2017 GasStorageRegulatoryConsiderations Reduce

Underground Gas Storage
Regulatory Considerations
A Guide for State and Federal Regulatory Agencies
States First Gas Storage Workgroup
Disclaimer: This is an informational document, and is not intended to offer recommended rules or
regulations. States First recognizes that management and mitigation of the risks associated with under-
ground natural gas storage are best considered at the state level with specific considerations at local,
regional, or cross-state levels, due to significant variability in local geology and surface conditions (e.g.,
population, building conditions, infrastructure, critical facilities, etc.). Neither the Ground Water Protec-
tion Council, the Interstate Oil and Gas Compact Commission, (collectively the Group) nor any person
acting on their behalf makes any warranty, express or implied; or assumes any legal liability or responsi-
bility for the accuracy, completeness, or any third party’s use or reliance on any information, apparatus,
product, or process disclosed; or represents that its use would not infringe on privately owned rights.
Reference herein to any specific commercial product, process, or service by trade name, trademark,
manufacturer, or otherwise, does not constitute or imply its endorsement, recommendation, or favor by
the Group nor any person acting on its behalf. The views and opinions of individual authors expressed
herein do not necessarily reflect those of the Group.
Recommended citation: Ground Water Protection Council and Interstate Oil and Gas Compact Commis-
sion. Underground Gas Storage Regulatory Considerations : A Guide for State and Federal Regulatory
Agencies . May, 2017. 122 pages.
Table of Contents
Preface.................................................................................................................................................. 1
Executive Summary.............................................................................................................................. 2
Introduction to Underground Gas Storage........................................................................................... 2
Regulatory Framework of Underground Gas Storage (Federal and State)......................................... 2
Risk Management.................................................................................................................................. 3
State Permitting of Underground Gas Storage..................................................................................... 3
Well Drilling, Construction, and Conversion........................................................................................ 3
Well Integrity Testing............................................................................................................................ 3
Reservoir Integrity................................................................................................................................ 4
Injection and Withdrawal Well Operations and Maintenance............................................................. 4
Monitoring and Observation Wells....................................................................................................... 5
Wellhead and Surface Facilities............................................................................................................ 5
Emergency Response Planning............................................................................................................. 5
Temporary Abandonment, Well Closure and Restoration................................................................... 6
Chapter 1: Introduction to Underground Gas Storage.......................................................................7
Chapter 2: Regulatory Framework of Underground Gas Storage (Federal and State)....................10

a. Federal..........................................................................................................................10
b. State.............................................................................................................................. 12
Chapter 3: Risk Management..............................................................................................................13

Introduction...........................................................................................................................................13
Major Issues and Concerns................................................................................................................... 13
Main Take-Aways................................................................................................................................... 13
Risk Management.................................................................................................................................. 14
a. Plan Elements............................................................................................................... 14
b. Identification of Potential Threats and Hazards........................................................ 14
c. Preventive and Mitigative Responses to Threats and Hazards.................................. 15
d. Approval and Certification Requirements.................................................................. 15
e. Updating Plans .............................................................................................................16
Chapter 4: State Permitting of Underground Gas Storage............................................................... 17

Introduction.......................................................................................................................................... 17
Main Take-Aways................................................................................................................................... 18
State Permitting of Underground Gas Storage by Reservoir Type...................................................... 18
a. Geologic Site Characterization General Comments.................................................... 18
b. Engineering Review..................................................................................................... 23
c. Area of Review............................................................................................................. 25
d. Siting and Spacing Considerations.............................................................................. 27
e. Operational Requirements Near Sensitive Areas....................................................... 28
f. Drilling Through Storage Reservoirs by Type............................................................ 28

