R 299.2415
R 299.2415 Operation of disposal wells; monitoring and reporting requirements.
Cite as Mich. Admin. Code R 299.2415
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 11 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.