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Cavern Storage Permit Procedures

Administrative Review | Attachments for Permit Applications | Technical Review | Post-Permitting

Administrative Review

This part of the permit review verifies that all rule and statutory requirements have been met for a permit to be issued. 

Application Forms

  • Form H-4 (Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations, Rule 95)
  • Form H-4 (Underground Storage of Gas in Salt Formations Rule 97)

Fees and Surcharges

$500 for each well in the application ($200 application fee plus $300 surcharge). These fees are non-refundable. 

Where to File

File the original with Technical Permitting in Austin.

Preliminary Review

  • Organization Report (Form P-5) - The applicant must have a current organization report on file with the Commission. The Commission's mainframe database is checked to verify that the organization report is on file and current.
  • Certificate of Compliance (Form P-4) - The applicant must be the current operator of the lease. If a Form P-4 has been filed on the lease, the applicant must be shown as the operator on the current Form P-4.  For a new lease, the operator will be required to file Form P-4 along with the completion report (Form W-2/G-1) on the injection/disposal well.
  • Injection/Disposal Well Inventory - The Commission's mainframe database is checked to determine whether the application is for a new permit or an amendment of an existing permit. This check determines which application attachments are required. All attachments are required when filing for a new permit; others may not be required depending on the type of the amendment. 
  • Compliance with Permit Conditions – For amended applications, information required by permit conditions may be reviewed.  This check will determine whether the operator may be required to submit any information required as a monitoring or operating condition of the existing permit.

NOTE: Beginning February 2, 2005, permit applications will be administratively denied if the subject well is under pipeline severance or seal-in for Rule or permit violations on that well. This consideration does not apply to permit amendment applications that, if granted, would return the subject well to compliance.

Attachments for Cavern Storage Permit Applications

Geologic Definition of the Salt Formation

  1. Description of the geology of the site
  2. For all zones penetrated by the storage well, description of annotation of the geologic formation name, lithologic description, thickness and any faults or fractures.
  3. Two perpendicular geologic cross sections extending at least one half mile beyond the limits of the storage caverns or proposed storage caverns.
  4. Any logs or other data used in the cross sections.

Groundwater Depth Determination Letter (GAU Letter)

Statewide Rule 95(d)(2) and 97(d)(2): Fresh water strata. The applicant must submit with the application a letter from the Groundwater Advisory Unit (GAU) of the Oil and Gas Division stating the depth to which fresh water strata occur at each storage facility.

Area of Review

The purpose of this requirement is to identify any wells near the proposed injection well which may provide an avenue for migration of fluids out of a cavern in the facility.

  1. All wells within a ¼-mile radius of each well in the facility
  2. If any nearby salt formation storage facilities include storage cavities extending within ¼ mile of the facility in the subject application, map and identify those facilities
  3. A map indicating the areal footprint of each cavern in the facility.

    Map Guidelines:

    • Use a current map.
    • Use a legible map clearly showing operator names, lease names, and well numbers.
    • Draw 1/4 mile radius around the well, wells (multi-well applications), or lease (area permit applications).
    • Always provide map scale.
    • Be able to distinguish wells with same numbers.

    RRC Mapping Database:

    The RRC Public GIS Map Viewer is the system that RRC staff will use to verify that all wells within a 1/4-mile radius have been examined.

    • The interface allows you to locate the well by API number, Lease Id number, Survey or GPS coordinates.
    • You may also navigate by zooming in using landmarks such as cities and highways.
    • You may use the "MAP TOOLS" function to to either navigate, identify wells, surveys or draw a 1/4 or 1/2 mile circle around the subject well.
  4. A table of wells within the 1/4-mile radius that penetrate the caprock is required. For each well, list the well name and number, date drilled, and current status, including the date plugged if applicable.

    Table of Wells Guidelines:

    • List all wells within 1/4 mile radius around the well, wells (for multi-well applications), or lease (for area permit applications) that penetrate the top of the proposed injection zone.
    • For each well, show the well names, well numbers, API numbers and Total Depth.
    • For each well, show date drilled, current status, and date plugged (if applicable).
    • Include a copy of the plugging report for any wells plugged prior to January 1, 1967.
    • If records are not readily available for any plugged wells, include copies of the plugging report to expedite processing.
    • If space allows, the Map and Table of wells within the 1/4-mile radius can be combined.