Chapter 5: Well Drilling, Construction, and Conversion.................................................................... 30
Introduction.......................................................................................................................................... 30
Main Take-Aways.................................................................................................................................. 30
Well Drilling, Construction, and Conversion........................................................................................ 31
a. Goals of Drilling, Cementing and Completion............................................................ 32
b. Drilling Process for Porosity Storage (Depleted and Aquifer Storage Reservoirs)... 32
c. Casing Program Development for Porosity Storage................................................... 32
d. Wellhead Construction for Porosity Storage.............................................................. 33
e. Well Cementing and Evaluation for Porosity Storage................................................ 33
f. Well Completion Methodology for Porosity Storage.................................................. 34
g. Drilling Wells for Bedded and Domal Salt Cavern Storage........................................ 34
h. Casing Program for Bedded and Domal Salt Cavern Storage..................................... 35
i. Wellhead Construction for Bedded and Domal Salt Cavern Storage......................... 35
j. Well Cementing and Evaluation for Bedded and Domal Salt Cavern Storage.............. 36
k. Well Completion Methodology for Bedded and Domal Salt Cavern Storage................ 36
l. Drilling Process for Wells in Hard Rock Cavern Storage............................................ 37
m. Casing Program for Mined-out Cavern Storage.......................................................... 38
n. Wellhead Construction................................................................................................38
o. Well Cementing and Evaluation for Hard Rock Cavern Storage................................ 39
p. Well Completion Methodology for Hard Rock Cavern Storage................................. 39
q. Plugging and Abandonment of Shafts.........................................................................40
Chapter 6: Well Integrity Testing........................................................................................................ 41

Introduction.......................................................................................................................................... 41
Main Take-Aways.................................................................................................................................. 41
Objectives, types and methods of mechanical integrity testing..........................................................41
a. Objectives of Integrity Testing.................................................................................... 41
b. Types of Well Integrity................................................................................................ 42
c. Well Integrity Testing Methods and Technologies..................................................... 43
d. Internal Well Integrity.................................................................................................46
e. External Well Integrity................................................................................................ 48
f. Evaluating Mechanical Integrity Testing.................................................................... 52
Chapter 7: Reservoir Integrity............................................................................................................. 53

Introduction.......................................................................................................................................... 53
Main Take-Aways.................................................................................................................................. 53
Reservoir Integrity................................................................................................................................54
a. Relevance of Reservoir Integrity to Underground Gas Storage................................. 54
b. Guidance from Existing Standards............................................................................. 57
c. Risks and Mitigation Strategies in Underground Facilities....................................... 58
d. Rock Mechanics Aspects of Geologic Storage............................................................. 60
e. Pore Storage Considerations in Depleted Formations............................................... 62
f. Pore Storage Considerations in Aquifers.................................................................... 64
g. Salt Cavern Storage Considerations............................................................................ 66
Chapter 8: Injection and Withdrawal Well Operations and Maintenance....................................... 70
Introduction........................................................................................................................................... 70
Main Take-Aways................................................................................................................................... 70
Well Operation and Maintenance......................................................................................................... 71
a. Long Term Well Integrity............................................................................................. 71
b. Periodic Well Integrity Testing.................................................................................... 72
c. Periodic Wellhead Inspections.................................................................................... 75
d. Periodic Wellsite Inspections...................................................................................... 75
e. Maintenance Requirements and Schedules................................................................ 76
f. Water Wells.................................................................................................................. 76
g. Well Reporting and Compliance.................................................................................. 76
h. Procedures, Training, and Record Retention.............................................................. 77
Chapter 9: Monitoring and Observation Wells.................................................................................. 78

Introduction.......................................................................................................................................... 78
Main Take-Aways................................................................................................................................... 78
Monitoring and Observation Wells....................................................................................................... 78
a. Reasons and Justification............................................................................................. 78
b. Well Construction......................................................................................................... 79
c. Monitoring Type and Frequency................................................................................. 80
d. Reporting Requirements and Alarms......................................................................... 80
e. Observation Well Operations and Maintenance......................................................... 80
Chapter 10: Wellhead and Surface Facilities.................................................................................... 82

