Administrative Rules for
Rule 2415.
(1) Injection of a waste product
shall not begin until all of the following are complete:
(a) The well is
confirmed for use as provided by R 299.2414.
(b) The warning system
required in subrule (8) of this rule is installed and tested or the monitoring
plan required in subrule (8) of this rule is approved by the supervisor of
mineral wells.
(c) A working check
valve is installed on the flow line as close as practicable to the wellhead to
prevent backflow.
(2) The permittee shall inject only
through tubing with a packer set within the innermost casing string or strings
at a point within or below the confining zone. During injection operations, the
annulus between the injection tubing and innermost casing shall be filled with
a noncorrosive liquid. Any changes in the arrangement of downhole equipment
shall be submitted by the permittee on forms prescribed by the supervisor of
mineral wells for approval by the supervisor of mineral wells or authorized
representative of the supervisor of mineral wells before installation.
(3) During disposal operations a
permittee shall ensure that the injection pressure at the wellhead does not
exceed a pressure determined by the following equation:
Pm = (fpg -
0.433 sg)d
where
Pm = surface injection pressure.
fpg = fracture pressure gradient.
sg = highest specific gravity of
liquid planned for injection.
d = depth to top of disposal zone in
feet (true vertical depth).
The
permittee shall maintain a positive pressure at the wellhead on the annulus
between the injection tubing and the innermost casing. Injection pressure shall
not initiate fractures or cause existing fractures to propagate into the
confining zone or cause movement of injected or formation fluids through the
confining zone.
(4) If migration of injected fluids
through the confining zone is discovered, the permittee shall immediately cease
injection and submit to the supervisor of mineral wells a remediation plan. A
report of the discovery shall be made orally to the supervisor of mineral wells
or authorized representative of the supervisor of mineral wells within 24 hours
of the time of discovery. A written report detailing the circumstances of the
discovery shall be filed with the supervisor of mineral wells within 10
business days of the discovery. The supervisor of mineral wells may require a
permittee to demonstrate an underground source of drinking water is not
impacted by the migration of injected fluid.
(5) The permittee shall at all times
ensure that injected fluids do not enter an underground source of drinking
water. If the injected fluids have the potential to react with the rock of the
injection formation, then the permittee shall ensure that pressure imbalances
do not occur.
(6) The supervisor of mineral wells
may require a permittee to monitor the pressure buildup in the injection zone.
The pressure monitoring shall include a suitable pressure transient test. From
this observation the permittee shall submit a report to the supervisor of
mineral wells including all of the following information:
(a) All measured data.
(b) A calculation of
pressure buildup and static bottom hole pressure in the injection zone.
(c) Injection zone
transmissivity.
(d) Well bore skin
factor.
(e) Radius of
investigation of the test. At least 30 days before a test, a permittee shall notify
the supervisor of mineral wells or authorized representative of the supervisor
of mineral wells of the date and approximate time of the test.
(7) If required by the supervisor of
mineral wells, the permittee shall maintain monitoring devices and use them to
monitor injection pressure, pressure in the annulus between the injection
tubing and the innermost casing, and injection rate. The permittee shall
monitor the annulus pressure system reservoir volume daily.
(8) The permittee shall do 1 of the
following:
(a) Install an automatic
warning system to notify the permittee if either of the following conditions
exist:
(i) Pressure
changes in the annulus or tubing signifying or identifying possible
deficiencies in mechanical integrity.
(ii) Injection
pressure exceeding the pressure limits specified in subrule (3) of this rule.
(b) Submit for the
supervisor of mineral wells approval, a monitoring plan to detect conditions
described in paragraphs (a)(i) and (a)(ii) of this subrule.
(9) The permittee shall test an
automatic warning system installed under subrule (8) of this rule at least
every twelfth month. The test must involve subjecting the system to simulated
failure conditions. At least 30 days before a test, a permittee shall notify the
supervisor of mineral wells or authorized representative of the supervisor of
mineral wells of the date and approximate time of the test.
(10) The permittee shall install and
maintain a suitable coupling and valve on the wellhead to be used for independent
injection pressure measurements.
(11) All injection and withdrawal
activities shall be monitored by an individual who is trained and experienced
in such activities. A permittee shall submit a plan for monitoring injection
and withdrawal activities. The wellhead and facility shall be secured in a
manner to prevent unauthorized access to the well if the well is not in use for
an extended period of time.
(12) The supervisor of mineral wells
or authorized representative of the supervisor of mineral wells may approve a
waste product, in addition to those specified in the application for a permit
to drill and operate, to be injected into a well. Requests to inject an
additional waste product shall be in writing and accompanied by the
characterization required in R 299.2312(h).
(13) A permittee shall submit a
waste analysis plan for approval by the supervisor of mineral wells or the
authorized representative of the supervisor of mineral wells.
(14) A permittee shall submit
monthly reports of the following information no later than the end of the month
following the reporting period:
(a) Maximum and average
injection pressure for each day of the month and monthly averages of the
maximum and minimum injection pressures.
(b) maximum and minimum
pressure in the annulus between the injection tubing and innermost casing for
each day of the month and monthly averages of the maximum and minimum pressure
in the annulus between the injection tubing and innermost casing.
(c) Maximum and average
injection rates for each day of the month and monthly averages of the maximum
and minimum injection rates.
(d) The total volume of
waste products injected for each day of the month and to date, in the current
calendar year. If surface runoff is injected, the total annual and monthly
volumes for both waste fluids and surface runoff shall be reported
individually. If waste products injected into a multisource commercial
hazardous waste disposal well include waste that is not hazardous, the volumes
of both hazardous and nonhazardous waste shall be reported separately.
(e) The amounts and
types of liquid added to or removed from the annulus pressure system for each
day of the month and the cumulative amount of liquid added to or removed from
the annulus pressure system for the current month and each of the past 12
months.
(f) Any event that
exceeds operating pressures as specified in subrule (3) of this rule and any
event that triggers an alarm or shutdown device provided by subrule (8) of this
rule.
(g) A description of any
well bore stimulation that does not require an application to change well
status under R 299.2384, including all of the following:
(i) The date
of the stimulation.
(ii) The
amount of acid used.
(iii) The
concentration and type of acid used.
(iv) The
maximum pressure generated during the stimulation.
(h) The supervisor of
mineral wells may grant an exception to the reporting requirements of
subdivisions (a) to (g) of this subrule if a permittee makes a request in
writing. (15) All records pertaining to a disposal well shall be retained by
the permittee for a period of at least 3 years following the plugging and
abandonment of the disposal or storage well and shall be open to inspection at
any time by the supervisor of mineral wells or an authorized representative of
the supervisor of mineral wells.
These administrative rules are provided as a free
service of the State Bar of Michigan Environmental Law Section. The administrative rules, which were
re-formatted for consistency, are not intended to replace official versions and
are subject to revision and/or repeal. The Environmental Law Section presents this information, without
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timeliness, or completeness. If you believe the information is inaccurate,
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