1. UIC Inspection and Compliance Team
What to Do When Your Well Breaks Down The Workover Process from Loss of Mechanical Integrity to “Back in Service” May 15, 2019
Rich Heitzenrater
UIC Inspection and Compliance Team
TCEQ Region 14
Corpus Christi
(361)

2. What Triggers a Workover
Loss of Mechanical Integrity
Failed Annual Testing
Loss of Injectivity

3. What Constitutes a Workover?
Any changes or repairs to the well that require removal of the wellhead and or deenergizing the annulus system.
Major repairs to the wellhead that prevent annulus differential pressure from being maintained.
Recompletion or Sidetracking of the wellbore.

4. Mechanical Integrity 30 TAC § 331.4 Mechanical Integrity Required
Must have mechanical integrity
Must demonstrate that the well has mechanical integrity
30 TAC § (a) Mechanical Integrity Standards
Casing, Tubing, and Packer
Wellbore
Permittees must demonstrate mechanical integrity to the satisfaction of the Executive Director annually or at any time there is reason to believe the well may lack mechanical integrity.
Mechanical integrity of the casing, tubing, and packer is demonstrated by means of an annulus pressure test.
Mechanical Integrity of the wellbore and surrounding cement is determined through use of a radioactive tracer survey and, once every five years, a differential temperature survey.

5. Loss of Mechanical Integrity
Discovered during annual testing
Failed Annulus Pressure Test
Failed Radioactive Tracer Survey
Discovered during operation
Inability to maintain annulus differential pressure
Notification to TCEQ required within 24 hours

6. Loss of Injectivity
Well cannot inject within permitted pressure limits
Well cannot inject at rates needed by the facility
Well may require recompletion
New perforations or screens
Sidetrack of well for new bottom hole completion

7. Workover Procedures Submitted to Regional Offices
Region 1 (Amarillo)
Region 14 (Corpus Christi)
Must be approved in writing prior to the commencement of work (30 TAC § (i))
May require changes to the UIC permit depending upon work performed.
Procedures are submitted to Region 1 (Amarillo) for wells within TCEQ Region 1 and Region 7.
Procedures are submitted to Region 14 (Corpus Christi) for wells in all other TCEQ Regions.
Generally if the workover involves replacing damaged equipment with identical equipment made of the same materials, a permit Modification or Amendment will not be necessary. If there is significant change to the material or construction of well components, a permit Modification or Amendment will be needed.

8. During the Workover
Any significant changes to the procedures must be approved in writing before being performed.
The TCEQ Regional Office (and TCEQ UIC Permits Section if involved) should be included on daily activity reports.
TCEQ should be given no less than 24 hours notice prior to the post workover mechanical integrity testing so that an investigator may be present.

9. Post Workover MIT Procedures should be approved prior to testing.
What test will be required depends upon the work performed during the workover.
Mechanical integrity testing must be approved in writing before the well can resume injection (30 TAC § (d)(4)(E)).
Preliminary Review
Final Review

10. Well Back In Service
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11. UIC Field Operations Staff Region 14
Rich Heitzenrater
(361)
Elizabeth Murphey
(361)

12. UIC Field Operations Staff Region 1
Timothy Dewbre
(806)

13. Questions ?