Introduction.......................................................................................................................................... 82
Main Take-Aways................................................................................................................................... 82
Surface Facilities................................................................................................................................... 82
a. Overview...................................................................................................................... 82
b. Wellhead...................................................................................................................... 83
c. Pipeline Isolation Valve / Equipment Between Wellhead and
Hand-off to U.S. Department of Transportation Jurisdiction................................ 89
d. Pressure Management/Monitoring............................................................................ 90
e. Surface Leak Detection................................................................................................ 92
Chapter 11: Emergency Response Planning..................................................................................... 98

Introduction.......................................................................................................................................... 98
Main Issues and Concerns.................................................................................................................... 98
Main Take-Aways.................................................................................................................................. 99
Emergency Response Program Organization...................................................................................... 99
a. Purpose and Scope...................................................................................................... 99
b. Leadership, Commitment, and Policy......................................................................... 99
c. Response Team Organization..................................................................................... 99
d. Roles and Responsibilities...........................................................................................100
e. Resources Allocation and Development..................................................................... 100
f. Communication Systems............................................................................................. 100
Emergency Response Planning............................................................................................................ 100
a. Emergency Response Planning................................................................................... 101
b. Emergency Response Planning Implementation....................................................... 101
c. Training and Education............................................................................................... 102
d. Exercises, Program Maintenance, Improvement, and Update.................................... 103
Chapter 12: Temporary Abandonment, Well Closure, and Restoration............................................ 104

Introduction.......................................................................................................................................... 104
Main Take-Aways.................................................................................................................................... 104
Temporary Abandonment, Well Closure, and Restoration.................................................................. 104
a. Safety Considerations.................................................................................................. 104
b. Potential Considerations for Porosity Storage............................................................ 105
(Depleted and Aquifer Storage Reservoirs)
c. Temporary Abandonment Well Considerations for Porosity Storage....................... 105
d. Plugging and Abandonment Well Considerations for Porosity Storage.................... 105
e. Restoration of Site for Porosity Storage Wells........................................................... 106
f. Potential Issues for Salt Cavern Storage Wells........................................................... 106
g. Temporary Abandonment Well Considerations for Salt Cavern Storage.................. 107
h. Plugging and Abandonment Well Considerations for Salt Cavern Storage............... 107
i. Restoration of Salt Cavern Storage Wells................................................................... 108
j. Potential Considerations for Hard Rock Cavern Storage Wells................................. 108
k. Temporary Abandonment Well Considerations for Hard Rock Cavern Storage....... 109
l. Plugging and Abandonment Well Considerations for Hard Rock Cavern Storage..... 109
m. Restoration of Hard Rock Cavern Wells....................................................................... 111
Appendix A: List of References........................................................................................................... 112
Appendix B: List of Acronyms.............................................................................................................. 118

