UNITED STATES
ENVIRONMENTAL
PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 300
DENVER, COLORADO 80202-
SUBJECT: GROUNDWATER PROGRAM GUIDANCE
2466
NO.
40: Plugging and
Abandonment Requirements For Class II Injection Wells
FROM: D. Edwin Hogle
Director, Groundwater Program
Office of Pollution Prevention,
State and Tribal Assistance
Sharon L. Kercher, Director
Technical Enforcement Program
Office of Enforcement, Compliance
and Environmental Justice
TO: Underground Injection Control (UIC) Program Staff
Montana Operations Office
Region VIII Class II Well Operators
Region VIII Delegated Class II UIC Programs
I. Introduction
This guidance is intended to provide information about the
Environmental Protection Agency (EPA) requirements for developing
and submitting Class II injection well plugging and abandonment
(P&A) plans for Region VIII approval. GROUNDWATER PROGRAM
GUIDANCE NO. 41 discusses Region VIII requirements for financial
responsibility. Although EPA plugging and abandonment
requirements can be found in the Code of Federal Regulations
(CFR) Title 40 (40 CFR) Parts 144, 146, and 147, those
regulations provide, at best, some non-specific guidelines for
plugging and abandoning injection wells. This guidance discusses
the following topics.
P&A Plan Information Requirements
Methods And Technical Considerations
P&A Plans And Financial Responsibility
Post-P&A Reporting Requirements
When EPA first promulgated final underground injection
control (UIC) regulations in 1984 under the Safe Drinking Water
Act (SDWA), it provided for protection of all aquifers or parts
of aquifers which meet the definition of an underground source of
drinking water (USDW), except where exempted (see 40 CFR 144.7
and 146.4). A USDW is defined by EPA as an aquifer or its
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portion: which supplies any public water system; or which
contains a sufficient quantity of ground water to supply a public
water system and currently supplies drinking water for human
consumption or has a total dissolved solids (TDS) concentration
of less than 10,000 mg/l, and is not an exempted aquifer. P&A
plans are developed and implemented in order to assure the
prevention of movement of fluids into or between USDWs after an
injection well has served its useful life.
Although EPA plugging and abandonment requirements address
the protection of USDWs, other local, state, tribal, and federal
agencies may require plugs to be set for additional reasons. For
example, other regulatory agencies may require additional plugs
to address the following objectives:
1. Protect surface soils and surface waters from contamination
by formation fluid migration to the surface;
2. Isolate oil, gas, or mineral-bearing formations;
3. Isolate well problems (junk split casing, etc.);
4. Isolate casing shoes, or casing stubs;
5. Isolate injection/disposal intervals; and
6. Minimize conflict with surface land use.
Bureau of Land Management (BLM) well plugging requirements
may be found in 43 CFR Part 3160. It is the operator's
responsibility to be aware of all required plugs and include them
in the P&A plan. All plugs should be shown on the well schematic
submitted as part of the EPA's required P&A plan.
II. Information Needed to Develop a P&A Plan
Well construction and geologic information is needed to
develop a P&A Plan and is required by the EPA to evaluate whether
the proposed plugging procedures will be adequate to protect all
USDWs. This information generally is included as part of the
permit application and must be referenced in the P&A plan.
The applicant must provide a completed EPA Form 7520-14 and
other information that supports the proposed P&A plan. Other
information includes: all Well Completion and Sundry Notice
Reports; the daily drilling log (through completion); cased and
open hole logs with log headers; a brief narrative description of
the plugging and abandonment procedures; and a schematic diagram
for both of the following:
1) The Existing Well Configuration, that shows hole size, all
surface, intermediate and long string casing(s), depth to top of
cement and how determined, depth of all perforated intervals, and
Groundwater Program Guidance No. 40 2
depth of intervals of all repairs and/or cement Asqueezes.@ The
Information Needed to Develop a P&A Plan (continued)
schematic also should show and identify by formation name and top
and bottom depth:
all water-bearing zones (show TDS of each zone),
all confining zones, and
all hydrocarbon-bearing zones.
2) The Proposed Well Configuration After Plugging And
Abandonment, that shows hole size, all surface, intermediate and
long string casing(s), the placement of any and all bridge plugs,
all repairs and/or cement Asqueezes@, any unusual conditions
(e.g. > junk= in hole, etc.), all retainers and cement plugs, all
perforations, and a description of the fluid to remain between
plugs. The schematic should show and identify by formation name
and top and bottom depth:
all water-bearing zones (show TDS of each zone),
all confining zones, and
all hydrocarbon-bearing zones.
