continuous 30-minute period. If the well is in an area of review for a cyclic steam injection well or a steamflood injection well, then an increase in pressure of as much as 10 percent is a successful test.
If the casing pressure test is conducted using the inert gas depression test method to satisfy the pressure testing requirement, then testing must be repeated within 48 months. For an inert gas depression test to be successful, the fluid level must be static and the pressure must stabilize at the calculated pressure with a change of no more than 1 percent over a continuous 60-minute period. A fluid level measurement must be taken at the end of the test to confirm the correct depth was maintained.
If mechanical integrity is demonstrated using an alternative testing method other than a casing pressure test, then testing must be repeated within 48 months. The alternative testing method must be approved by CalGEM on a case-by-case basis and must be demonstrated to be at least as effective as a pressure test at demonstrating the mechanical integrity of the well.
If the well is a low-priority idle well and an operator may satisfy the casing pressure testing requirements by conducting a caliper survey using testing protocols approved by CalGEM, then testing must be repeated within 48 months.
All wells that became idle on or before April 1, 2019, that an operator has not scheduled for plugging and abandoning as part of an approved Testing Waiver Plan (see the Testing Compliance Work Plan below) or an approved IWMP, must be scheduled to come into compliance with the casing pressure testing requirements by April 1, 2025.
Before conducing a casing integrity test, the operator shall give the appropriate district office 24 hours notice, or a shorter notice acceptable to the district office, so that CalGEM staff may witness the testing.
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What methods may I use to satisfy the casing pressure test requirement?
A traditional casing pressure test with liquid may be used to satisfy the casing pressure test requirement. An operator may conduct an inert gas depression test to satisfy the pressure testing requirement with CalGEM’s approval. However, the calculated pressure necessary to depress the fluid column to within 100 feet (MD) above the uppermost perforation, immediately above the casing shoe of the deepest cemented casing, or immediately above the top of the landed liner, whichever is highest, cannot be less than 500 psi. On a case-by-case basis, with CalGEM approval, an alternate mechanical integrity test method may be used to satisfy the pressure testing requirement. These alternate testing methods are required to be approved by CalGEM and to be at least as effective as a casing pressure test in demonstrating mechanical integrity. Examples of alternate testing methods that will be considered on a case-by-case basis include casing wall thickness inspection, employing such methods as magnetic flux, ultrasonic technologies, or a combination of an ultrasonic imaging tool and a cement evaluation log.
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What happens if my well fails a pressure test?
In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a casing pressure test, the operator must do one of the following:
- Bring the well into compliance;
- Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
- Plug and abandon the well in accordance with PRC section 3208; or
- Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.
To make amendments to your approved IWMP or Testing Waiver Plan, contact
CalGEMIdleWells@conservation.ca.gov.
Clean Out Tags
A clean out tag to demonstrate the operator’s ability to reach the current CalGEM- approved depth of the well, must be performed within 8 years of a well becoming idle. The clean out tag must be performed using open-ended tubing or a gauge ring demonstrated to CalGEM to be of the minimum diameter of the tubing necessary to properly plug and abandon the well. The operator must attempt to reach the CalGEM-approved depth, but shall at least reach 25 feet below the uppermost perforation in the lowermost zone not abandoned under CCR, title 14, sections 1723 and 1723.1.
The clean out tag must be repeated every 48 months for as long as the well remains an idle well. CalGEM may approve less frequent, clean outs on a case-by-case basis based on the successful results of previous testing and consideration of the factor described in CCR, title 14, section 1772.4. Similarly, CalGEM may require more frequent clean outs if known field or geologic conditions indicate risk to the mechanical integrity of the well.
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What happens if my well fails the clean out tag?
In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a clean out tag, the operator must do one of the following:
- Bring the well into compliance;
- Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
- Plug and abandon the well in accordance with PRC section 3208; or
- Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.
To make amendments to an approved IWMP or Testing Waiver Plan, contact
CalGEMIdleWells@conservation.ca.gov.
Testing Compliance Work Plan
For all wells that were idle on or before April 1, 2019, an operator shall conduct a casing pressure test and clean out tag by April 1, 2025. However, wells that are scheduled for plugging and abandonment under an approved IWMP or Testing Waiver Plan are excluded from the requests specified in CCR, title 14, sections 1772.1, 1772.1.1, and 1772.1.2. Wells that became or become idle after April 1, 2019, must be tested in accordance with the timeframes specified in CCR, title 14, section 1772.1.
