R 324.413 Drilling to strata beneath gas storage reservoirs.

Rule 413. Except when special orders have been adopted for specific reservoirs, areas, or practices, all of the following provisions about drilling to strata beneath gas storage reservoirs shall apply: (a) The applicant shall send a copy of the entire drilling permit application and all revisions to the gas storage operator when the application and revisions are submitted to the supervisor. The gas storage operator shall have 10 business days to provide written comments to the supervisor. (b) Drilling operations shall proceed through gas storage zones only when the gas storage reservoir pressure exerts a pressure gradient of not more than 0.50 psig per foot of true vertical depth to the top of the gas storage zone. (c) Drilling rigs for wells drilled through gas storage reservoirs shall use rotary tools and shall have blowout prevention equipment pursuant to R 324.406. Complete operational checks of the well control appliances shall be made every 8 hours, with the well control system initially checked by pressure testing and checked again before drilling into the gas storage reservoir. The 8-hour checks shall be recorded in the daily driller's log. (d) Surface casing and any other protective casing string required above the gas storage reservoir shall be new casing manufactured in compliance with the API specifications for casing and tubing as adopted by reference in R 324.411, the properties and design of which have been approved by the supervisor or authorized representative of the supervisor. Surface casing and any other protective casing string shall be designed to withstand the required test pressures as set forth in R 324.410(3). Surface casing shall be set pursuant to R 324.408. Surface casing shall be cemented to the surface and not disturbed for a period of 18 hours after completion of cementing. Cement shall attain a minimum compressive strength of 500 psi before disturbing the casing or resuming drilling. Surface casing, other protective casing strings, and blowout preventers shall be tested pursuant to R 324.406(4) before drilling out the cement, unless otherwise specified by the supervisor or authorized representative of the supervisor. (e) Drilling fluid shall be circulated and conditioned at a point not less than 100 feet above the gas storage reservoir and shall be maintained with the following characteristics until the gas storage reservoir is cased off: (i) Drilling fluid density shall be sufficient to provide a hydrostatic pressure of not less than 100 psig above the anticipated bottom hole pressure of the gas storage reservoir. (ii) When drilling through the storage reservoir, the drilling fluid shall have a maximum fluid loss of 15 cubic centimeters or less as specified by the API standard procedure for testing drilling fluids, API RP 13B-1, entitled “Recommended Practice for Field Testing Water-Based Drilling Fluids,” March, 2009, fourth edition, which is adopted by reference in these rules. Copies are available for inspection at the Lansing office of the office of oil, gas, and minerals of the department of environmental quality. Copies may be obtained from the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals, P.O. Box 30256, Lansing, Michigan 48909, at a cost as of the time of adoption of these rules of $165.00 each, and from the American Petroleum Institute, 1220 L Street NW, Washington, DC 20005, at a cost as of the time of adoption of these rules of $165.00 each. (f) Hole size shall be large enough to allow the running of a separate intermediate casing, which shall be set through each gas storage reservoir. The casing shall be new and conform to the API specification and performance properties for casing, tubing, and drill pipe, API BULL 5C3, entitled “Bulletin on Formulas and Calculations for Casing, Tubing, Drill Pipe, and Line Pipe Properties, October 1, 1994,” sixth edition, which is adopted by reference in these rules. Copies are available for inspection at the Lansing office of the office of oil, gas, and minerals of the department of environmental quality. Copies may be obtained from the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals, P.O. Box 30256, Lansing, Michigan 48909, at a cost as of the time of adoption of these rules of $206.00 each, and from the American Petroleum Institute, 1220 L Street NW, Washington, DC 20005, at a cost as of the time of adoption of these rules of $206.00 each. The gas storage operator shall be allowed to review the intermediate casing design and cementing program before implementation. Intermediate casing shall be set in competent stratum approximately 100 feet below the base of the gas storage reservoir or set as required by the supervisor or authorized representative of the supervisor. Intermediate casing shall be designed for the maximum gas storage reservoir operating pressure using a minimum collapse design factor of 1.125, a minimum burst design factor of 1.25, and a minimum tension design safety factor of 1.6. The minimum hole size for a given size casing shall be pursuant to R 324.410(4). The hole shall be properly