Documentation provided must identify hole size and strings
of casing by size, weight, and setting depth. Cement information
should describe the number of sacks used and the type of cement.
When available, include a complete cement bond log (CBL). At a
minimum, include a CBL that covers the interval from a section of
free pipe directly above the top of cement continuing unbroken
through the cemented interval and on down to total depth. Also
include the CBL > log header= that records all logging
parameters.
Several methods for obtaining TDS values accepted by the EPA
are listed below. Alternate methods and sources of information
may be accepted upon approval.
Open hole log analyses.
Water analyses of samples recovered from Aswab@ tests.
Drill stem test (DST) water recovery analyses generally
are not acceptable unless it can be shown that the
Groundwater Program Guidance No. 40 3
water in the chamber was not contaminated by drilling
or other fluids.
Produced water analyses from nearby wells
Confining zones are those geologic formations, or parts of
formations, which provide an effective barrier to the migration
of fluids above, between and below USDWs and other fluid bearing
geologic formations.
III. Methods and Technical Considerations
Plugging and abandonment operations commence in the
lowermost interval and proceed sequentially up the wellbore to
the surface. Discussions of plug placement techniques and
cementing materials are available in the SPE Monograph,
Cementing, edited by Dwight K. Smith and Well Cementing, edited
by Erik B. Nelson.
A. PLUG PLACEMENT CONSIDERATIONS
EPA=s key objective for injection well abandonment is to
protect all USDWs. Critical intervals, such as USDWs, water-
bearing zones, hydrocarbon-bearing zones, and confining zones may
require separate plugs to adequately isolate and protect all
USDWs. If there is more than 2,000 mg/liter difference of TDS
between individual exposed USDWs, they must be isolated from each
other. In a case where all USDWs are within 2,000 mg/l TDS of
each other, isolation may be accomplished by setting a plug at
the base of the lowermost USDW. A surface plug of at least 50
feet must be set inside and outside of the casing, to prevent
surface water runoff from entering the plugged and abandoned
wellbore and to seal all possible pathways for fluid migration
into the subsurface via the well.
Uncemented longstring casing intervals frequently exist in
older wells, and all exposed critical intervals must be isolated
by placing cement behind pipe. Uncased (exposed) intervals also
may occur if the longstring casing is cut and pulled during
abandonment operations. Other agencies may require that the
remaining casing > stub= is sealed off before isolating other
zones uphole.
B. PLUG LENGTH AND COVERAGE CONSIDERATIONS
Groundwater Program Guidance No. 40 4
Cement plugs must extend at least 50 feet above and below
each zone being isolated. In some cases, for example where a
zone is greater than 100 feet thick, placing a minimum 100 feet
plug at the top and base of the interval may be adequate (rather
than cementing across the entire geologic horizon). The volume
of cement to be used for adequate plug coverage should be
calculated using the desired plug length, the casing diameter,
the hole diameter based on caliper logs, and must include
allowances for cement contamination by wellbore fluids or
cementing spacers and any unusual wellbore conditions.
C. CEMENT TYPE AND WELL FLUID CONSIDERATIONS
The wellbore fluid should be at static equilibrium prior to
cement plug placement operations. Control measures such as
Methods and Technical Considerations (continued)
spotting viscous high density mud pills, pumping lost circulation
material, or other methods may be necessary to achieve static
equilibrium. Water-based muds, or brines containing a plugging
gel, with a density of at least 9.2 lb/gal should be used during
plugging operations, and should remain between plugs in the well
after cement plug placement.
Class A, C, G, or H cements typically are used in well
plugging operations. The selection of cement for plugging
depends on the well depth, formation temperatures, formation
properties, and wellbore mud properties. Cement additives such
as accelerators and retarders may be added to enhance or control
the properties of the cement slurry, however, volume-extending
additives and > gel= cements must not be used for cement plugs.
D. PLUG PLACEMENT METHODS
1. Isolating the injection zone: Several methods may be
employed to isolate the injection zone from the rest of the
wellbore. These include:
For Open Hole Completions:
Using a cement retainer. The injection zone may be isolated
by setting a cement retainer 50-100 feet above the casing
shoe and squeezing cement below the retainer. The amount of
cement used must be adequate to fill both the casing and the
open hole interval to at least 50 feet below the casing
shoe. At least 20 feet of cement also should be left on top
of the retainer.