Appendix C: List of Terms.................................................................................................................... 119
Acknowledgements.............................................................................................................................. 121
Underground Gas Storage Regulatory Considerations: A Guide for State & Federal Regulatory Agencies
Preface
Underground storage of gas is a critical element in the U.S. energy supply and distribution system. It plays
an essential role in maintaining the reliability of natural gas supplies and ensuring stable prices for consumers.
The first underground gas storage (UGS)( *Includes underground storage of natural gas and natural
gas liquids unless otherwise noted) operation in the U.S. began in 1916 near Buffalo, New York. Today
there are over 400 active UGS facilities in the U.S., operated by about 120 companies. Over 80 percent of
the U.S. gas storage is in depleted oil or natural gas reservoirs. Most of the remaining storage is in
non-potable aquifers or in salt caverns developed specifically for that purpose, with a few facilities utilizing
mechanically mined caverns.
Most underground storage facilities have safe histories of operation; however, when an accident occurs,
it can have dramatic impacts on public health and safety and the environment. Two of the most serious
occurred at the Moss Bluff storage facility in Texas and the Yaggy storage field in Kansas. The Moss Bluff
facility was a salt cavern storage operation. In August 2004, casing in one of the wells failed, resulting in
a large release of gas and an uncontrolled fire lasting for more than six days. The Yaggy incident involved
a wellbore failure which led to a series of gas explosions in Hutchinson, Kansas. The explosions and fire
damaged 26 businesses and caused two deaths.
Most recently, there was a serious underground leak at the Aliso Canyon gas storage facility near Los
Angeles, California. The leak began in October 2015 and continued for almost four months before it was
controlled. It is characterized as the worst natural gas leak in U.S. history, and resulted in the evacuation
of about 4,000 homes in the area. The incident has focused attention on the regulation of gas storage
operations across the U.S. In response to that concern, states established a Natural Gas Storage Task
Force under the auspices of the States First Initiative.
The States First Initiative is a state led program organized by the Interstate Oil and Gas Compact Com-
mission (IOGCC) and the Ground Water Protection Council (GWPC). Its purpose is to facilitate multi-
state collaboration and innovative regulatory solutions for states involved with oil and natural gas
production and related issues.
This report is the principal work product of the Gas Storage Workgroup of the States First Initiative.
The report was drafted by state regulators, with input and advice from experts in academia, industry,
non-profit organizations, other state and federal agencies, and other interested parties. The report eval-
uates potential vulnerabilities at gas storage operations and identifies prospective regulatory responses
for consideration by state and federal agencies. It is intended to serve as a resource for regulatory agencies,
and not to advocate for specific regulatory actions.
1
Executive Summary
Introduction to UGS
This report addresses underground storage of both natural gas and liquid petroleum gas (LPG). Natural
gas is composed primarily of methane but may have minor amounts of other hydrocarbon gases and other
gases. LPG is a product of gas processing and petroleum refining; it is composed primarily of propane,
butane, and related hydrocarbons that are gaseous at standard temperature and pressure but are stored
and transported in a liquid state under pressure. In this report “gas”, “gas storage”, and UGS refer to both
natural gas and LPG unless the wording or context denotes only natural gas.
The primary purpose of UGS is to provide a buffer between a relatively constant supply and variable de-
mand for natural gas and LPG. UGS allows large supplies of gas to be stored during times of low demand,
and withdrawn from storage when demand for natural gas is high, which reduces the need for larger
transmission pipelines and allows for continuous supply of gas in the event of supply interruptions such as
natural disasters, accidents, or acts of terror.
The need to store large volumes of natural gas to provide a leveling buffer between supply and demand
has been recognized since natural gas transmission pipelines were initially being built in the late 1890s.
Seeing the importance of a reliable supply of natural gas, the U.S. Geological Survey (USGS) recommended
in 1909 that surplus natural gas be stored in underground reservoirs.
The natural gas industry relies on a complex network of transmission and distribution lines to provide
the primary link from producing areas to end users; however, the storage of natural gas is an essential
component of this system and is critical for maintaining its efficiency and reliability. One of the challenges
with using gas is that it is more difficult to stockpile than other fuels, such as coal or oil. To manage this
issue, gas is stored in underground formations that provide for the containment of large volumes of gas
and quick withdrawal to meet the needs of end users.
Regulatory Framework of Underground Gas Storage (Federal and State)

