​Well Maintenance and Cleanout History

As mentioned in NTO-2017-05 (PDF), a treatment with pressures exceeding the formation fracture gradient and/or any well treatment or operation that involves emplacing acid in a well and that uses a volume of fluid equal to or greater than the Acid Volume Threshold (AVT) (PDF) for the operation shall be presumed to be a well stimulation treatment unless it is demonstrated to the satisfaction of the Geologic Energy Management Division (CalGEM, formerly DOGGR) that the treatment, as designed, does not enhance oil and gas production or recovery by increasing the permeability of the formation. Well Stimulation Treatment may not commence without a valid permit approved by CalGEM (Cal. Code Regs., title 14, § 1783(a)). Demonstrations must be made to CalGEM prior to performing any operation that exceeds formation fracture gradient or involves emplacing acid in a well and that uses a volume of fluid equal or greater than the Acid Volume Threshold. CalGEM highly recommends that any operation which may come close to the above thresholds be brought to CalGEM's attention for an advance determination from CalGEM prior to commencing the operation. Failure to make the requisite demonstration in advance of the operation may result in enforcement action, including but not limited to issuance of a civil penalty and/or order for remedial action.

California Statutes and Regulations for Conservation of Oil, Gas, and Geothermal Resources (April 2019)​ (PDF) has additional information on the applicability of the requirements under California Code of Regulations, Title 14, section 1777.4. Please contact CalGEM if you have questions.

Subject to the approval of CalGEM, under Cal. Code Regs., title 14, section 1777.4(d), an operator may propose a plan for submitting aggregated information regarding a specific type of repeated operation that involves emplacing fluid containing acid in the well, yet clearly does not meet the definition of a well stimulation treatment. Once approved, aggregated data is due to CalGEM annually on January 31.

A proposal for an aggregated plan should contain, but is not limited to the following items:

1. The oil and gas field names you would like your plan to cover
2. A description of the different types of well maintenance to be covered by your plan
   
3. An explanation of why you believe this work is clearly not well stimulation
   
4. Examples of typical volumes of fluids containing acids emplaced in the well
5. A range of volumes of fluids containing acids emplaced in the well (minimums and maximums)
6. The name (trade name) of each chemical, its purpose and a Safety Data Sheet (SDS) for each chemical you plan on using
   

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.