Groundwater Program Guidance No. 40 5
Using a Cast Iron Bridge Plug (CIBP). A CIBP set 50-100
feet above the casing shoe may effectively isolate the open-
hole interval. At least 20 feet of cement also should be
left on top of the bridge plug.
Setting a Balanced Plug. The balanced plug method involves
pumping cement slurry through drill pipe, coiled tubing,
work string, or production tubing until the level of cement
outside is equal to that inside the drill pipe/tubing
string. The pipe then is pulled slowly from the slurry,
leaving behind the cement plug. To minimize cement
contamination by wellbore fluids, fluid spacers should be
used both ahead of and behind the slurry, especially if the
wellbore fluid is incompatible with the cement slurry. Plug
placement must be verified by tagging the top of the plug
after the cement has had adequate time to set. If a bridge
Methods and Technical Considerations (continued)
plug is used at the base of the cement plug, tagging the top
of the plug is not necessary.
For Cased Hole Completions
Using a cement retainer. The injection zone may be isolated
by setting a cement retainer 50-100 feet above the injection
perforations and squeezing cement below the retainer. The
amount of cement used must be adequate to fill the casing
between the retainer and the perforations, and should allow
for some extra cement to be squeezed into the perforations.
At least 20 feet of cement also should be left on top of
the retainer.
Using a Cast Iron Bridge Plug (CIBP). A CIBP set 50-100
feet above the top injection perforation may effectively
isolate the injection interval. At least 20 feet of cement
should also be left on top of the bridge plug.
Setting a Balanced Plug. The balanced plug method involves
pumping cement slurry through drill pipe, coiled tubing,
work string, or production tubing until the level of cement
outside is equal to that inside the drill pipe/tubing
string. The pipe then is pulled slowly from the slurry,
leaving behind the cement plug. To minimize cement
contamination by wellbore fluids, fluid spacers should be
used both ahead of and behind the slurry, especially if the
wellbore fluid is incompatible with the cement slurry. Plug
placement must be verified by tagging the top of the plug
after the cement has had adequate time to set. If a bridge
Groundwater Program Guidance No. 40 6
plug is used at the base of the balanced plug, tagging the
top of the plug is not necessary.
2. Isolating up-hole zones: Several methods may be employed
to isolate up-hole zones from the rest of the wellbore.
These include:
For Uncased (Open Hole) Intervals
Setting a Balanced Plug. The balanced plug method involves
pumping cement slurry through drill pipe, coiled tubing,
work string, or production tubing until the level of cement
outside is equal to that inside the drill pipe/tubing
string. The pipe then is pulled slowly from the slurry,
leaving behind the cement plug. To minimize cement
contamination by wellbore fluids, fluid spacers should be
used both ahead of and behind the slurry, especially if the
Methods and Technical Considerations (continued)
wellbore fluid is incompatible with the cement slurry. Plug
placement must be verified by tagging the top of the plug
after the cement has had adequate time to set.
Using a Dump Bailer. The dump bailer containing a measured
quantity of cement is lowered into the well on wireline.
The bailer opens by electrical activation. Because cement
contamination can occur when setting plugs with a dump
bailer, use of this method is discouraged. If this method
is chosen, the operator may be required to take additional
special measures to ensure the quality of the cement plug.
These measures may vary depending on site-specific
conditions, and may add considerable time to the plugging
operation and approval. Dump-bailed plug placement must be
verified by tagging the top of the plug after the cement has
had adequate time to set.
For Uncemented, Cased Hole Intervals
Cement Squeeze Method. The cement squeeze method often is
used to isolate intervals where uncemented casing exists
through the interval to be plugged. This method requires
that the casing be perforated and cement forced through
these perforations into the space between the casing and the
formation face. Several methods may be employed for squeeze
cementing, but the method that assures the most accurate
placement of cement is the block squeeze. Normally, a block
squeeze involves two sets of perforations; one at the base
of the interval to be cemented, and the other set of
Groundwater Program Guidance No. 40 7
perforations at the top of the interval. Usually a cement
retainer is set immediately above the lower set of
perforations, and cement is pumped through the retainer via
the tubing or workstring. As cement passes through the
retainer, it is forced out the lower set of perforations and
upward through the casing/open-hole annulus. Fluid returns
are taken through the top set of perforations, allowing mud
and cement to flow back into the casing. Evidence of a good
cement job can be seen when cement is circulated out of the
casing. After cement has been squeezed behind casing, the
inside of the casing can be cemented by leaving cement on
top of the retainer. When used in conjunction with a cement
retainer, a plug set in this manner does not require
tagging.