For idle wells that were idle before April 1, 2019, by June 1, 2019, operators shall provide CalGEM with a Testing Compliance Work Plan (TCWP) that schedules the completion of the required initial casing pressure test and clean out tag testing over a 6-year period. Wells idle for less than two years as of April 1, 2019, do not require a cleanout tag during the compliance period. The TCWP shall exclude any well scheduled for plugging and abandonment under an approved IWMP or Testing Waiver Plan.
The TCWP shall include the following required annual benchmarks:
- Testing shall be completed on at least 5 percent of all wells covered by the TCWP by April 1, 2020.
- Testing shall be completed on at least 15 percent of all wells covered by the TCWP by April 1, 2021.
- Testing shall be completed on at least 30 percent of all wells covered by the TCWP by April 1, 2022.
- Testing shall be completed on at least 50 percent of all wells covered by the TCWP by April 1, 2023.
- Testing shall be completed on at least 75 percent of all wells covered by the TCWP by April 1, 2024.
- Testing shall be completed on all wells covered by the TCWP by April 1, 2025.
- At least one well shall be scheduled for testing each year until initial testing is completed on all wells covered by the TCWP.
Meeting the annual benchmarks requires completion of testing, proper plugging and abandonment, or partial plugging and abandonment of a well. Before conducting a casing integrity test, the operator shall give the appropriate district office 24 hours notice, or a shorter notice acceptable to the district office, so that CalGEM staff may witness the testing. Testing conducted prior to April 1, 2019 will be accepted for compliance with the annual benchmarks, provided the test was conducted in accordance with the parameters specified in CCR, title 14, sections 1772.1 and 1772.1.1.
Once testing is completed for an idle well covered by a TCWP, subsequent testing of the idle well shall be conducted in accordance with the timeframes for repeat testing specified in CCR, title 14, sections 1772.1(a)(2) and (a)(3).
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How do I submit the TCWP?
The TCWP form is available. To request a TCWP form, please send a request to
CalGEMIdleWells@conservation.ca.gov.
The preferred method is to submit the completed TCWP form electronically through
WellSTAR using the “Idle Well” form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at
CalGEMIdleWells@conservation.ca.gov. Paper copies may be mailed to:
Geologic Energy Management Division
Attn: Idle Well Program
801 K Street, MS 18-00
Sacramento, CA 95814
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Which wells go on the TCWP?
The Idle Well Program has compiled a preliminary TCWP Inventory that is available for download in the “Idle Well Inventories” section below. The file is a Microsoft Excel file and may be filtered by operator. The file is formatted to be pasted directly into the TCWP form and only includes wells eligible to be on a TCWP over the six (6) years of the Compliance Period. Each idle well listed includes a yes/no value as to whether it is projected to and required to be scheduled for a casing pressure test, clean out tag, and a 15-year Engineering Analysis over the six (6) year period.
All wells that met the definition of idle well on or before April 1, 2019, are required to come into compliance with the casing pressure test by April 1, 2025. If a well has been an idle well for less than 2 years as of April 1, 2019, then completion of the clean out tag is not required during the compliance period. Once a well has been idle for 8 years a cleanout tag is required. While there is no penalty for conducting a cleanout tag early, a cleanout tag on a well idle for less than 2 years as of April 1, 2019, will not count toward clean out tag benchmarks.
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What does the annual review of a TCWP entail?
The annual review of each TCWP will be conducted as of April 1 of each year. During the review, CalGEM will confirm that test results have been uploaded to WellSTAR for wells scheduled for testing. This includes, if applicable, confirmation that partial plugging and proper plugging and abandonment of wells has been completed in lieu of testing. CalGEM will document and notify each operator if the operator has met the annual benchmark.
If an operator has complied with the annual benchmarks, the operator will receive a letter documenting compliance and instructions for updating their TCWP for the next year.
If an operator has not complied with the annual benchmarks, in addition to any enforcement action CalGEM may take for failing to comply with the benchmarks, the operator will receive a letter documenting the number of tests the operator failed to complete to comply with their annual benchmarks. Each well that an operator fails to test constitutes a separate violation and is subject to the requirements of CCR, title 14, section 1772.1, subd. (b).
