SECTION 165:10-5-6. Testing and monitoring requirements for injection wells and disposal wells

(a)   Mechanical integrity during injection. The operator of an injection, disposal or commercial disposal well must maintain mechanical integrity in order to continue operation of the well.

(b)   Initial pressure test requirements for wells permitted on or after December 2, 1981.

(1)   Mandatory initial mechanical test. Before commencement of operation, each well authorized for injection or disposal by a Commission order issued on or after December 2, 1981, must pass an initial pressure test of the casing tubing annulus according to the minimum testing standards of (2) of this subsection, unless a Commission order or permit authorizes other test procedures of the mechanical integrity of the well. Any operator failing to comply with initial mechanical integrity testing and reporting requirements may be fined up to $500.00.

(2)   Minimum testing standards for initial tests. For each initial test required by (1) of this subsection, the minimum testing standards are:

(A)   Witnessing of the test. The test shall be witnessed by an authorized representative of the Conservation Division. It shall be the responsibility of the well operator to secure the presence of the Commission representative.

(B)   Down-hole equipment. Injection and disposal shall be through adequate tubing and packer.

(C)   Aboveground extensions and fittings. Adequate aboveground extensions shall be installed in each annulus in the well. In addition, the operator shall install an adequate working pressure gauge with a cutoff valve to the tubing, so that the amount of injection pressure may be measured by the Commission representative. An operator is required to keep adequate working gauges on the tubing and annulus of the well.

(D)   Packer setting depth under the order. The mechanical packer shall be set within 40 feet of the packer setting depth prescribed by the order permitting the well for injection or within 75 feet of the perforations of the injection zone(s) opened.

(E)   Verification of packer setting depth. The Commission District Manager may require the operator of the well to verify the packer setting depth by running a wireline or other method approved by the Manager of the Underground Injection Control Department.

(F)   Minimum testing pressure for noncommercial disposal and injection wells. Noncommercial disposal and injection wells shall be tested as follows:

(i)   If the maximum authorized injection pressure for the well is less than 300 psig under the order or permit authorizing the well for injection, the minimum testing pressure shall be 300 psig.

(ii)   If the maximum authorized injection pressure is greater than 300 psig under the order or permit authorizing the well for injection, the minimum testing pressure shall be the lesser of 1000 psig or the maximum authorized injection pressure under the order permitting the well.

(G)   Minimum testing pressure for commercial disposal wells. Commercial disposal wells shall be tested at the maximum injection pressure authorized in the order or permit authorizing the well for injection, but not less than 300 psig.

(H)   Thirty minute minimum testing period. The minimum testing period shall be 30 minutes at the testing pressure.

(I)   Ten percent maximum permitted bleed-off. The maximum permitted change in pressure during the testing period shall be ten percent of the maximum testing pressure used.

(J)   Test report on Form 1075. The Field Inspector shall submit the results of the mechanical integrity test on Form 1075 within 30 days from the date the test is performed.

(K)   Cement circulated above injection zone. The annulus between the casing and the borehole must be cemented through the injection or disposal zone to a height at least two hundred fifty (250) feet above the injection or disposal zone. If a cement squeeze is necessary to raise annular cement to the minimum height of 250 feet, a cement bond log showing quality and placement of the cement must be furnished to be approved by the Commission before the well may be used for injection or disposal.

(L)   Packer setting depth. The packer must be set at a depth which is at least 50 feet below the depth of the top of cement behind the production casing.

(3)   Alternative testing procedures. Operators can test at a maximum of 500 psi if there is in place an automatic and continuous pressure monitor on the tubing-casing annulus that will shut-in the well if there is a pressure increase of 250 psi on the annulus. Application for this alternative test procedure shall be made in writing to the Manager of the UIC Department. The Manager of the UIC Department may allow the alternative test procedure to be used as the initial mechanical integrity test, which permission shall be reflected in the order or permit regarding the well.

(4)   Use of fluid seal without a mechanical packer. Use of a fluid seal without a mechanical packer is prohibited.

(c)   Initial pressure test requirements for wells permitted prior to December 2, 1981.

(1)   Mandatory initial pressure test or monitoring test.

(A)   Each well authorized for injection or disposal by Commission order issued prior to December 2, 1981, must pass an initial mechanical integrity test according to the minimum testing standards of (2) of this subsection.

(B)   In lieu of casing test required in (A) of this paragraph, the operator shall monitor and record during actual injection the pressure in the casing-tubing annulus monthly and report the pressure annually on Form 1075. A measurable positive pressure must be maintained at the casing valve and be continuously measured to qualify.