Notice

The notification process ensures that all affected parties are informed and have opportunity to protest the permitting of the proposed storage facility and storage cavern wells.  The following attachment is required:

Plat of leases or owned properties showing the proposed areal limits of the proposed storage facility and the ownership of property or leases adjacent to the proposed facility.

Mail or deliver a copy of the application form(s), both front and back, to:

  • the surface owner of the tract where the storage facility is located or is proposed to be located;
  • the surface owner of each tract adjoining the tract where the storage facility is located or is proposed to be located;
  • each oil, gas, or salt leaseholder, other than the applicant, of the tract on which the storage facility is located or is proposed to be located;
  • each oil, gas, or salt leaseholder of any tract adjoining the tract on which the storage facility is located or is proposed to be located;
  • the county clerk of the county where the storage facility is located or is proposed to be located; and
  • if the storage facility is located or proposed to be located within city limits, the city clerk or other appropriate city official.
  • Provide a signed statement listing name, address, and relation to the application (i.e. offset operator, surface owner, etc.) and the date that a copy of the application (front & back) was mailed or delivered to each of the required recipients. If there are no offsetting parties identified by the above, provide a statement to this effect.
  • Notice of the application must be published once a week for three consective weeks by the applicant in a form approved by the Commission in a newspaper of general circulation in the county where the well is located. Notice instructions and forms may be obtained from the Commission's Austin office, district offices, or downloaded from this website. The following information must be submitted with the application:
    • Affidavit of publication. The affidavit must be notarized and must state that the newspaper has general circulation in the county where the well is located.
    • Newspaper clipping.

Publication Guidelines:

  • Include Formation Name(s).
  • Include the Field and Lease Name(s).
  • Include the Well Number(s).
  • The direction/miles from the nearest town must be consistent with the information in the application.
  • The subsurface cavern depth interval must be consistent with the information in the application.
  • For applications including more than one well, use the top of the shallowest and the bottom of the deepest interval for the subsurface depth interval.
  • Notice must be published (once a week for three consecutive weeks) at your expense on or before the day the application is filed.
  • The newspaper need not be in the same county as the well, but must have general circulation in that county.
  • The legal authority paragraph must be included in the publication.
  • The notice must contain instructions for persons who wish to protest the application or who wish to request further information concerning the application.

Surface Ownership Map Guidelines:

  • Clearly show the location of all wells of public record within one-half mile radius of the proposed injection/disposal well.
  • Identify the commission designated operators of wells within one-half mile of the proposed injection/disposal well.
  • For a commercial disposal well application, show the owners of record of the surface tracts that adjoin the proposed disposal well tract.

Include a list of the names and addresses of the surface owners or record, operators or wells within one-half mile, county clerk, and, if applicable, city clerk.

  1. Submit a signed statement indicating the date that a copy of the application form(s) was mailed or delivered to each person on the list.

NOTE: Operators of wells or wells with active drilling permits that fall within the above tract identification must be notified regardless of the status of the wells.

Well Completion Procedures

  1. Well completion procedures
  2. Logging procedure and types of logs
  3. Casing testing procedure
  4. Wellbore diagram for each well
  5. Tabulation of casing and cementing program, including type, size, weight, grade and setting depth, number and location of centralizers, cementing technique, type and volume of cement, additives, and gel

Description of Salt Cavern Development Process

  1. Injection procedure and rates
  2. Type and composition of displacement fluid
  3. Methods used to monitor and control boundary and shape
  4. Method of circulation
  5. Use of blanket material, if applicable

Identification of Stored Products

Provide a list of the type and composition of the product to be stored in each cavern.

Plugging Procedure

  • Provide the plugging and abandonment procedure for each well in the application.
  • State the composition of fluid to be used to fill cavities.

Technical Review

Surface Casing Requirements

This part of the permit review verifies that groundwater is adequately protected. 

  • For new wells, surface casing must be set to the protection depth determined by the Groundwater Advisory Unit of the Railroad Commission of Texas and cemented to the surface. 

NOTE: Cementing the long-string casing from total depth to the surface instead of setting surface casing is not normally allowed.

