For Operators - Idle Well Program

A: Casing pressure test results are submitted via WellSTAR using the ‘Upload Test Results’ form. From the form information page, select the Test Subject of Well and then from the Test Type dropdown, select “Pressure Test – Casing Only.”
Upload Test Result Guide for Operators

Q: What methods may I use to satisfy the casing pressure test requirement?

A: A traditional casing pressure test with liquid may be used to satisfy the casing pressure test requirement. An operator may conduct an inert gas depression test to satisfy the pressure testing requirement with CalGEM’s approval. However, the calculated pressure necessary to depress the fluid column to within 100 feet (MD) above the uppermost perforation, immediately above the casing shoe of the deepest cemented casing, or immediately above the top of the landed liner, whichever is highest, cannot be less than 500 psi. On a case-by-case basis, with CalGEM approval, an alternate mechanical integrity test method may be used to satisfy the pressure testing requirement. These alternate testing methods are required to be approved by CalGEM and to be at least as effective as a casing pressure test in demonstrating mechanical integrity. Examples of alternate testing methods that will be considered on a case-by-case basis include casing wall thickness inspection, employing such methods as magnetic flux, ultrasonic technologies, or a combination of an ultrasonic imaging tool and a cement evaluation log.

Q: What happens if my well fails a pressure test?

A: In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a casing pressure test, the operator must do one of the following:

• Bring the well into compliance;
  
• Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
• Plug and abandon the well in accordance with PRC section 3208; or
• Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.

To make amendments to your approved IWMP or Testing Waiver Plan, contact CalGEMIdleWells@conservation.ca.gov.

Q: What happens if my well fails the clean out tag?

A: In addition to any other penalty or remedial requirement imposed by CalGEM, within 12 months of an idle well failing a clean out tag, the operator must do one of the following:

• Bring the well into compliance;
• Partially plug and abandon the well in accordance with CCR, title 14, section 1752;
• Plug and abandon the well in accordance with PRC section 3208; or
• Schedule the well for plugging and abandonment under an approved IWMP or an approved Testing Waiver Plan.

To make amendments to an approved IWMP or Testing Waiver Plan, contact CalGEMIdleWells@conservation.ca.gov.

Q: Which wells go on the TCWP?

A: The Idle Well Program has compiled a preliminary TCWP Inventory that is available for download in the “Idle Well Inventories” section below. The file is a Microsoft Excel file and may be filtered by operator. The file is formatted to be pasted directly into the TCWP form and only includes wells eligible to be on a TCWP over the six (6) years of the Compliance Period. Each idle well listed includes a yes/no value as to whether it is projected to and required to be scheduled for a casing pressure test, clean out tag, and a 15-year Engineering Analysis over the six (6) year period.

All wells that met the definition of idle well on or before April 1, 2019, are required to come into compliance with the casing pressure test by April 1, 2025. If a well has been an idle well for less than 2 years as of April 1, 2019, then completion of the clean out tag is not required during the compliance period. Once a well has been idle for 8 years a cleanout tag is required. While there is no penalty for conducting a cleanout tag early, a cleanout tag on a well idle for less than 2 years as of April 1, 2019, will not count toward clean out tag benchmarks.

Q: What does the annual review of a TCWP entail?

A: The annual review of each TCWP will be conducted as of April 1 of each year. During the review, CalGEM will confirm that test results have been uploaded to WellSTAR for wells scheduled for testing. This includes, if applicable, confirmation that partial plugging and proper plugging and abandonment of wells has been completed in lieu of testing. CalGEM will document and notify each operator if the operator has met the annual benchmark.

If an operator has complied with the annual benchmarks, the operator will receive a letter documenting compliance and instructions for updating their TCWP for the next year.

If an operator has not complied with the annual benchmarks, in addition to any enforcement action CalGEM may take for failing to comply with the benchmarks, the operator will receive a letter documenting the number of tests the operator failed to complete to comply with their annual benchmarks. Each well that an operator fails to test constitutes a separate violation and is subject to the requirements of CCR, title 14, section 1772.1, subd. (b).

Operators may request an in-person review of the results by emailing CalGEMIdleWells@conservation.ca.gov.

Q: What if I need to change my TCWP?

A: With CalGEM’s approval, changes may be made to the wells scheduled for testing during the year. Please submit a revised TCWP to the Idle Well Program at CalGEMIdleWells@conservation.ca.gov with a narrative of well(s) to be rescheduled on the TCWP and well(s) to be moved to an approved IWMP or Waiver. When submitting a revised TCWP, please take care to ensure that the required number of wells are proposed each year to meet the annual benchmarks. Changes will be reviewed by CalGEM on a case-by-case basis and must be approved by CalGEM.

Q: What if wells idle as of April 1, 2019, are transferred from one operator to another?

Q: What will happen if CalGEM finds a well is not viable to return to operation in the future?

A: If CalGEM determines upon initial review of the engineering analysis that it is not viable to return the well to operation in the future, CalGEM will inform the operator of the basis of that determination. The operator will be allowed at least 30 days to provide additional information to substantiate that the well is viable to return to operation in the future.

If CalGEM determines upon final review of the engineering analysis and any additional information provided by the operator that a well is not viable to return to operation in the future, CalGEM will provide a notice of final determination to the operator. After the final determination, the operator shall either plug and abandon the well in accordance with PRC section 3208 within 12 months of receiving the notice of final determination or schedule the well for plugging and abandonment under an approved Idle Well Management Plan or an approved Testing Waiver Plan.

Q: When is the 15-Year Engineering Analysis due?

A: The 15-Year Engineering Analysis is a one-time submission due by the end of the month in which an idle well has been idle for 15 years.

