La. Admin. Code tit. 43 § XVII-625

Current through Register Vol. 50, No. 11, November 20, 2024

Section XVII-625 - Testing and Monitoring

A. Testing and Monitoring Requirements. The owner or operator of a Class VI well must prepare, maintain, and comply with a testing and monitoring plan to verify that the geologic sequestration project is operating as permitted and is not endangering USDWs. The requirement to maintain and implement an approved plan is directly enforceable regardless of whether the requirement is a condition of the permit. The testing and monitoring plan must be included with the permit application and must include a description of how the owner or operator will meet these requirements- including accessing sites for all necessary monitoring and testing during the life of the project. Testing and monitoring associated with geologic sequestration projects must include, at a minimum:

1. analysis of the carbon dioxide stream with sufficient frequency to yield data representative of its chemical and physical characteristics;

2. installation and use of continuous recording devices to monitor injection pressure, rate, and volume; the pressure on the tubing-casing annulus; and the annulus fluid volume added. Continuous monitoring is not required during well workovers as defined in §621.A 5;

3. corrosion monitoring of the well materials for loss of mass, thickness, cracking, pitting, and other signs of corrosion, which must be performed on a quarterly basis to ensure that the well components meet the minimum standards for material strength and performance set forth in §617.A 2, by:

a. analyzing coupons of the well construction materials placed in contact with the carbon dioxide stream; or

b. routing the carbon dioxide stream through a loop constructed with the material used in the well and inspecting the materials in the loop; or

c. using an alternative method approved by the commissioner;

4. periodic monitoring of the ground water quality and geochemical changes above the confining zone(s) that may be a result of carbon dioxide movement through the confining zone(s) or additional identified zones including:

a. the location and number of monitoring wells based on specific information about the geologic sequestration project, including injection rate and volume, geology, the presence of artificial penetrations, and other factors; and

b. the monitoring frequency and spatial distribution of monitoring wells based on baseline geochemical data that has been collected under §607.C.2.e and on any modeling results in the area of review evaluation required by §615.B 3

5. a demonstration of external mechanical integrity pursuant to §627.A.3 at least once every 12 months until the injection well is permanently plugged and abandoned; and, if required by the commissioner, a casing inspection log pursuant to requirements at §627.A.4 at a frequency established in the testing and monitoring plan;

6. a pressure fall-off test at least once every five years unless more frequent testing is required by the commissioner based on site-specific information;

7. testing and monitoring to track the extent of the carbon dioxide plume and the presence or absence of elevated pressure (e.g., the pressure front) by using:

a. direct methods in the injection zone(s); and

b. indirect methods (e.g., seismic, electrical, gravity, or electromagnetic surveys and/or down-hole carbon dioxide detection tools), unless the commissioner determines that such methods are not appropriate, based on site-specific geology;

8. The commissioner may require surface air monitoring and/or soil gas monitoring to detect movement of carbon dioxide that could endanger a USDW.

a. Design of Class VI surface air and/or soil gas monitoring must be based on potential risks to USDWs within the area of review;

b. The monitoring frequency and spatial distribution of surface air monitoring and/or soil gas monitoring must be decided using baseline data, and the monitoring plan must describe how the proposed monitoring will yield useful information on the area of review delineation and/or compliance with standards under §603 D;

c. If an owner or operator demonstrates that monitoring employed under 40 CFR 98.440 to 98.449 accomplishes the goals of §625.A.8.a and b., and meets the requirements pursuant to §629.A.1 v, a regulatory agency that requires surface air/soil gas monitoring must approve the use of monitoring employed under 40 CFR 98.440 to 98.449. Compliance with 40 CFR 98.440 to 98.449 pursuant to this provision is considered a condition of the Class VI permit;

9. Any additional monitoring, as required by the commissioner, necessary to support, upgrade, and improve computational modeling of the area of review evaluation required under §615.B.3 and to determine compliance with standards under §619;

10. The owner or operator shall periodically review the testing and monitoring plan to incorporate monitoring data collected under §625, operational data collected under §621, and the most recent area of review reevaluation performed under §615.C.2 In no case shall the owner or operator review the testing and monitoring plan less often than once every five years. Based on this review, the owner or operator shall submit an amended testing and monitoring plan or demonstrate to the commissioner that no amendment to the testing and monitoring plan is needed. Any amendments to the testing and monitoring plan must be approved by the commissioner, must be incorporated into the permit, and are subject to the permit modification requirements at §613, as appropriate. Amended plans or demonstrations shall be submitted to the commissioner as follows:

a. within 12 months of an area of review reevaluation;

b. following any significant changes to the facility, such as addition of monitoring wells or newly permitted injection wells within the area of review, on a schedule determined by the commissioner; or

c. when required by the commissioner.

11. a quality assurance and surveillance plan for all testing and monitoring requirements.

B. Monitoring and Records

1. Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity.

2. The permittee shall retain records of all monitoring information, including the following:

a. calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least 3 years from the date of the sample, measurement, report, or application. This period may be extended by request of the commissioner at any time; and

b. the nature and composition of all injected fluids until three years after the completion of any plugging and abandonment procedures specified under §629 The commissioner may require the owner or operator to deliver the records to the commissioner at the conclusion of the retention period.

3. Records of monitoring information shall include:

a. the date, exact place, and time of sampling or measurements;

b. the individual(s) who performed the sampling or measurements;

c. the date(s) analyses were performed;

d. the individual(s) who performed the analyses;

e. the analytical techniques or methods used; and

f. the results of such analyses.

4. Owners or operators of Class VI wells shall retain records as specified in §615.C.4 6, and 633.A.8 of this chapter.

La. Admin. Code tit. 43, § XVII-625

Promulgated by the Department of Natural Resources, Office of Conservation, LR 4774 (1/1/2021).

AUTHORITY NOTE: Promulgated in accordance with R.S. 30:4 et seq., 30:22 et seq., and 30:1101 et seq.