  • Proposals to convert existing wells with short surface casing or single string completions will be considered on a case-by-case basis. They may be permitted for injection or disposal with additional safeguards such as remedial cementing, annual pressure testing, and/or annulus pressure monitoring. 

Long String Casing

This part of the permit review verifies that the production casing is adequately cemented to confine injected fluids to the proposed injection zone. 

  • The long string casing must be cemented in accordance with Statewide Rule 13.
  • All hydrocarbon storage wells drilled in salt domes after January 1, 1994, shall have at least two casing strings cemented into the salt formation. Sufficient cement shall be used to fill the annular space outside the casing from the casing shoe to the ground surface, or from the casing shoe to a point at least 200 feet above the shoe of the previous casing string.
  • All hydrocarbon storage wells in bedded salt drilled after January 1, 1994, shall have all casing strings cemented with sufficient cement to fill the annular space outside each casing string from the casing shoe to the ground surface.
  • The long string casing must be set into the salt formation. A minimum depth distance between the top of the salt formation and the end of the long string casing is not specified in the statewide rules. The operator is responsible for determining the long string casing depth consistent with best practices.

Geological Requirements

This part of the permit review verifies that salt formation is adequately defined and that the subsurface caverns will be appropriately contained within the salt formation.

The interval overlying the salt formation must provide sufficient confidence that upward growth of the cavern roof will not occur in an uncontrolled manner.

Area of Review

This part of the permit review verifies that all wells within the area of review are adequately plugged to ensure that the cavern is not negatively affected by an existing wellbore. The operator is responsible for demonstrating that the footprint of the cavern is adequately separated from any existing wellbore.

Tubing

This part of the permit review verifies that storage configuration is appropriately stable and consistent with acceptable industry standards as required by Statewide Rules 95 and 97.

  • An acceptable roof blanket program must be implemented while the cavern is being developed.
  • An acceptable roof blanket must be maintained while storing liquid or liquefied hydrocarbons.

Injection Pressure

This part of the permit review verifies that the proposed injection pressure does not exceed the maximum pressure allowed to be exerted on the salt formation.

Requirements for applications under Rule 95:

  • The maximum operating pressure at the shoe of the lowermost cemented casing shall not exceed a gradient of 0.8 psi/ft.
  • The permitted maximum allowable operating pressure is that pressure specified in the Commission permit or order, or, if not specified in the permit or order, that pressure stated in the application or the application for amendment to a permit or order.
  • As different liquefied products have different densities and different critical behaviors, the operator is responsible for presenting a maximum pressure appropriate for the product to be stored.  Notwithstanding the permitted pressure given on the permit, the operating conditions of the well still may not exceed the above-referenced gradient limitation.

Requirements for applications under Rule 97:

  • The maximum operating pressure at the shoe of the lowermost cemented casing shall not exceed a gradient of 0.85 psi/ft.
  • The permitted maximum allowable operating pressure is that pressure specified in the Commission permit or order, or, if not specified in the permit or order, that pressure stated in the application or the application for amendment to a permit or order
  • As different gases have different densities, the operator is responsible for presenting a maximum pressure appropriate for the product to be stored. Notwithstanding the permitted pressure given on the permit, the operating conditions of the well still may not exceed the above-referenced gradient limitation.

Injected Fluids

This part of the permit review verifies that the proposed injection fluids are within the jurisdiction of Statewide Rules 95 and 97.

  • In an application under Rule 95 (storage of liquid or liquefied hydrocarbons), the stored product is limited to substances that 1) are hydrocarbon; and 2) is liquefiable under operating conditions
  • In an application under Rule 97 (storage of liquid or liquefied hydrocarbons), the stored product is limited to substances will exist in a gaseous state under operating conditions.

Permit Classification

This part of the permit review verifies that the distinction between permitting of brine mining injection Wells and permitting of storage cavern wells is appropriately applied.

In this section, the term “hydrocarbon,” will mean “liquid or liquefied hydrocarbons,” as that phrase is used in Statewide Rule 95, as well as “gas,” as that word is used in Statewide Rule 97.

