UPDATED APRIL 4, 2016
Changes were made to Louisiana state regulations concerning Hydrocarbon Storage Wells in Salt Dome Cavities (43.17.3.3) and Class III (Solution Mining) Injection Wells (43.17.5.33). Salt dome storage development and activity has come under increasing scrutiny at the state and federal levels, and these changes reflect the additional interest in these operations.
Two of the changes that can potentially mean more work and expense for the owner / operator involve the new permitting regime, which has many more steps than in the past, and a change to a 15 year frequency for refilling caverns with water and running multiple integrity tests. Other changes are summarized below.
For Title 43, Part XVII.3.3 – Hydrocarbon Storage Wells in Salt Dome Cavities, changes to the regulations include:
- §303.B. This modification involves Statewide Orders 29-M and 29-M (Revision 3) and requirements for compliance.
- §303.G. Additional Requirements: these are now given in much greater detail, and reports must be submitted by licensed professional geoscientists and licensed professional engineers.
- §309.B.1. The financial responsibility requirements are now expanded to explicitly include class II saltwater disposal wells and any associated equipment or pipelines whether located inside or outside of the permitted facility boundary.
- §309.B.3. and 4. The information on Assistance to Residents has been removed for other parts of the regulation and consolidated and expanded in new subpart 3. The new subpart 4 contains a description of reimbursement to states and individuals.
- §309.F.9. Under Notification Requirements, there is an addition that requires that hydrocarbon storage caverns that are not in an inactive status as of the date written notification of permanent conclusion of storage operations is submitted to the Office of Conservation will be immediately placed in an inactive status.
- §309.K.1. This section, under Compliance Review, now gives a detailed list of acceptable submittals for satisfying cavern location and periphery of salt stock review.
- §311.D.1.c. This is a new section under Public Hearing Requirements as part of the Permitting Process that pertains only to Iberia Parish, and concerns the requirement of a public hearing prior to the issuing of certain salt cavern permits.
- §315.B.3.d. Regarding salt periphery under Cavern Design, this new section will allow caverns with less than 300 feet but more than 100 feet of salt separation to continue to operate with enhanced monitoring and any additional documentation that the commissioner feels necessary in the interest of safe operations.
- §327. A Mechanical Integrity Test (MIT) must now be performed prior to well closure except in the event of mechanical failure in the cavern. Additionally, a separate pressure test on the casing, of at least 60 minutes, shall be performed when an MIT is run.
- §329. Concerning cavern configuration and capacity, types and frequency of surveys are more detailed.
- §331. Inactive caverns may not be returned to service without the submittal of a written request and work permit application to the Office of Conservation, and the approval of the commissioner.
Similar changes were made in Title 43, Part XVII.5.33 – Class III (Solution Mining) Injection Wells.