For Operators - Idle Well Program

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​​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. The 2020 Idle Well Fee Invoice will include each well that was an idle well at any time in 2019.

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.

2019 Idle Well Fee Invoices: Digital copies of all invoices are available on CalGEM’s FTP site at ftp://ftp.consrv.ca.gov/pub/oil/Idle-Wells/2019-Fee-Letters/. Email CalGEMIdleWells@conservation.ca.gov for assistance.

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 2020 IWMP is based on the operator’s inventory as of January 1, 2020.

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).)

 

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.

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.

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.

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).​​

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).

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.

Operator Resources

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 four idle well inventories: annual fee inventory, IWMP inventory, compliance period inventory, and the current 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 as of January 1 of the current calendar year. This inventory is used for IWMP calculations.

  • 2020 IWMP inventory (Excel, download) of idle wells. This inventory contains all wells that were idle on January 1, 2020.

Compliance Period Inventory Includes all wells that met the definition of idle well prior to the effective date of the proposed regulations, April 1, 2019. This inventory is used for planning and monitoring of the testing compliance period provided in Section 1772.1.4 of the proposed regulations.

Current Inventory Includes all wells that currently meet the definition of idle well. This list is updated monthly and can be obtained through WellSTAR. Those who do not have access to WellSTAR may request a copy of the Current Inventory by emailing CalGEMIdleWells@conservation.ca.gov.

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).)​