Cavern Leaching vs. Brine Mining

  1. Statewide Rules 95 and 97 regulate wells used for leaching a cavern for the underground storage of hydrocarbons. See 16 Tex. Admin. Code § 3.81(a)(3) (“The term ‘brine mining injection well’ does not include a well used to inject fluid for the purpose of leaching a cavern for the underground storage of hydrocarbons…”).
  2. Staff does not consider a well that meets the following criteria to be a well used for leaching a cavern for the underground storage of hydrocarbons regulated by Statewide Rules 95 and 97:
    1. a well used to inject fluid for the purpose of extracting brine by the solution of a subsurface salt formation for more than two (2) years.
  3. If a well meets the criteria of subsection (b), Staff will alert the operator that additional permitting may be required as follows:
    1. New hydrocarbon storage wells and/or underground hydrocarbon storage facilities: Staff will include a new permit condition (detailed in the last section of this document) to specify that any well used in leaching operations for more than two (2) years will be considered a brine mining injection well. The permittee will be required to obtain a brine mining injection permit for that well.
    2. Existing hydrocarbon storage wells and/or underground hydrocarbon storage facilities:
      1. If an operator has used a well for more than two (2) years in leaching operations, Staff will notify the operator that they have one (1) year to complete the leaching operations.
      2. If leaching operations do not cease after one (1) year, the operator will be required to obtain a brine mining injection well permit.

Staff will initiate an enforcement action under Statewide Rule 81 for any operator that fails to obtain a brine mining injection well permit as required by this subsection.

Post-Permitting

Annual Monitoring Report (Form H-10H)

  • Statewide Rule 95(m) states, the operator shall report maximum wellhead pressures on the hydrocarbon and brine sides of each hydrocarbon storage well and the net volumes of hydrocarbons injected into and withdrawn from each hydrocarbon storage well in accordance with the instructions on the annual report form prescribed by the Commission.
  • Statewide Rule 97(m)(2) states, the operator shall file annually a status report for each storage well in accordance with the instructions on the form prescribed by the Commission.

Mechanical Integrity Test (Form H-5)

  • A mechanical integrity test (MIT) must be performed before any fluids are injected into the well.
  • Each gas storage well shall be tested for integrity prior to being placed into service, at least once every five years, and after each workover that involves physical changes to any cemented casing string. The following requirements apply to such integrity tests.
  • Integrity tests for wells in salt domes with a single casing string. Each hydrocarbon storage well drilled into a salt dome and having a single casing string cemented to the surface shall have the casing inspected by mechanical, ultrasonic, or magnetic methods at least once every five years and after each workover that involves physical changes to the cemented casing string.
  • Integrity tests for wells other than those in salt domes with a single casing string. Each hydrocarbon storage well shall be tested for integrity prior to being placed into service, at least once every five years, and after each workover that involves physical changes to any cemented casing string. The following requirements apply to all such integrity tests.

Completion report (Form W-2 or G-1)

  • File a completion report within 30 days of conversion to reflect the actual completion of the well.
  • Commission staff will review the actual completion against the proposed completion in the permit application. 
  • File a completion report within 30 days of any physical change to the well as required under Rule 16(b)(2)

Guidelines for Filing Completion Reports:

  • Fill in required dates and permit numbers. Be certain injection into a productive zone for disposal purposes is shown under injection rather than disposal authority.
  • The well location blocks are to be completed on both front and back sides of Form W-2 or G-1.
  • Casing and liner record must be completed.
  • Presence of packer and packer depth must be included.
  • The "producing" interval must be included. Show the perforated intervals here, not the permitted intervals.
  • Please include all cement squeeze information.
  • Please indicate if the well is dually completed for disposal and production.
  • Select “Active UIC” as the “well type” if the well is in injection or disposal service, brine mining service, hydrocarbon storage service, or gas storage service
  • Select “Shut-in UIC” as the well type if the well is not configured to meet the definition of active operation given in Rule 15(a)(1).

Emergency Response Drill

Applies to permits pursuant to Rules 95 and 97

A emergency response drill must conducted annually as described by the rules quoted below.  Submit the report of the drill to UIC and the district office.

RULE §3.95         Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations

(h) Safety. The following safety requirements shall apply to all underground hydrocarbon storage facilities, except as specifically provided otherwise, provided, however, that the provisions of this subsection shall not apply to any hydrocarbon storage well that is out of service and disconnected from all surface piping. Notwithstanding the compliance time periods specified in this subsection, a new storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All storage facilities that are permitted on the effective date of this section must have such safety measures and equipment in place within the period of time specified. Further, until such a facility has all the safety measures and devices required by paragraphs (2) - (7) and (13) - (16) of this subsection in place, the facility must have an attendant on site at all times. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.

