H-10 - Annual Monitoring Reports FAQs

Frequently Asked Questions for Railroad Commission of Texas Form H-10

Our company has recently taken over operation of a well with a delinquent H-10. How do we correct the violation if we have limited records of the previous operator's operations ?

In most cases, this type of well was shut in for a long period of time, which can be easily documented, so reporting "zero" injection pressures and volumes is appropriate.  In other cases, the well test report (Form W-10 or G-10) will provide the oil (or gas) to water production ratio.  This ratio can be used to estimate the water production based on the oil or gas production, and the estimated volumes and pressure may be reported.  Please indicate that these values were estimated. 

When is an annual monitoring report required?

An annual monitoring report (Form H-10) must be filed for every permitted injection/disposal well, regardless of current status, for the life of the injection/disposal permit.   The production well status report (Form W-10 or G-10) will satisfy the reporting requirement for wells that are actively producing. 

How will we know when to file?

Filing of the Form H-10 will be staggered by testing county for the field in which the well is completed.   This is the same cycle used for production well status reports (Form W-10 or G-10).   The Commission will send you the pre-printed Forms H-10 with the months to be reported already indicated.   The Forms H-10 will be mailed out at the same time as the production well status reports, and will be due at the same time. 

What effect does shutting a well in or converting it to production have on the monitoring report requirements?

A shut in injection / disposal well must continue to file the Annual Monitoring Report (Form H-10).  Optional monitoring of the tubing-casing annulus will not delay the mechanical integrity test schedule for a shut in well.  Permit required tubing-casing annulus monitoring, which is required on certain wells with insufficient surface casing, may be discontinued. 

A well that was converted to production will be required to file an annual monitoring report (Form G-10) for the part of the reporting cycle up to the conversion date.  The production test reports (Form W-10 of G-10) will fulfill the H-10 filing requirements from that date forward. 

Can annulus monitoring be done with open tubing-casing pressure valves?

No.  The purpose of having wellhead pressure observation valves is two-fold:  First, it contains injected fluids inside the wellbore in the event of a tubing or packer leak;  Second, it allows pressure to build up and be detected.  Leaving pressure observation valves open will be cited as an operating violation and nullify any potential annulus monitoring credit. 

Operating an injection well with open tubing-casing wellhead valves is an unsound practice because a tubing or packer failure will result in immediate surface and therefore, groundwater pollution. 

How long do we have to keep these monitoring records?

Five years.  Statewide Rules 9 and 46 specify that monitoring reports must be kept for five years.  In addition, Statewide Rule 1 specifies that all supporting documements that were used to prepare the monitoring records must be retained for the same time frame.