(GP/GT) for Additional Water Supply in the Lower Rio Grande

the applicant can show. by computation. that a lesser area will be affected by pressure
increases. then the lesser area may be used in Heu of the fIXed radius. In cases where the
Director has knowledge of geologic. hydrologic. or engineering condl tlons specific to a given
operation which ensure that wells within the area of review will not serve as conduits for
migration of fluids Into fresh water resources. a permit may be issued without reqUIring
corrective action on wells wi thin the area of review. Under this situation. the Director may
waive certain data submission reqUirements. No permit will be Issued, however. where the
Information submitted Indicates that fresh water sources will be endangered unless permit
conditions require appropriate corrective action In the area.
Tubing and Packer Requirements
On all newly drilled or converted disposal and Injection wells. Injection must be through
tubing set on a packer unless an exception Is granted by the Director for good cause.
Operating Requirements
Maximum Injection pressure limitations have been part of the Commlsslon's permitting
program for many years and will continue to be required as a condition of each Class II
permit Issued. Pressure limitations are establlshed to provide adequate assurance that
Injection will not Initiate fractures In the confining zones.
Monitoring and Reporting
The operator of each Class II wen Is required by the Statewide Rules and by each new
permit to monitor the Injection pressure and volume on a monthly basis and to report the
results annually on the prescribed form (Form H-lO). For Class II wells. except hydrocarbon
storage facll!tles. any downhole problem must be reported to the appropriate district office
within twenty-four (24) hours and confirmed In wrltlng within five (5) working days.
Operators of hydrocarbon storage facll!tles must report problems to the appropriate district
office Immediately and must confirm this report In wrltlng within five (5) days. An
automatic data processing system was developed for the monitoring and annual reports.
Mechanical Integrity
The Statewide Rules reqUire that all Class II wells be pressure-tested at least once every
five (5) years to determine If leaks exist In the casing. tubing. or packer. Permits require
pressure tests prior to beginning Injection operations and after each workover. Some
permits reqUire annual pressure tests. The appropriate district office must be notified
before conducting the pressure test to allow a Commission representative to witness the
test. The operator must then rue a record of this test with the district office (Form H-5). As an
alternative to this pressure-testing. the operator may monitor the casing-tubing annulus
pressure and report the results annually to demonstrate that no additional pressure-testing
Is needed. Also. an exception to testing may be granted upon demonstration to the Director
of a viable alternative monitOring program. Mechanical Integrity testing must also be
performed. pursuant to Rule 74. for storage wells.
Completion Reports
A Completion Report (Form W-2 or G-l) must be filed with the appropriate district office
within thirty (30) days of completion or conversion to disposal. Injection. or underground
hydrocarbon storage operations to reflect the new or current completion.
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