  (11) Annual emergency drill. Annually, each operator shall conduct a drill that tests response to a simulated emergency. Written notice of the drill shall be provided to the appropriate Commission district office, the county emergency management coordinator, and the county sheriff's office at least seven days prior to the drill. Local emergency response authorities shall be invited to participate in all such drills. The operator shall file a written evaluation of the drill and plans for improvements with the appropriate district office and the county emergency management coordinator within 30 days after the date of the drill.

RULE §3.97         Underground Storage of Gas in Salt Formations

(h) Safety. The following safety requirements shall apply to all underground gas storage facilities, provided, however, that the provisions of this subsection shall not apply to any natural gas storage well that is out of service and disconnected from surface piping. Notwithstanding the compliance time periods specified in this subsection, a new underground gas storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All existing storage facilities must have such safety measures and equipment in place within the period of time specified. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.

  (9) Annual emergency drill. Annually, each operator shall conduct a drill that tests response to a simulated emergency. Written notice of the drill shall be provided to the appropriate Commission district office, the county emergency management coordinator, and the county sheriff's office at least seven days prior to the drill. Local emergency response authorities shall be invited to participate in all such drills. The operator shall file a written evaluation of the drill and plans for improvements with the appropriate district office and the county emergency management coordinator within 30 days after the date of the drill.

Emergency Response Plan

Applies to permits pursuant to Rules 95, 96, and 97

Submit the plan (or updated plan) to UIC when the plan changes or is updated.  The operator is responsible for maintaining an emergency response plan pursuant to the following rules:

RULE §3.95         Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations

(h) Safety. The following safety requirements shall apply to all underground hydrocarbon storage facilities, except as specifically provided otherwise, provided, however, that the provisions of this subsection shall not apply to any hydrocarbon storage well that is out of service and disconnected from all surface piping. Notwithstanding the compliance time periods specified in this subsection, a new storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All storage facilities that are permitted on the effective date of this section must have such safety measures and equipment in place within the period of time specified. Further, until such a facility has all the safety measures and devices required by paragraphs (2) - (7) and (13) - (16) of this subsection in place, the facility must have an attendant on site at all times. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.

  (8) Emergency response plan. Each storage facility shall submit to the Commission a written emergency response plan. The plan shall address spills and releases, fires, fire suppression capability, explosions, loss of electricity, and loss of telecommunication services. The plan shall describe the storage facility's emergency response communication system, procedures for coordination of emergency communication and response activities with local emergency planning committees and other local authorities, use of warning systems, procedures for citizen and employee emergency notification and evacuation, and employee training. The initial plan must be designed based upon the existing safety measures at the facility. The plan shall be updated as changes in safety features at the facility occur, or as the Commission or its designee requires. The plan shall include a plat of the facility that shows the location of wells, processing areas, loading racks, brine pits, and other significant features at the site. A copy of the plan shall be provided to the local emergency response planning committee and to any other local governmental entity that submits a written request for a copy of the plan to the operator. Copies of the plan shall also be available at the storage facility and at the company headquarters.

RULE §3.97         Underground Storage of Gas in Salt Formations

(h) Safety. The following safety requirements shall apply to all underground gas storage facilities, provided, however, that the provisions of this subsection shall not apply to any natural gas storage well that is out of service and disconnected from surface piping. Notwithstanding the compliance time periods specified in this subsection, a new underground gas storage facility permitted under this section must have all required safety measures and equipment in place before commencement of storage operations at the facility. All existing storage facilities must have such safety measures and equipment in place within the period of time specified. Notwithstanding the compliance time periods specified in paragraph (2)(B) of this subsection, no storage well in active service may be operated without a fully functional emergency shutdown valve unless in compliance with specified conditions of paragraph (2)(C) of this subsection.