Operators may request an in-person review of the results by emailing
CalGEMIdleWells@conservation.ca.gov.
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What if I need to change my TCWP?
With CalGEM’s approval, changes may be made to the wells scheduled for testing during the year. Please submit a revised TCWP to the Idle Well Program at
CalGEMIdleWells@conservation.ca.gov with a narrative of well(s) to be rescheduled on the TCWP and well(s) to be moved to an approved IWMP or Waiver. When submitting a revised TCWP, please take care to ensure that the required number of wells are proposed each year to meet the annual benchmarks. Changes will be reviewed by CalGEM on a case-by-case basis and must be approved by CalGEM.
15-Year Engineering Analysis
By the end of the month in which an idle well has been idle for 15 years, the operator must provide a 15-Year Engineering Analysis demonstrating that the well is viable to return to operation in the future. The engineering analysis must document that the well could be used to access potential oil and gas reserves and the well has mechanical integrity as demonstrated by compliance with the pressure testing and clean out tag requirements found under CCR, title 14, section 1772.1(a)(2) and (a)(3).
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What must be provided in the 15-Year Engineering Analysis?
- The API number and name of the well
- Statement of the potential future use for the idle well
- Identification of each reservoir unit that might be accessed and the reservoir characteristics of each of the identified reservoir units
- A representative electric log to a depth below the deepest-producing zone, identifying all geologic units, formations, USDWs, freshwater aquifers, oil or gas zones, and each reservoir unit to be utilized
- Structural contour map drawn on a geologic marker at or near the top of each reservoir unit to be used, indicating faults, other lateral containment features, and area extent of the productive zone
- Casing diagram or flat file data set as specified in CCR, title 14, section 1772.1.3.
CalGEM may require the operator to include additional data in the engineering analysis on a case-by-case basis if CalGEM deems it necessary for the evaluation of whether it is viable to return the well to operation in the future.
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What will happen if CalGEM finds a well is not viable to return to operation in the future?
If CalGEM determines upon initial review of the engineering analysis that it is not viable to return the well to operation in the future, CalGEM will inform the operator of the basis of that determination. The operator will be allowed at least 30 days to provide additional information to substantiate that the well is viable to return to operation in the future.
If CalGEM determines upon final review of the engineering analysis and any additional information provided by the operator that a well is not viable to return to operation in the future, CalGEM will provide a notice of final determination to the operator. After the final determination, the operator shall either plug and abandon the well in accordance with PRC section 3208 within 12 months of receiving the notice of final determination or schedule the well for plugging and abandonment under an approved Idle Well Management Plan or an approved Testing Waiver Plan.
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When is the 15-Year Engineering Analysis due?
The 15-Year Engineering Analysis is a one-time submission due by the end of the month in which an idle well has been idle for 15 years.
For wells that as of April 1, 2019, have met the definition of an idle well for 9 years or more, the operator shall provide the Engineering Analysis to CalGEM by the later of the following:
- Within sixty (60) days after the date pressure testing on the idle well is scheduled in the operator’s Testing Compliance Work Plan; or
- By the end of the month in which the idle well has been idle for 15 years
Examples:
As of April 1, 2019, the well has been idle for 22 years. The casing pressure test is scheduled in the Compliance Work Plan for 2021. The engineering analysis is due within 60 days of the pressure test. As of April 1, 2019, the well has been idle for 10 years. The casing pressure test is scheduled for 2021, when the well will have been idle for 12 years. The engineering analysis is not due within 60 days of the pressure test; it is due by the end of the month in which the well has been idle for 15 years.
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Do I have to submit an Engineering Analysis for every well idle for 15 years or more?
If a well is scheduled for plugging and abandonment on an approved Idle Well Management Plan or Testing Waiver Plan (described in next section), an operator is not required to submit an engineering analysis for the well. By the same account, if an operator plugs and abandons a well in lieu of testing, then a 15-Year Engineering Analysis is not required.
If an operator submits information for a 15-Year Engineering Analysis demonstrated to be applicable to multiple wells in the same field subject to the engineering analysis, the operator may reference the applicable information in subsequent engineering analyses and is not required to submit duplicate information.