Gas storage is regulated at both the federal and state levels by a combination of regulatory authorities. At
the federal level the principal regulatory authority is the Federal Energy Regulatory Commission (FERC).
However, FERC has a limited role in the actual management of facilities. Primary responsibility for gas
storage facility safety resides with the Pipeline and Hazardous Materials Safety Agency (PHMSA) which
is part of the U.S. Department of Transportation (USDOT). With respect to state regulation of gas storage
there are a number of authorities which play varying roles. For example in most states the oil and gas
regulatory agency has primary authority over permitting, operation, and closure of storage facilities
while public utility commissions exercise authority over gas rates. However, in some states the utility
regulatory authority has a greater role in actual facility functions.
With the adoption of the PHMSA Interim Federal Rule (IFR), the states and the federal government now
may formally share authority over the nation’s 400 plus natural gas storage facilities provided states
apply for and obtain certification from PHMSA to do so.
2
Risk Management
Risk can be defined as the probability of an activity having negative consequences. It is an inherent
property of all human activity. While no activity is “risk free”, there are varying degrees of risk and the
management of risk is a prime component of any gas storage project. The principal purpose of risk
management is to identify, assess and take appropriate risk-reduction measures for threats and hazards
associated with gas storage.
Risk management plans (RMPs) are developed by gas storage operators in anticipation of potential
events. These plans are typically updated on a routine basis and are usually included in the application
for a permit submitted to the state.
State Permitting of Underground Gas Storage

The permitting of gas storage facilities at the state level consists of administrative and technical reviews
of an application submitted by a gas storage operator. The purpose of these reviews is to assure that the
operation of the storage facility will be conducted in a manner that protects the environment and pre-
vents the migration of gas out of the storage zone. The nature of the review depends upon several factors
including the location of the facility, the depth to protected groundwater, the type of storage media (porosity
or cavern), the location and condition of existing wells in the storage project area and the operation spec-
ifications of the particular storage project.
Well Drilling, Construction and Conversion

One of the principal components of any gas storage project is the wells that are used to emplace and
withdraw gas into the storage zone (injection/withdrawal wells) and those that are used to monitor gas
storage operations (monitoring wells). The drilling, construction, and conversion of injection/ with-
drawal wells is typically authorized under the state oil and gas regulatory authority, which requires an
operator to develop wells in a manner that prevents the migration of stored gas out of the storage zone
and is protective of human health and the environment. While the drilling and construction of wells
varies depending upon the type of storage zone to be utilized, in general, this is accomplished through
the application of specific requirements on the operator. These requirements typically include the use of
materials and methods such as the use of specific drilling fluids, use of blow out prevention equipment,
placement of multiple casing strings, cementing of casing using the displacement method, and, where
deemed necessary by the regulatory authority, equipping the well with tubing and packer. For further
information about the use of multiple barriers please see the United States Department of Energy (USDOE)
report. (1) One principal concern is the conversion of existing wells from oil or gas production to gas
storage. Because these wells were not drilled or constructed specifically as gas storage wells, it is im-
portant to evaluate their capabilities for this use and to perform testing and, as needed, remedial con-
struction to assure they can be safely operated in a gas storage regime where the well will be subjected to
pressures and stresses not typically found in oil and gas production.
Well Integrity Testing

After a well has been drilled and constructed in accordance with regulatory requirements it is necessary
to assure that the construction has been accomplished in a way that will prevent migration of gas out of
the gas storage zone. This is called well integrity and is accomplished by subjecting the well to various
tests that demonstrate both internal (casing, tubing and packer) integrity and external (cement) integrity.
The principal test of internal integrity is the Standard Annulus Pressure Test (SAPT). It involves filling the
3
space between the tubing and the casing with a non-compressible fluid, placing the fluid under pressure
for a pre-determined amount of time and evaluating changes in the pressure that might indicate a leak in
the casing, tubing or packer. External mechanical integrity is often demonstrated by running a variety of
tests which can demonstrate the quality of the cement bond between the casing and cement or demon-
strate the lack of fluid or gas movement behind the casing. These tests can include Cement Bond Logs
(CBLs), Temperature Logs, Noise Logs; Radioactive Tracer Surveys (RATs) and others.
The risks associated with performing tests should be considered when determining testing schedules,
and the application or development of tests that require less invasive changes in the well operations
should be encouraged.
Reservoir Integrity
In addition to the integrity of the well, the integrity of the reservoir or gas storage zone is of paramount
importance to the safe operation of a gas storage project. Reservoir integrity refers to the geologic
conditions for safe operation of UGS facilities beyond the wellbore. It is a function of the volume, oper-
ating pressure, and physical conditions of the gas storage reservoir or cavern. Likely risk areas for gas
leakage are breaches of vertical and lateral confinement. An operator should consider the potential
consequences of artificial penetrations of the gas storage reservoir or cavern, faults, fractures, confining
zone/caprock sequence, and stratigraphy.
The integrity of gas storage reservoirs or zones relies primarily upon several factors such as the type of
storage zone (porosity vs. cavern), the geologic framework (confining zones, structural closure, zone com-
petence, pressure variables), and factors such as pressure maintenance, hydrologic conditions and others.
Injection and Withdrawal Well Operations and Maintenance