(2)   Minimum testing standards for initial mechanical integrity tests.

(A)   Wells with casing-tubing annulus. The minimum testing standards of (b)(2) of this Section for an initial test of a well with a casing tubing annulus shall apply with the following modifications:

(i)   The District Manager shall have the option to waive witnessing of the test.

(ii)   If the test is not witnessed, the well operator shall submit documentation of the test to the Conservation Division within 30 days after the test on Form 1075.

(iii)   The minimum testing pressure shall be 200 psig.

(B)   Wells without a casing-tubing annulus or wells with perforations above the packer. The minimum testing standards for an initial test of a well without a casing-tubing annulus or wells with perforations above the packer are:

(i)   Witnessing of the test. The test shall be witnessed by an authorized representative of the Conservation Division unless the District Manager for the Conservation Division waives the requirement of witnessing the initial test. It shall be the responsibility of the well operator to secure the presence of the commission representative for witnessing the test.

(ii)   Documentation for unwitnessed tests. If the test is not witnessed, then the operator shall submit on Form 1075 documentation of the test to the Conservation Division within 30 days after the test.

(iii)   Aboveground extensions and fittings. The operator shall install a one-fourth (1/4) inch female fitting, with cutoff valve to the tubing, so that the amount of injection pressure may be measured by the Commission representative using a gauge having a one-fourth (1/4) inch male fitting.

(iv)   Setting depth for plug. For purposes of the test, a mechanical packer, retrievable bridge plug, or seating nipple plug shall be placed in the injection string not more than 75 feet above the top of the injection interval.

(v)   Pressure testing of tubing string. The well operator shall pressure test the tubing string for at least 30 minutes. The minimum testing pressure shall be the greater of 300 psig, or the maximum authorized injection pressure provided that the actual working injection pressure for the well may be used instead of the maximum authorized injection pressure when necessary to prevent damage to the casing or packer.

(vi)   Ten percent maximum permitted bleedoff. The maximum permitted bleedoff during the testing period shall be ten percent of the maximum testing pressure used.

(vii)   Radioactive tracer survey. A radioactive tracer survey shall be run demonstrating that the injected fluid is going into the authorized zone when there is no cement bond log or cementing reports to demonstrate sufficient cement behind pipe to isolate the injection zone or to insure the packer is properly set.

(viii)   Pressure test using a gas media. In lieu of a pressure test using a liquid testing media, the UIC Department may approve a mechanical integrity test using a gas media if it conforms to a method previously approved by the EPA.

(ix)   Test report on Form 1075. The Field Inspector shall submit the results of the mechanical integrity test on Form 1075 to the Conservation Division within 30 days after the test.

(d)   Subsequent mechanical integrity test requirements for noncommercial disposal wells and injection wells.

(1)   Pressure tests.

(A)   Noncommercial disposal wells permitted for injection at volumes equal to or greater than 20,000 barrels per day. Unless a well has been approved by an order or permit of the Commission for other testing procedures or monitoring, each noncommercial disposal well permitted for injection at volumes equal to or greater than 20,000 barrels per day shall demonstrate mechanical integrity by using one of the following methods:

(i)   Conduct a pressure test of the casing tubing annulus at least once every year according to the minimum testing standards of (3) of this subsection, or

(ii)   If a continuous pressure monitor is installed on the casing tubing annulus that will automatically notify the operator of a mechanical failure, then the well shall demonstrate mechanical integrity at least once every five years according to the minimum testing standards of (3) of this subsection.

(B)   Noncommercial disposal wells permitted for injection at volumes less than 20,000 barrels per day and injection wells. Unless a well has been approved by an order or permit of the Commission for other testing procedures or monitoring, each noncommercial disposal well permitted for injection at volumes less than 20,000 barrels per day, and each injection well permitted for injection shall demonstrate mechanical integrity at least once every five years according to the minimum testing standards of (3) of this subsection.

(C)   Penalty for noncompliance. Any operator failing to comply with periodic mechanical integrity testing and reporting requirements may be fined up to $500.00.

(2)   Required retest if down-hole equipment is moved or replaced. After a well passes a pressure test required by this Section, if the operator moves the packer or replaces either the packer or the tubing, then the operator shall notify the Commission and retest the well according to the minimum testing standards of (3) of this subsection.

(3)   Minimum testing standards.