  (7) Emergency response plan. Each storage facility shall submit to the Commission a written emergency response plan. The plan shall address gas releases, fires, fire suppression capability, explosions, loss of electricity, and loss of telecommunication services. The plan shall describe the facility's emergency response communication system, procedures for coordination of emergency communication and response activities with local authorities, use of warning systems, procedures for citizen and employee emergency notification and evacuation, and employee training. The plan shall also include a plat of the facility showing the locations of wells, processing areas, and other significant features at the facility. The initial plan must be designed based upon the existing safety measures at the facility. The plan shall be updated as changes in safety features at the facility occur, or as the Commission or its designee requires. A copy of the plan shall be provided to the local emergency response committee and to any other local governmental entity that submits a written request for a copy of the plan to the operator. Copies of the plan shall also be available at the storage facility and at the company headquarters.

Casing Inspection Log

If the casing inspection accompanies an MIT report, include the casing inspection log as an attachment to the MIT report.  Otherwise, submit the casing inspection log via email to cavern_reports@rrc.texas.gov.  For each well, the schedule for the casing inspection log is determined by the rules cited below.

UIC may grant up to a five-year extension on the regular casing inspection requirement if sufficient information is available to establish that a well has not experienced noticeable casing degradation that may increase the risk of casing failure.  Information necessary to establish that a well has not experienced noticeable casing degradation must include at least two comparable casing inspection logs run at separate times over a period of not less than ten years and indicating that the condition of the casing has not noticeably changed during the interval of time between inspections.  Information necessary to waive the regular casing inspection requirement must also establish that there is competent cement coverage throughout the caprock interval and into the next outer casing.  Requests for extension to the casing inspection log must be submitted via email to cavern_reports@rrc.texas.gov.  The request will be reviewed within 45 days.

RULE §3.95         Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations

(o) Testing and maintenance.

  (1) ... Each hydrocarbon storage well drilled into a salt dome and having a single casing string cemented to the surface shall have the casing inspected by mechanical, ultrasonic, or magnetic methods at least once every five years and after each workover that involves physical changes to the cemented casing string.

  (3) Storage wellhead and casing. Storage wellhead components and casing shall be inspected at least once every 10 years for corrosion, cracks, deformations or other conditions that may compromise integrity and that may not be detected by the five-year test. The operator may request an extension of up to five years from the Commission for good cause. Factors the Commission may consider in determining good cause pursuant to this paragraph include by are not limited to the age, location, and configuration of the well; well and facility history; operator compliance record; operator efforts to comply with this subsection; and accuracy of inventory control.

RULE §3.97         Underground Storage of Gas in Salt Formations

(o) Testing and maintenance.

  (3) Storage wellhead and casing. Storage wellhead components and casing shall be inspected at least once every 15 years for corrosion, cracks, deformations, or other conditions that may compromise integrity and that may not be detected by the five-year test. The operator may request an extension of up to five years from the Commission for good cause. Factors the Commission may consider in determining good cause pursuant to this paragraph include by are not limited to the age, location, and configuration of the well; well and facility history; operator compliance record; operator efforts to comply with this subsection; and accuracy of inventory control.

Barbers Hill special field rules, established under Oil and Gas Docket No. 03-0223293, effective March 6, 2001, applicable to wells reported to the Barbers Hill field

Rule 5. Cavern and Well Inspections and Special Investigations

At least once every five years, commencing with the next mechanical integrity testing required by Statewide Rule 95(o), the operator of each active underground hydrocarbons storage well shall perform the following logs and surveys of the hydrocarbon storage well shall perform the following logs and surveys of the hydrocarbon storage well and cavern:

(3) downhole casing inspection logging of the final cemented casing (to determine the condition of the casing) using a commercially available electromagnetic, ultrasonic, or other similar logging technology suited for identifying and determining corrosion, pitting, crimping, or ovality of the particular wellbore.

Roof Monitoring Log

Applies to permits pursuant to Rules 95 and 97 for bedded salt formations.

A sonar survey may substitute for a roof monitoring log.

If the roof monitoring log accompanies an MIT report, include the roof monitoring log as an attachment to the MIT report.  Otherwise, submit the roof monitoring log via email to cavern_reports@rrc.texas.gov.  For each well, the schedule for the sonar survey is determined by the following rules:

RULE §3.95         Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations

(i) Cavern capacity and configuration.

  (4) Bedded salt. The configuration of the roof of each hydrocarbon storage cavern in bedded salt shall be determined by downhole log or an alternate method approved by the Commission or its designee at least once every five years.