Gas storage wells and fields require proper operations, practices, and regular maintenance and assess-
ments to ensure integrity and intended use throughout all stages of the facility’s life – from permitting,
start of initial testing, injection, and withdrawal from storage, through final plugging and abandonment.
The operation and maintenance of injection and withdrawal wells is highly dependent upon both the
nature of the gas storage reservoir and the gas being stored. In porosity storage, gas storage wells often
are converted former oil and natural gas producing wells that may be either existing or newly drilled and
completed wells, properly tested to assure these dedicated storage wells will have extended lives. Long-
term well integrity and functionality depend upon proper field and well operations and maintenance,
including changes in the reservoir, fluids, rates, stimulation, remedial, offset, and surface conditions and
parameters.
LPG salt cavern storage wells have significant differences in operation compared to natural gas storage;
with both a brine side and a product side to the operation. These systems should be kept separate for
safety and environmental considerations. Safety equipment, such as gas separators, directed to flares
should be used to handle any LPG that enters the brine system. Gas detectors may also be deployed
around the perimeter of the impoundment as an added safety feature. One should be concerned with the
containment not only of the LPG, but also the brine.
Hard rock cavern storage relies on geomechanical stability that is addressed by the appropriate geome-
chanical analysis techniques. (2) The main issues and concerns with hard rock cavern storage include
roof collapse, pillar collapse and surface subsidence.
4
Monitoring and Observation Wells

Gas storage projects require monitoring to assure that gas is not leaking from the gas storage reservoir
or zone. This is accomplished through both surface and subsurface monitoring systems. With respect to
subsurface systems the principal means of monitoring is through wells that are specifically drilled and
constructed so that they can be used to assess the movement of gas within and outside of the reservoir or
zone. These wells can be utilized to establish baseline conditions and allow for gas, pressure, and liquid
monitoring of conditions and changes. They are typically drilled into formations that have relatively high
permeability and porosity so that the movement of gas within the formation will reach the monitoring
well and provide an early alert that gas has migrated outside of the storage zone. Monitoring or observa-
tion wells being considered for placement directly into the geologic formation(s) utilized for gas storage
can be limited to the buffer zone (which is established outside of the delineated gas storage field) and
can potentially detect additional pathways of gas migration out of the gas storage reservoir within the
storage field. The use of and need for observation wells may be determined as part of the risk assessment
for each new gas storage project.
Wellhead and Surface Facilities

In addition to the wells used to inject and withdraw gas from the storage zone there are a number of
surface facilities related to gas storage operations. This guide deals exclusively with surface facilities
between the well and the first isolation valve beyond the wellhead.
The wellhead is a critical surface facility component. It consists of a series of fittings, valves, and flanges
often referred to as the “christmas tree”. The wellhead is essentially a well control mechanism that can
be used to shut-in the well, to provide access points to the well itself, to be used to monitor well pressure,
and to provide the piping that transports gas into the gathering system.
In addition to well and piping related equipment, gas storage facilities typically utilize equipment
designed to detect surface leaks of gas. This includes systems such as infrared cameras and flame
ionizations gas detectors that can be manually operated or automated. Surface leak detection equipment
is designed to provide the operator with a warning in the event of gas leakage to the atmosphere.
Emergency Response Planning