Testing Waiver Plan
A Testing Waiver Plan (TWP) is a plan in which an operator commits to plug and abandon their idle wells over a scheduled period of up to eight (8) years. In exchange for committing to plug and abandon the scheduled idle wells, those wells are exempt from the testing requirements of CCR, title 14, sections 1772.1, 1772.1.1, and the engineering analysis requirements of CCR, title 14, sections 1772.1.2 and 1772.1.3. The TWP must be approved by CalGEM. The TWP may extend up to 8 years into the future and requires that at least 10 percent of the idle wells covered by the plan to be plugged and abandoned each year. After each year of adherence to a TWP, an operator may add additional wells and extend the TWP up to the maximum 8 years, provided the additions comply with the requirements of CCR, title 14, section 1772.2, subd. (b). This includes the requirements that all idle wells covered by the TWP be scheduled to be plugged and abandoned within 8 years of being scheduled on the TWP.
CalGEM will review an operator’s TWP for compliance annually on the anniversary of the date that CalGEM first approved the operator’s TWP.
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What does “plug and abandon” mean for a TWP?
For the purposes of the TWP, “plugging and abandonment” means plugging and abandonment in accordance with PRC section 3208, or partial plugging and abandonment in accordance with CCR, title 14, section 1752.
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What must be included in a proposed TWP?
The TWP must include a list of idle wells to be plugged and abandoned, and the following information for each of the wells listed:
- The API Number and name of the well;
- The date by which is well is scheduled to be plugged and abandoned; and
- Documentation of any known wellbore integrity deficiencies associated with the well, including an explanation of the deficiency, when it became known, and a description of prior attempts to remediate or abandon the wellbore.
Wells on the plan should be prioritized based on the considerations listed in CCR, title 14, section 1772.4.
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Does a TWP have to be 8 years in length?
No, a TWP may be submitted for any number of years up to 8 (eight). However, in each year of the TWP, at least 10 percent of the idle wells covered by the TWP must be scheduled to be plugged and abandoned. If an operator lists less than eight wells on a plan, CalGEM will reduce the term length to be equal to the number of listed wells to ensure that a minimum of 10 percent of the wells covered by the TWP are plugged and abandoned each year of the plan.
After each year of adherence to a TWP, an operator may add additional wells and additional years to their TWP, provided the addition complies with the requirements of CCR, title 14, section 1772.2, subd. (b).
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What happens if I fail to complete my TWP as proposed?
If an operator fails to complete plugging and abandonment of any well according to the schedule approved by CalGEM on the TWP, CalGEM may cancel the TWP. If the TWP is cancelled, the exemptions for testing no longer apply for any of the wells listed in the TWP. The operator will be required to comply with testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, section 1772.1.2. within 90 days of the cancellation. When CalGEM cancels an operator’s TWP, CalGEM will not consider a new TWP from that operator unless the operator is in compliance with all of the requirements of CCR, title 14, sections 1772.1, 1772.1.1, and 1772.1.2. Operators concerned about meeting their TWP commitments should contact CalGEM immediately for assistance in managing obstacles to avoid having their TWP cancelled.
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If I have an approved TWP, what is the date each year by which I must complete the plugging and abandonment operations for the listed wells?
The annual review date for a TWP is the anniversary of the date CalGEM first approves the operator’s TWP. If an operator adds additional wells or extends the TWP for additional years, the annual review date will remain the anniversary of the date CalGEM first approved the initial TWP submitted by the operator. Each year, a minimum of 10 percent of wells on the TWP must be plugged and abandoned by the annual review date.
The compliance due date for a TWP is the date by which all the wells originally included on the Plan must be plugged and abandoned. This date will be dependent on the length of the TWP and the date CalGEM approves it. Upon approval, each well on the TWP will be given an elimination due date. The elimination due date is the date by which the well on the TWP must be plugged and abandoned. The elimination due date cannot exceed the term of the TWP and cannot exceed 8 years from the date the well was first added to the TWP. During each subsequent renewal of the TWP, newly added wells will receive a unique elimination due date and each existing well will retain its original elimination due date.
Example:
A Testing Waiver Plan is approved on June 1, 2019 to include 50 wells with an 8-year length.