conditioned before running casing by circulating the drilling fluid at a rate equal to the drilling circulating rate and by utilizing a circulating time equivalent of not less than twice the hole displacement. Casing shall be equipped with a sufficient number of centralizers and scratchers to ensure good cement distribution and shall include centralizers above and below the gas storage reservoir. All centralizers shall conform to the API for casing centralizers, API specification 10D, entitled “Specification for Bow-Spring Casing Centralizers,” March 6, 2002, sixth edition, which is adopted by reference in these rules. Copies are available for inspection at the Lansing office of the office of oil, gas, and minerals of the department of environmental quality. Copies may be obtained from the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals, P.O. Box 30256, Lansing, Michigan 48909, at a cost as of the time of adoption of these rules of $89.00 each, and from the American Petroleum Institute, 1220 L Street NW, Washington, DC 20005, at a cost as of the time of adoption of these rules of $89.00 each. Casing shall include float equipment that will prevent movement after the cementing operation is completed. If conditions allow, casing shall be rotated or reciprocated slowly during cementing. The mill varnish shall be removed from the casing shoe to a point 100 feet above the storage reservoir. An acceptable spacer that is at least as dense as the drilling fluid shall precede the cement to aid in removing the drilling fluid. Cement mix water shall be tested before the cementing operation to ensure compatibility with the cement. The casing shall be cemented using a sufficient cement volume to circulate cement to the surface. Multistage cementing operations and external casing packers may be used only with the approval of the supervisor or authorized representative of the supervisor. Cemented casing shall not be disturbed for a period of 18 hours. Cement shall also attain a minimum compressive strength of 500 psi based on cement tables before disturbing the casing or resuming drilling. Absent backflow, the internal casing pressure shall be relieved after the cementing operation. Intermediate casing and the blowout preventers shall be tested to a pressure of not less than 1,500 psig at the surface or as otherwise specified by the supervisor or authorized representative of the supervisor, and the pressure shall be held for not less than 20 minutes before drilling out the cement. (g) When additional intermediate casing is run inside the innermost storage zone casing, below the base of the Detroit river group, the intermediate casing string and cementing shall be pursuant to these rules and the orders and instructions issued by the supervisor. (h) A centralized cement bond evaluation log or equivalent test approved by the supervisor shall be performed on the storage zone casing before running subsequent casing or plugging the hole, but not sooner than 48 hours after cementing the storage zone intermediate casing. A description of problems occurring while running or cementing casing shall be recorded in the daily driller's log. If unsatisfactory conditions are indicated, including unsatisfactory cement bonding, gas to the surface in the cellar area, or gas pressure on the surface or intermediate casing string annulus, and additional testing does not provide sufficient proof the unsatisfactory condition does not exist, then the permittee shall initiate remedial action before additional casing is installed. (i) Wellhead equipment and assemblies shall conform to the API specification for wellhead equipment, and shall include slip and seal assemblies for all casings, unless an exception is approved by the supervisor or authorized representative of the supervisor. The API specification for wellhead equipment is specification 6A, entitled “Specification for Wellhead and Christmas Tree Equipment,” October, 2010, twentieth edition, which is adopted by reference in these rules. Copies are available for inspection at the Lansing office of the office of oil, gas, and minerals of the department of environmental quality. Copies may be obtained from the Michigan Department of Environmental Quality, Office of Oil, Gas, and Minerals, P.O. Box 30256, Lansing, Michigan 48909, at a cost as of the time of adoption of these rules of $260.00 each, and from the American Petroleum Institute, 1220 L Street NW, Washington, DC 20005, at a cost as of the time of adoption of these rules of $260.00 each. The wellhead shall be assembled to allow the monitoring of the pressure of each annulus at the surface. (j) The permittee shall notify the gas storage operator before moving personnel or equipment, or both, onto the well location to ensure all of the following: (i) That the proposed well location does not endanger gas storage facilities or storage operations. (ii) That the movement of drilling rigs, related trucks, and equipment does not endanger gas storage facilities or storage operations. (iii) That the gas storage operator is allowed to witness drilling operations that impact the gas storage reservoir.