For Cemented Cased Hole Intervals
Setting a Balanced Plug. The balanced plug method involves
pumping cement slurry through drill pipe, coiled tubing,
Methods and Technical Considerations (continued)
work string, or production tubing until the level of cement
outside is equal to that inside the drill pipe/tubing
string. The pipe then is pulled slowly from the slurry,
leaving behind the cement plug. To minimize cement
contamination by wellbore fluids, fluid spacers should be
used both ahead of and behind the slurry, especially if the
wellbore fluid is incompatible with the cement slurry. Plug
placement must be verified by tagging the top of the plug
after the cement has had adequate time to set. If a bridge
plug is used at the base of the cement plug, tagging the top
of the plug is not necessary.
Using a Dump Bailer. The dump bailer containing a measured
quantity of cement is lowered into the well on wireline.
The bailer opens upon impact (i.e., striking the bridge
plug, cement retainer, etc.) or by electrical activation.
Typically, the dump bailer method is used for placing cement
on top of mechanical plugs such as a cement retainer or cast
iron bridge plug. Unless used in conjunction with a cement
retainer or bridge plug, plug placement must be verified by
tagging the top of the plug after the cement has had
adequate time to set.
Other Methods:
Special abandonment procedures may be necessary for wells
with unusual surface or downhole conditions. Procedures for such
wellbore conditions are considered beyond the scope of this
document. Operators must address fluid migration potential
Groundwater Program Guidance No. 40 8
associated with the unusual conditions in their plugging programs
and assure that USDWs are protected. If special procedures are
needed, the operator must develop procedures and receive written
approval from EPA prior to initiating the plugging operation.
E. DOCUMENTATION OF WELL ABANDONMENT
All well work records (wellbore clean outs, tubing
movements, casing repair work, plug setting records, pipe
tallies, etc.), procedures used, and rig operation reports should
be documented and maintained by the operator in a permanent well
file, and copies supplied to EPA and other appropriate regulatory
agencies as required. Permits and other authorization documents
also should be preserved in the operator=s permanent file. The
operator that plugged the well should preserve the permanent file
as the operator of record. If the well property is acquired by
another operator, that operator should assume responsibility for
preserving the permanent well file and become the operator of
record. If the operator of record ceases doing business and no
other survivor assumes responsibility for the permanent well
Methods and Technical Considerations (continued)
files, the operator should send the permanent well files to the
appropriate regulatory agency as custodian.
IV. P&A Plans and Financial Responsibility
The P&A plan provided by the operator, when approved by the
EPA, provides a basis on which to determine the amount of
financial responsibility (bonding) required. GROUNDWATER PROGRAM
GUIDANCE NO. 41 discusses Region VIII requirements for financial
responsibility. UIC regulations require that an operator provide
an adequate demonstration of financial responsibility to cover
costs for plugging and abandoning an injection well. The
required financial responsibility reflects the cost that the EPA
would incur if required to plug the well. Failure to provide a
complete P&A Plan and/or failure to establish an acceptable
demonstration of financial responsibility may result in the EPA
denying a UIC permit application or taking enforcement action.
An enforcement action may include civil administrative penalties
of up to $5,000 per day for each violation up to a maximum
penalty of $125,000, or civil judicial penalties of up to $25,000
for each day for each violation. In addition, if the violation
is willful, criminal penalties may be prosecuted in accordance
with Title 18 of the United States Code.
Groundwater Program Guidance No. 40 9
V. Post-Plugging and Abandonment Reporting Requirements
Within sixty (60) days after the plugging and abandonment of
a well, the owner or operator shall submit a Plugging Record (EPA
Form 7520-13) to the Regional Administrator through the Region
VIII UIC Program office at Mail Code 8ENF-T-UIC. The Plugging
Record must be certified as accurate and complete by the person
who performed the plugging operation.
Financial Responsibility previously established with the EPA
by means of a Surety Bond, Trust Fund, or Letter of Credit for
plugging costs may be released to the operator, or may be applied
to update the operator=s financial responsibility coverage.
Enclosures:
Plugging and Abandonment Plan-Form 7520-14
Plugging Record-Form 7520-13
Application to Transfer Permit-Form 7520-7
Well Rework Record-Form 7520-12
Groundwater Program Guidance No. 40 10