- First annual review date is June 1, 2020, with a minimum of 5 wells plugged and abandoned.
- Compliance due date for all 50 wells to be plugged and abandoned is June 1, 2027.
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How do I submit my proposed TWP?
A TWP form is available. To request a TWP form, please send a request to
CalGEMIdleWells@conservation.ca.gov.
The preferred method to submit the completed TWP form is to send it electronically through
WellSTAR using the “Idle Well” form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at
CalGEMIdleWells@conservation.ca.gov. Paper copies may be mailed to:
Geologic Energy Management Division
Attn: Idle Well Program
715 P Street, MS 1803
Sacramento, CA 95814
CalGEM will either approve the TWP as submitted or return it to the operator contingent on revision. Potential revisions could include modifications to the length of the TWP, the dual listing of wells on the TWP and either a TCWP or IWMP, and corrections to the number of wells that must be plugged and abandoned to meet the 10 percent benchmark.
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What if I need to change my TWP?
An operator may request to modify the idle wells listed in an approved TWP during the annual review. The request to modify the TWP shall be supported by:
- A justification for the change.
- Information required under CCR, title 14, section 1772.2, subdiv. (b)(1) for any idle wells added to the list.
- A work plan for expeditiously bringing any wells removed from the list into compliance with the requirements of CCR, title 14, sections 1772.1, 1772.1.1 and 1772.1.2.
Amendment requests should be submitted to the idle Well Program at:
CalGEMIdleWells@conservation.ca.gov.
Operator Resources
Upload of Test Result Guide for Operators
2019 Operator Workshops
Operator workshops were held in March 2019 to review idle well regulations that took effect April 1, 2019. The workshop focused on testing of idle wells, the Idle Well Testing Compliance Work Plan, Idle Well Testing Waiver, and the 15-year Engineering Analysis. To obtain copies of the Idle Wells Workshop Implementation Presentation or the FAQs and diagrams from the workshop, email
CalGEMIdleWells@conservation.ca.gov.
Idle Well Inventories
CalGEM manages two idle well inventories:
annual fee inventory and IWMP inventory.
Annual Fee Inventory Includes all wells that met the definition of idle well in the prior calendar year. This inventory is used for the calculation of idle well fees.
IWMP Inventory includes all wells that met the definition of idle well on January 1 of the current calendar year. This inventory is used to establish the number of wells that must be eliminated by an operator in the current year if they elect to submit Idle Well Management Plans in lieu of pay an annual fee.
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2023 IWMP Inventory (Excel) of idle wells. This inventory contains all wells that were idle on January 1, 2023
Idle Well Definitions
Idle well
"[A]ny well that for a period of 24 consecutive months has not either produced oil or natural gas, produced water to be used in production stimulation, or been used for enhanced oil recovery, reservoir pressure management, or injection. For the purpose of determining whether a well is an idle well, production or injection is subject to verification by the division.” (Pub. Resources Code, § 3008, subd. (d).)
A
well no longer meets the definition of idle well when:
“[A]n idle well continues to be an idle well until it has been properly abandoned in accordance with Section 3208 or it has been shown to the division’s satisfaction that, since the well became an idle well, the well has for a continuous six-month period either maintained production of oil or natural gas, maintained production of water used in production stimulation, or been used for enhanced oil recovery, reservoir pressure management, or injection. An idle well does not include an active observation well.” (Pub. Resources Code, § 3008, subd. (d).)
Long-term idle well (LTIW)
"[A]ny well that has been an idle well for eight or more years." (Pub. Resources Code, § 3008, subd. (e).)
Idle Start Date
This is the date that the well meets the definition of idle well. It is the first day of the month following the 24th month of having not either produced or injected.
Example: If the last month of reported production on a well is January 2009, then its Idle Start Date is February 1, 2011.
Active observation well
“[A] well being used for the sole purpose of gathering reservoir data, such as pressure or temperature in a reservoir being currently produced or injected by the operator. For a well to be an active observation well, the operator shall demonstrate to the division’s satisfaction that the well fulfills a need for gathering reservoir data, and the operator shall provide the division with a summary report of the type of data collected at least annually or as requested by the division.” (Pub. Resources Code, § 3008, subd. (c).)