Unlike risk management planning that is designed to evaluate the potential for failure, emergency
response plans (ERPs) are designed to lay out the actions to be taken should a failure actually occur.
ERPs may be created for foreseeable emergencies such as unintended releases of fluids, unexpected
failure of critical equipment, natural disasters, damage to the facility that impedes facility operations,
hazardous material and other releases, gas leaks from wells and pipelines, fire and explosions, well blow-
outs, emergencies during routine well operations, medical emergencies, or manmade emergencies.
At a minimum, ERPs should be written to include detailed descriptions of the equipment, procedures,
training, equipment testing, roles and responsibilities of all required responders, and supporting plan
execution. ERPs should address internal and external communication protocols, including emergency
contact information and procedures for notification. ERPs should include procedures for all major facility
components, including wells, for all identified emergencies.
5
Temporary Abandonment, Well Closure, and Restoration

As with most human activities there may come a time when the operations of gas storage wells may
need to be suspended temporarily or ceased permanently. The process of temporarily suspending the
operation of gas storage wells is typically referred to as “temporary abandonment”. This process differs
from mere shut down of a well in that it is governed by a regulatory process that includes notifications
to the regulatory agency and in some cases the application of specific physical tests or well management
techniques.
Unlike temporary abandonment, well closure involves changing the status of a well permanently by
either plugging the well or applying other abandonment requirements as appropriate for the type of
storage zone. In the event a well is permanently plugged this is typically accomplished through the
placement of mechanical and/ or cement plugs at pre-defined intervals in the well to assure that gas or
other fluids will not migrate through the plugged well. In some types of storage zones, such as in bedded
salt caverns, wells may sometimes be left unplugged so that they can be used to monitor the conditions
of the cavern over time.
The restoration of a gas storage facility site often includes the removal of surface equipment, grading
of sites, and remediation of the surface to as near pre-storage condition as required by regulatory authorities.
Removal of pipes, wellheads, tanks, gas processing equipment, fluid storage excavations, treatment
equipment and all other surface facilities typically only occurs when the last storage well in the project is
officially abandoned.
6
Chapter 1
Introduction to Underground Gas Storage
The U.S. economy relies upon an uninterrupted supply of energy. This energy is supplied by a variety of
sources such as crude oil, natural gas, wind, solar, nuclear and coal. Over time, natural gas has become a
vital component of the U.S. energy supply, currently comprising 29 percent of the total. In addition, natural
gas is playing an ever-increasing role in meeting the nation’s electricity demands. (3) The demand for
natural gas is spread across numerous sectors of the U.S. economy and natural gas serves as an important
energy source for industrial, commercial, and electrical generation sectors and also plays a vital role in
residential heating.
The key advantages to natural gas keep an energy source are that it is clean burning, cost effective, and
domestically abundant. Compared to other fossil fuels, natural gas is a cleaner-burning fuel with low air
emissions, making it a popular choice for power companies seeking to comply with increasingly strict
air emission standards. Additionally, over 95 percent of the natural gas consumed in the U.S. is produced
domestically, resulting in a low-cost, stable supply that is not dependent on foreign sources that may be
subject to potential instability caused by political stresses.
The natural gas industry relies on a complex network of transmission and distribution lines to provide
the primary link from producing areas to end users. The storage of natural gas is an essential component
of this system and is critical for maintaining its efficiency and reliability. One of the challenges with using
natural gas is that it is more difficult to stockpile than other fuels, such as coal or oil. To manage this
issue, natural gas is stored in underground formations that allow for the containment of large volumes of
natural gas and quick withdrawal to meet the needs of end user.
As demand for natural gas has increased over the years, the importance of underground natural gas
storage to the gas delivery network has increased proportionally. As UGS regulations and demand have
evolved, operations have also changed and have allowed natural gas storage to maintain its essential role