  (6) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

RULE §3.97         Underground Storage of Gas in Salt Formations

(i) Cavern capacity and configuration.

  (3) Bedded salt. The configuration of the roof of each gas storage cavern in bedded salt shall be determined by downhole log or an alternate method approved by the Commission, or its designee, at least once every five years.

  (5) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any such cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

Sonar Survey

Applies to permits pursuant to Rules 95 and 97

If the sonar survey accompanies an MIT report, include the sonar survey as an attachment to the MIT report.  Otherwise, submit the sonar survey via email to cavern_reports@rrc.texas.gov.  For each well, the schedule for the sonar survey is determined by the following rules:

RULE §3.95         Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations

(i) Cavern capacity and configuration.

  (1) Crude oil storage. The provisions of this subsection shall not apply to underground hydrocarbon storage facilities where only crude oil is stored.

  (2) Before storage operations begin. The capacity and configuration of each hydrocarbon storage cavern (both salt domes and bedded salt) shall be determined by sonar survey before storage operations begin in a newly completed cavern.

  (3) Salt domes. The capacity and configuration of each salt dome hydrocarbon storage cavern shall be determined by sonar survey at least once every 10 years.

  (6) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

RULE §3.97         Underground Storage of Gas in Salt Formations

(i) Cavern capacity and configuration.

  (1) Before storage operations begin. The capacity and configuration of each gas storage cavern (both salt domes and bedded salt) shall be determined by sonar survey before storage operations begin in a newly completed cavern.

  (2) Salt domes. The capacity and configuration of each salt dome gas storage cavern shall be determined by sonar survey before a cavern that has been out of service is returned to service, provided, however, that a sonar survey shall not be required on a cavern that is being returned to service if a sonar survey of that cavern has been run at any time during the previous 10 years.

  (5) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any such cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

Directional Survey

Applies to permits pursuant to Rules 95 and 97 that are reported to the Barbers Hill field.  Directional surveys must be submitted via the RRC online directional surveys system pursuant to Rule 12.  For each well, the schedule is determined by the following rules:

Rule 5. Cavern and Well Inspections and Special Investigations

At least once every five years, commencing with the next mechanical integrity testing required by Statewide Rule 95(o), the operator of each active underground hydrocarbons storage well shall perform the following logs and surveys of the hydrocarbon storage well shall perform the following logs and surveys of the hydrocarbon storage well and cavern:

(2) gyroscope or directional survey (to determine the position of the wellbore)

Alternative Monitoring

Out-of-service or Permanently Deactivated Hydrocarbon Storage Wells

  1. MIT
    1. An operator of an out-of-service storage well may request approval to conduct storage well pressure monitoring in lieu of an MIT. See 16 Tex. Admin. Code §§ 3.95(o)(5) and 3.97(o)(2).
    2. A well must be tested for integrity before it is returned to service. See 16 Tex. Admin. Code §§ 3.95(o)(5) and 3.97(o)(2).
  2. Plugging
    1. An operator must apply for and receive approval from Staff before converting a permanently deactivated hydrocarbon storage well into a monitor well in lieu of plugging the well. See 16 Tex. Admin. Code §§ 3.95(p)(2) and 3.97(p)(2).
      1. An H-10H is not an application to convert a permanently deactivated hydrocarbon storage well into a monitor well.
    2. The operator must submit a pressure monitoring plan to the Commission with its request to convert the well to a monitor well. 16 Tex. Admin. Code §§ 3.95(p)(2) and 3.97(p)(2).
  3. Inactive well status
    1. An inactive well is defined as “an unplugged well that has had no reported production, disposal, injection, or other permitted activity for a period of greater than 12 months.” Tex. Nat. Res. Code § 89.002(a)(12).
    2. An out-of-service or permanently deactivated hydrocarbon storage well will be considered “inactive,” and subject to the Commission’s inactive well requirements, including, but not limited to, Rule 14(b)(2), if the well meets the definition of an inactive well. See 16 Tex. Admin. Code §§ 3.95(r) and 3.97(r) (“The owner or operator of an underground gas storage facility is not relieved by this section of compliance with any other requirements of Chapters 3, 4, 7, or 8 of this title (relating to Oil and Gas Division; Environmental Protection; Gas Services Division; or Pipeline Safety Regulations).”).


Commissioners