Idaho Underground Injection Control Permit (14-ID-c)
Underground Injection Control Permit Process
14-ID-c.1 - Conduct analysis of proposed injection fluids
The developer must be able to communicate details about the proposed injection fluid to enable IDWR to make appropriate recommendations. The minimum data to be collected includes:
- Existing reservoir conditions;
- Proposed method of injection;
- Source of injection fluid;
- Estimates of daily amount of material medium to be injected;
- Zones or formations affected; and
- Analysis of fluid to be injected and of the fluid from the intended zone of injection.
14-ID-c.2 - Application for Geothermal Injection Well (Form 4003-3) and Application for Permit to Construct, Modify or Maintain an Injection Well (Form 42-39-1)
14-ID-c.3 - Review application for completeness
IDWR will review the application to ensure it has all of the necessary information.
14-ID-c.4 - Is the application complete
If the application is incomplete, IDWR will notify the developer. Review of the application does not commence until the application is complete.
14-ID-c.5 - Consider impacts and Advertise 30-day Public Comment Period
IDWR will use the application and any accompanying documentation to consider impacts the injection may have on the geothermal resource as well as other natural resources such as nearby water sources or soil quality.
IDWR then prepares a draft permit and makes it available for a 30-day public review. The public comment provides the public with the opportunity to submit additional information that IDWR may not have had access to in the processing of the original permit application. Historically, IDWR hasn't receive many if any comments; however, on controversial applications comments would be expected. IDWR must respond to all comments prior to issuing the permit. If a high level of public concern or interest is expressed, IDWR will hold a Fact Finding Hearing in the local community to collect more information in a face-to-face format. The Fact Finding Hearing also requires a public notification; to compress timeframes for applications expected to be controversial, IDWR will schedule the Fact Finding Hearing at the same time that the public comment period starts so that the two processes are running concurrently. IDWR considers information gathered during the Fact Finding Hearing and then makes a decision whether to issue or deny the permit.
14-ID-c.6 - Permit to Convert a Geothermal Injection Well
IDWR grants the permit to the developer.
Well Spacing, Casing, and Electric Logging
IDAPA 37.03.04.025.05 requires:
a. Any well drilled for the discovery and production of geothermal resources or as an injection well shall be located more than one hundred (l00) feet from and within the outer boundary of the parcel of land on which the well is situated, or more than one hundred (l00) feet from a public road, street, or highway dedicated prior to the commencement of drilling. This requirement may be modified or waived by the Director upon written request.
b. For several contiguous parcels of land in one or different ownerships that are operated as a single geothermal field, the term outer boundary line means the outer boundary line of the land included in the field. In determining the contiguity of any such parcels of land, no street, road, or alley lying within the lease or field shall be determined to interrupt such contiguity. (7-1-93)
c. The Director shall approve the proposed well spacing programs or prescribe such modifications to the programs as he deems necessary for proper development giving consideration to such factors as, but not limited to, topographic characteristics of the area, hydrologic, geologic, and reservoir characteristics of the area, the number of wells that can be economically drilled to provide the necessary volume of geothermal resources for the intended use, minimizing well interference, unreasonable interference with multiple use of lands, and protection of the environment.
d. Directional Drilling. Where the surface of the parcel of land containing one acre or more is unavailable for drilling, the surface well location may be located upon property which may or may not be contiguous. Such surface well locations shall not be less than twenty five (25) feet from the outer boundary of the parcel on which it is located, nor less than twenty-five (25) feet from an existing street or road. The production or injection interval of the well shall not be less than one hundred (100) feet from the outer boundary of the parcel into which it is drilled. Directional surveys must be filed with the Director for all wells directionally drilled.
