Ariz. Admin. Code § R18-9-J661 - Class VI; Injection Well Construction Requirements

A. The owner or operator must ensure that all Class VI wells are constructed and completed to:

1. Prevent the movement of fluids into or between USDWs or into any unauthorized zones;

2. Permit the use of appropriate testing devices and workover tools; and

3. Permit continuous monitoring of the annulus space between the injection tubing and long string casing.

B. Casing and Cementing of Class VI Wells.

1. Casing and cement or other materials used in the construction of each Class VI well must have sufficient structural strength and be designed for the life of the geologic sequestration project. All well materials must be compatible with fluids with which the materials may be expected to come into contact and must meet or exceed standards developed for such materials by the American Petroleum Institute, ASTM International, or comparable standards acceptable to the Director. The casing and cementing program must be designed to prevent the movement of fluids into or between USDWs. In order to allow the Director to determine and specify casing and cementing requirements, the owner or operator must provide the following information:

a. Depth to the injection zone or zones;

b. Injection pressure, external pressure, internal pressure, and axial loading;

c. Hole size;

d. Size and grade of all casing strings (wall thickness, external diameter, nominal weight, length, joint specification, and construction material);

e. Corrosiveness of the carbon dioxide stream and formation fluids;

f. Down-hole temperatures;

g. Lithology of injection and confining zone or zones;

h. Type or grade of cement and cement additives; and

i. Quantity, chemical composition, and temperature of the carbon dioxide stream.

2. Surface casing must extend through the base of the lowermost USDW and be cemented to the surface through the use of a single or multiple strings of casing and cement.

3. At least one long string casing, using a sufficient number of centralizers, must extend to the injection zone and must be cemented by circulating cement to the surface in one or more stages.

4. Circulation of cement may be accomplished by staging. The Director may approve an alternative method of cementing in cases where the cement cannot be recirculated to the surface, provided the owner or operator can demonstrate by using logs that the cement does not allow fluid movement behind the well bore.

5. Cement and cement additives must be compatible with the carbon dioxide stream and formation fluids and of sufficient quality and quantity to maintain integrity over the design life of the geologic sequestration project. The integrity and location of the cement shall be verified using technology capable of evaluating cement quality radially and identifying the location of channels to ensure that USDWs are not endangered.

C. Tubing and packer.

1. Tubing and packer materials used in the construction of each Class VI well must be compatible with fluids with which the materials may be expected to come into contact and must meet or exceed standards developed for such materials by the American Petroleum Institute, ASTM International, or comparable standards acceptable to the Director.

2. All owners or operators of Class VI wells must inject fluids through tubing with a packer set at a depth opposite a cemented interval at the location approved by the Director.

3. In order for the Director to determine and specify requirements for tubing and packer, the owner or operator must submit the following information:

a. Depth of setting;

b. Characteristics of the carbon dioxide stream (chemical content, corrosiveness, temperature, and density) and formation fluids;

c. Maximum proposed injection pressure;

d. Maximum proposed annular pressure;

e. Proposed injection rate (intermittent or continuous) and volume and/or mass of the carbon dioxide stream;

f. Size of tubing and casing; and

g. Tubing tensile, burst, and collapse strengths.

Notes

Ariz. Admin. Code § R18-9-J661

New Section made by final rulemaking at 28 A.A.R. 1904, effective 9/6/2022.