What Data Do You Need Before Permitting a Disposal Well?

Permitting a saltwater disposal well involves more than completing an application and identifying a place to inject produced water. Regulators need enough technical information to evaluate the proposed well, the injection formation, the fluids being injected, and how the well will be constructed and operated.

For Class II disposal wells, gathering the right information early can make the permitting process more efficient and help identify potential technical or regulatory issues before they become project delays.

Although specific requirements vary by state, regulatory agency, and project, most saltwater disposal well permitting efforts require information in seven key areas.

1. Well Location and Site Information

One of the first pieces of information needed is exactly where the proposed disposal well will be located.

Permit applications typically require information such as:

  • Proposed well coordinates
  • Well and facility location maps
  • Lease or property information
  • Surface ownership information, where applicable
  • Proposed access roads and surface facilities
  • Nearby geographic or environmental features

The location does more than identify where the well will be drilled. It helps determine which regulatory agencies have jurisdiction and provides the starting point for evaluating nearby wells, underground sources of drinking water (USDWs), geologic conditions, and other potential considerations.

Selecting a location early also allows the permitting and engineering teams to begin evaluating whether the site is technically and operationally suitable for disposal.

2. Geology and Injection-Zone Data

A disposal well needs a formation capable of accepting the anticipated injection volumes while maintaining containment.

Regulators therefore need information about the proposed injection zone and the formations surrounding it. Depending on the project and available data, this may include:

  • Injection formation name and depth
  • Formation thickness
  • Lithology
  • Porosity and permeability data, when available
  • Formation pressure
  • Estimated fracture pressure
  • Formation-water characteristics
  • Confining formations
  • Underground sources of drinking water
  • Known or suspected faults and fracture systems
  • Relevant seismic history

This information helps establish whether the proposed injection interval is appropriate for the project and whether overlying formations provide adequate separation from protected groundwater.

Existing well logs, offset-well information, geologic studies, public records, and formation testing may provide some of the necessary data. When adequate information is not already available, additional analysis or testing may be needed.

3. Nearby Wells and Area of Review Data

A disposal well cannot be evaluated in isolation.

As part of the Underground Injection Control permitting process, the operator may need to identify wells within the applicable Area of Review (AOR), particularly wells that penetrate the proposed injection zone.

Relevant information can include:

  • Well location
  • Well type
  • Date drilled
  • Total depth
  • Construction and completion information
  • Available well diagrams and logs
  • Cementing information
  • Plugging records for abandoned wells

Why does this matter?

Existing wellbores can potentially provide pathways for injected fluids or pressure to move outside the intended injection zone. Reviewing nearby wells allows the operator and regulator to identify wells that may require additional evaluation or corrective action.

This is one reason an AOR review can become an important part of early disposal well planning rather than something addressed only after the well design has been finalized.

4. Produced Water and Injection Fluid Data

Operators also need to understand what will actually be injected.

For a saltwater disposal well, this generally means characterizing the produced water or other eligible oil and gas-related fluids the well is expected to receive.

Information may include:

  • Source of the injection fluid
  • Producing field or formation
  • Expected fluid volumes
  • Physical characteristics
  • Chemical characteristics
  • Total dissolved solids (TDS)
  • pH
  • Specific gravity
  • Conductivity

Understanding the injection fluid is important for regulatory review, but it can also influence well design and long-term operations.

Fluid composition can affect compatibility with the injection formation and well materials. Knowing where the water comes from and how much is expected can also help establish realistic operating parameters for the proposed disposal system.

5. Expected Injection Rates and Pressures

How much fluid will the well need to handle?

That question needs to be addressed before permitting because injection volume and pressure are central to evaluating the proposed operation.

Class II permit applications commonly require proposed operating information such as:

  • Average daily injection rate
  • Maximum daily injection rate
  • Average injection pressure
  • Maximum injection pressure
  • Expected injection volumes
  • Proposed annular fluid, where applicable

These values need to make sense in the context of the injection formation and proposed well design.

The goal is not simply to determine whether fluid can be pumped underground. The proposed operating conditions must remain within regulatory and technical limits intended to protect the integrity of the injection zone and surrounding formations.

Understanding anticipated water volumes early can therefore help inform both the permitting strategy and the engineering design.

6. Proposed Well Design and Construction

Regulators also need to know how the disposal well will be built.

For a new Class II well, the permit package may include a proposed well schematic showing elements such as:

  • Well depth
  • Casing strings
  • Casing depths
  • Cementing program
  • Proposed top of cement
  • Tubing and packer configuration, where applicable
  • Injection interval
  • Perforated or open-hole intervals
  • Injection and confining zones
  • Underground sources of drinking water

The application may also describe proposed drilling, logging, testing, completion, and stimulation procedures.

If an existing well is being converted into a disposal well, the information needs can look somewhat different. Existing completion and cementing records, well schematics, logs, tests, and other historical well information may need to be reviewed to determine whether the well is suitable for conversion and what modifications may be necessary.

This is where permitting and well engineering become closely connected. The permit describes a well that must ultimately be capable of being constructed and operated safely and in accordance with applicable requirements.

7. Operating, Monitoring, Plugging, and Financial Responsibility Information

Permitting does not end with getting the well drilled.

Regulators also need information about how the well will be operated, monitored, and eventually plugged and abandoned.

Depending on the regulatory program and project, this may include plans for monitoring:

  • Injection pressure
  • Annulus pressure, where applicable
  • Injection flow rate
  • Cumulative injection volume
  • Injection-fluid characteristics
  • Mechanical integrity

Operators may also need contingency procedures for responding to well failures or abnormal operating conditions.

A plugging and abandonment plan is another important part of the permit application. This describes how the well will eventually be taken out of service in a manner designed to protect underground sources of drinking water and isolate the injection interval.

Applicable financial responsibility requirements may also need to be addressed so funds are available for plugging, abandonment, and other required closure activities.

What If You Don’t Have All of This Data Yet?

Not having every piece of information on day one does not necessarily mean a disposal well project cannot move forward.

In many cases, one of the first steps is determining what information already exists and what still needs to be developed.

Some data may be available through:

  • Existing well records
  • Offset-well logs
  • State or federal databases
  • Previous geologic studies
  • Existing water analyses
  • Historical drilling and completion records
  • Operator production and water-volume data

From there, the project team can identify gaps and determine whether additional geologic analysis, reservoir evaluation, fluid sampling, well testing, engineering, or other technical work is needed.

Doing this work early can also help answer a more important question than simply, “What does the permit application require?”

Does the available information support the disposal well project being proposed?

A technically strong permitting strategy should help answer that question before significant time and capital are committed.

Bringing the Data Together

Disposal well permitting brings together several disciplines. Geology, reservoir characteristics, produced-water volumes, well construction, operating conditions, environmental requirements, and regulatory requirements all influence the final permit application.

That is why early planning can be valuable.

Identifying the required data, evaluating existing information, and finding gaps early in the process can help operators develop a more complete permit application while making better-informed decisions about site selection, well design, construction, and operation.

Planning a Saltwater Disposal Well?

IPT Well Solutions provides Class II permitting and saltwater disposal well support from early project evaluation through well design, permitting, construction, monitoring, and ongoing operations.

Our team can help evaluate available project data, identify information gaps, develop the technical information required for the permit application, and coordinate with applicable regulatory agencies.

Planning a new saltwater disposal well or evaluating an existing well for conversion? Contact IPT Well Solutions to discuss your project.

Like this article? Share It Using the Links Below:

© Copyright 2022 New IPT Inc. All Rights Reserved.