IDAPA 37.03.04.025.06 requires:
a. General. All wells shall be cased in such a manner as to protect or minimize damage to the environment, usable groundwaters, geothermal resources, life, health, and property. The permanent well head completion equipment shall be attached to the production casing or to the intermediate casing if production casing does not reach the surface. No permanent well head equipment may be attached to any conductor or surface casing alone. The specification for casing strength shall be determined by the Director on a well-to-well basis. All casing reaching the surface shall provide adequate anchorage for blow out prevention equipment, hole pressure control, and protection for natural resources. Sufficient casing shall be run to reach a depth below all known or reasonably estimated groundwater levels to prevent blow outs or uncontrolled flows. The following casing requirements are general but should be used as guidelines in submitting applications for permit to drill.
b. Conductor Pipe. A minimum of forty (40) feet of conductor pipe shall be installed. The annular space is to be cemented solid to the surface. A twenty-four (24) hour cure period for the grout must be allowed prior to drilling out the shoe unless additives sufficient, as determined by the Director, are used to obtain early strength. An annular blow out preventer shall be installed on all exploratory wells and on development wells when deemed necessary by the Department.
c. Surface Casing. The surface casing hole shall be logged with an induction electrical log or equivalent or gamma-neutron log before running casing. This requirement may be waived by the Director. Permission to waive this requirement must be granted by the Director in writing prior to running surface casing. This casing shall provide for control of formation fluids, protection of shallow usable groundwater, and for adequate anchorage for blow out prevention equipment. All surface casing shall be cemented solid to the surface. A twenty-four (24) hour cure period shall be allowed prior to drilling out the shoe of the surface casing unless additives sufficient, as determined by the Director, are used to obtain early strength.
i. A minimum of two hundred (200) feet of surface casing shall be set in areas where pressures and formations are unknown. In no case may surface casing be set at a depth less than ten percent (10%) of the proposed total depth of the well.
ii. In areas of known high formation pressure, surface casing shall be set at the depth determined by the Director after a study of geologic conditions in the area.
iii. In areas where subsurface geological conditions are variable or unknown, surface casing shall be in accordance with specifications as outlined in a. above. The casing must be seated through a sufficient series of low permeability, competent lithologic units such as claystone, siltstone, basalt, etc., to insure a solid anchor for blow out prevention equipment and to protect usable groundwater from contamination. Additional casing may be required if the first string has not been cemented through a sufficient series of such beds, or a rapidly increasing thermal gradient or formation pressures are encountered.
iv. The temperature of the return drilling mud shall be monitored continuously during the drilling of the surface casing hole. Either a continuous temperature-monitoring device shall be installed and maintained in a working condition or the temperature shall be read manually. In either case, the return temperature shall be entered into the log book for each thirty (30) feet of depth drilled.
v. Blow out prevention equipment capable of shutting in the well during any operation shall be installed on the surface casing and maintained ready for use at all times. BOPE pressure tests shall be performed by the operator for department personnel on all exploratory wells prior to drilling out the shoe of the surface casing. The decision to perform BOPE pressure tests on other types of wells shall be made on a well-to-well basis by the Director. The Director must be notified five (5) days in advance of a scheduled pressure test. Permission to proceed with the test sooner may be given orally by the Director upon request by the operator.
d. Intermediate Casing. Intermediate casing shall be required for protection against anomalous pressure zones, cave-ins, washouts, abnormal temperature zones, uncontrollable lost circulation zones or other drilling hazards. Intermediate casing strings when installed shall be cemented solidly to the surface or to the top of the casing.
e. Production Casing. Production casing may be set above or through the producing or injection zone and cemented either below or just above the objective zones. Sufficient cement shall be used to exclude overlying formation fluids from the geothermal zone, to segregate zones, and to prevent movement of fluids behind the casing into possible fresh groundwater zones. Production casing shall either be cemented solid to the surface or lapped into the intermediate casing if run. If the production casing is lapped into an intermediate string, the casing overlap shall be at least fifty (50) feet, the lap shall be cemented solid, and the lap shall be pressure tested to insure its integrity.
IDAPA 37.03.04.025.07 requires:
All wells except observation wells shall be logged with an induction electrical log or equivalent or gamma-neutron log from the bottom of the hole to the bottom of the conductor pipe. This requirement may be modified or waived by the Director upon written request.
Extensive public comments can stretch the timeline since IDWR must respond to all comments, potentially hold a Fact Finding Hearing, and thoroughly review the input received in these processes prior to making a decision to issue or deny the permit.
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