For wells that as of April 1, 2019, have met the definition of an idle well for 9 years or more, the operator shall provide the Engineering Analysis to CalGEM by the later of the following:

• ​Within sixty (60) days after the date pressure testing on the idle well is scheduled in the operator’s Testing Compliance Work Plan; or
• By the end of the month in which the idle well has been idle for 15 years

Examples:
As of April 1, 2019, the well has been idle for 22 years. The casing pressure test is scheduled in the Compliance Work Plan for 2021. The engineering analysis is due within 60 days of the pressure test. As of April 1, 2019, the well has been idle for 10 years. The casing pressure test is scheduled for 2021, when the well will have been idle for 12 years. The engineering analysis is not due within 60 days of the pressure test; it is due by the end of the month in which the well has been idle for 15 years.​

Q: Do I have to submit an Engineering Analysis for every well idle for 15 years or more?

A: If a well is scheduled for plugging and abandonment on an approved Idle Well Management Plan or Testing Waiver Plan (described in next section), an operator is not required to submit an engineering analysis for the well. By the same account, if an operator plugs and abandons a well in lieu of testing, then a 15-Year Engineering Analysis is not required.

If an operator submits information for a 15-Year Engineering Analysis demonstrated to be applicable to multiple wells in the same field subject to the engineering analysis, the operator may reference the applicable information in subsequent engineering analyses and is not required to submit duplicate information.

Q: How do I submit my 15-Year Engineering Analysis?

Q: What must be included in a proposed TWP?

A: The TWP must include a list of idle wells to be plugged and abandoned, and the following information for each of the wells listed:

• ​The API Number and name of the well;
• The date by which is well is scheduled to be plugged and abandoned; and
• Documentation of any known wellbore integrity deficiencies associated with the well, including an explanation of the deficiency, when it became known, and a description of prior attempts to remediate or abandon the wellbore.
  

Wells on the plan should be prioritized based on the considerations listed in CCR, title 14, section 1772.4.

Q: Does a TWP have to be 8 years in length?

A: No, a TWP may be submitted for any number of years up to 8 (eight). However, in each year of the TWP, at least 10 percent of the idle wells covered by the TWP must be scheduled to be plugged and abandoned. If an operator lists less than eight wells on a plan, CalGEM will reduce the term length to be equal to the number of listed wells to ensure that a minimum of 10 percent of the wells covered by the TWP are plugged and abandoned each year of the plan.

After each year of adherence to a TWP, an operator may add additional wells and additional years to their TWP, provided the addition complies with the requirements of CCR, title 14, section 1772.2, subd. (b).

Q: What happens if I fail to complete my TWP as proposed?

A: If an operator fails to complete plugging and abandonment of any well according to the schedule approved by CalGEM on the TWP, CalGEM may cancel the TWP. If the TWP is cancelled, the exemptions for testing no longer apply for any of the wells listed in the TWP. The operator will be required to comply with testing requirements of CCR, title 14, sections 1772.1 and 1772.1.1 and the 15-Year Engineering Analysis requirements of CCR, title 14, section 1772.1.2. within 90 days of the cancellation. When CalGEM cancels an operator’s TWP, CalGEM will not consider a new TWP from that operator unless the operator is in compliance with all of the requirements of CCR, title 14, sections 1772.1, 1772.1.1, and 1772.1.2. Operators concerned about meeting their TWP commitments should contact CalGEM immediately for assistance in managing obstacles to avoid having their TWP cancelled.

Q: If I have an approved TWP, what is the date each year by which I must complete the plugging and abandonment operations for the listed wells?

A: The annual review date for a TWP is the anniversary of the date CalGEM first approves the operator’s TWP. If an operator adds additional wells or extends the TWP for additional years, the annual review date will remain the anniversary of the date CalGEM first approved the initial TWP submitted by the operator. Each year, a minimum of 10 percent of wells on the TWP must be plugged and abandoned by the annual review date.

The compliance due date for a TWP is the date by which all the wells originally included on the Plan must be plugged and abandoned. This date will be dependent on the length of the TWP and the date CalGEM approves it. Upon approval, each well on the TWP will be given an elimination due date. The elimination due date is the date by which the well on the TWP must be plugged and abandoned. The elimination due date cannot exceed the term of the TWP and cannot exceed 8 years from the date the well was first added to the TWP. During each subsequent renewal of the TWP, newly added wells will receive a unique elimination due date and each existing well will retain its original elimination due date.

Example:
A Testing Waiver Plan is approved on June 1, 2019 to include 50 wells with an 8-year length.

• First annual review date is June 1, 2020, with a minimum of 5 wells plugged and abandoned.
• Compliance due date for all 50 wells to be plugged and abandoned is June 1, 2027.​
  

Q: How do I submit my proposed TWP?

A: A TWP form is available. To request a TWP form, please send a request to CalGEMIdleWells@conservation.ca.gov.

The preferred method to submit the completed TWP form is to send it electronically through WellSTAR using the “Idle Well” form. The completed Excel file may also be returned to CalGEM’s Idle Well Program via email at CalGEMIdleWells@conservation.ca.gov. Paper copies may be mailed to:
Geologic Energy Management Division
Attn: Idle Well Program
715 P Street, MS 1803
Sacramento, CA 95814

​CalGEM will either approve the TWP as submitted or return it to the operator contingent on revision. Potential revisions could include modifications to the length of the TWP, the dual listing of wells on the TWP and either a TCWP or IWMP, and corrections to the number of wells that must be plugged and abandoned to meet the 10 percent benchmark.

Q: What if I need to change my TWP?