(A)   Wells with casing-tubing annulus. For a five year test or retest required by this subsection, the minimum testing standards of (b)(2) of this Section shall apply to wells with casing-tubing annulus with the following modifications:

(i)   The District Manager shall have the option to waive witnessing of the test.

(ii)   If the test is not witnessed due to waiver, the well operator shall submit documentation of the test to the Conservation Division within 30 days after the test.

(iii)   The minimum testing pressure shall be 200 psig for a noncommercial disposal or injection well.

(B)   Wells without a casing-tubing annulus or wells with perforations above the packer. For a five year test or retest required by this subsection, the minimum testing reporting standards of (c)(2)(B) of this Section, shall apply to wells without a casing-tubing annulus or wells with perforations above the packer.

(e)   Subsequent mechanical integrity test requirements for commercial disposal wells.

(1)   Pressure tests.

(A)   The well shall be tested a minimum of every twelve (12) months according to the minimum testing standards of (b)(2) of this Section.

(B)   After a well passes a pressure test required by this Section, if the operator moves the packer or replaces the packer or tubing, then the operator shall notify the Commission and retest the well according to the minimum testing standards of (b)(2) of this Section.

(C)   Any operator failing to comply with periodic mechanical integrity testing and reporting requirements may be fined up to $500.00.

(2)   Alternative testing procedures. Operators can test at a maximum of 500 psi if there is in place an automatic and continuous pressure monitor on the tubing-casing annulus that will shut-in the well if there is a pressure increase of 250 psig on the annulus. Application for this alternative test procedure shall be made in writing to the Manager of the UIC Department. The Manager of the UIC Department may allow the alternative test procedure to be used as the initial mechanical integrity test, which permission shall be reflected in the order or permit regarding the well.

(f)   Fluid level monitoring required by UIC orders or permits to address wells ascertained during the permitting process that may require remediation.

(1)   Fluid level monitoring. The operator must perform on an annual basis fluid level monitoring tests if required by a UIC order or permit.

(2)   Fluid level test procedures.

(A)   Unless otherwise stated in UIC orders or permits for fluid level monitoring, the well must be shut in for a minimum of 48 hours before a fluid level test is performed. A variance to the 48-hour shut-in period may be granted by the Manager of the UIC Department if it can be demonstrated that reservoir pressure will stabilize prior to the expiration of the 48-hour time period.

(B)   Fluid level test procedures shall be designed to determine reservoir pressure and such tests must be approved by the Conservation Division.

(C)   The appropriate Field Inspector shall be notified at least 48 hours in advance of a fluid level test to allow a Commission representative an opportunity to witness the test.

(D)   The operator is required to perform the fluid level monitoring test annually during the two month time period in May and June and submit the annual monitoring test results by June 30 of each year to the Manager of the Underground Injection Control Department.

(3)   Fluid level monitoring test failure. If the fluid level in a well is determined to be within 150 feet or less below the base of treatable water, the test shall be deemed a failure, and the following actions must be performed:

(A)   The operator shall immediately cease injection or disposal operations.

(B)   The operator shall notify the Manager of the Underground Injection Control Department of the results within 24 hours of the performance of the fluid level test, and shall submit the results of the test and a corrective action plan in writing to such Manager within 7 days of the test.

(4)   Failure to perform fluid level test. Any operator who fails to perform annual fluid level tests as required by a UIC order or permit pursuant to this subsection is subject to the following:

(A)   Injection or disposal into the UIC well is prohibited until the operator performs the test and submits the results to the Manager of the Underground Injection Control Department.

(B)   The operator may be fined up to $1,000.00, and

(C)   The UIC order or permit is subject to termination after notice and hearing.

[Source: Amended at 9 Ok Reg 2295, eff 6-25-92; Amended at 9 Ok Reg 2337, eff 6-25-92; Amended at 11 Ok Reg 3691, eff 7-11-94; Amended at 13 Ok Reg 2381, eff 7-1-96; Amended at 14 Ok Reg 2198, eff 7-1-97; Amended at 17 Ok Reg 1860, eff 7-1-00; Amended at 23 Ok Reg 2229, eff 7-1-06; Amended at 28 Ok Reg 1949, eff 7-11-11; Amended at 30 Ok Reg 1041, eff 7-1-13; Amended at 31 Ok Reg 977, eff 9-12-14; Amended at 34 Ok Reg 921, eff 9-11-17; Amended at 35 Ok Reg 973, eff 9-14-18; Amended at 36 Ok Reg 534, eff 8-1-19; Amended at 37 Ok Reg 1121, eff 10-1-20]