in ensuring the safe and reliable supply of natural gas to the U.S.
The need to store large volumes of natural gas to provide a leveling buffer between supply and demand
has been recognized since natural gas transmission pipelines were initially being built in the late 1890s.
Seeing the importance of a reliable supply of natural gas, the USGS recommended in 1909 that surplus
natural gas be stored in underground reservoirs. (4)
The first underground natural gas storage project was in 1915 in a gas field in Ontario, Canada. The
following year, the first underground natural gas storage project was initiated in the U.S. in a depleted gas
field to serve peak demands for the City of Buffalo, New York. (5) (4) This storage field is still in opera-
tion and is the longest operating underground storage project in the world. (6) As demand for natural
gas continued to grow, there was an associated increase in natural gas storage capacity, and by the 1930s,
there were nine underground natural gas storage projects located across six states. (7) See the under-
ground natural gas storage timeline in Figure 1-1.
7
Erie, NY.
Figure 1-1 Underground Gas Storage Timeline
Until the 1930s, underground natural gas storage in the U.S. had generally been conducted in depleted
gas reservoirs; however, with the U.S.’s continued reliance on natural gas, there was an associated need
for additional storage capacity throughout the nation, which necessitated additional types of gas storage
be used where depleted oil or gas fields were not available. To meet this need, experiments began with
underground natural gas storage in different types of storage structures, including depleted oil and gas
fields and aquifers. Expanding on the use of depleted hydrocarbon reservoirs for gas storage, the first
gas storage project in a depleted oil and gas field was conducted in 1941 in West Virginia and the first
storage in a depleted oil field was completed in 1954 in Texas. Early gas storage projects in oil fields
were initially conducted to enhance oil recovery but the fields were converted to gas storage once the
oil resources were depleted. The presence of oil in the storage reservoirs led to several complications,
including enrichment of the gas and oil condensing out of the gas once it entered the pipeline, along with
difficulties in assessing gas volumes in the reservoir due to large amounts of gas going into solution with
the oil. (13) Since not all regions of the U.S. have adequate depleted oil and gas fields available, natural
gas transmission operators began looking at aquifers as a storage option. The first experiments with gas
storage in water-bearing formations began in 1931 and the first successful storage project in an aquifer
was completed in Kentucky in 1946. (6)
The first usage of a salt cavern for gas storage was in 1961 using an abandoned salt cavern from the
Morton Salt Company. Subsequent salt cavern storage facilities were constructed in salt deposits that had
been mined for their salt for use in the chemical industry. The first salt cavern designed specifically for
use as a gas storage facility was in Saskatchewan, Canada, in 1963, followed by the first “purpose-built”
gas storage salt cavern in the U.S. constructed in Mississippi in 1970. (6)
Additionally, storage has historically been conducted in abandoned mines, although none are currently
in operation in the U.S. The first abandoned mine used for gas storage was conducted in Jefferson County,
Colorado, in an abandoned coal mine. This abandoned mine storage was in operation until 2003 when
the city of Aurora, Colorado, bought the mine for use as a subsurface water reservoir. (8)
8
Over the years, various factors have resulted in a continued increase in the demand for natural gas storage
capacity, which has risen 12 percent between 2000 and 2015. (17) As of December 2015, according
to the U.S. Energy Information Administration (U.S. EIA), the U.S. has 415 active underground natural gas
storage projects, which is more than any other country in the world. (3)
The primary purpose of UGS is to provide a buffer between a relatively constant supply and a variable
demand for gas. UGS allows large supplies of natural gas to be stored during times of low demand, and
withdrawn from storage when demand for natural gas is high, which reduces the need for larger trans-
mission pipelines and allows for continuous supply of gas in the event of supply interruptions such as
natural disaster, accidents, or acts of terror. This helps keep prices relatively stable through seasonal
peaks in demand or other disruptions. Further, in a somewhat recent development, gas storage may be
used by marketers for price hedging.
Underground natural gas storage facilities play an essential role in reliable natural gas delivery and have
been developed to ensure that natural gas is available for delivery to end-users on an as-needed basis. A
lack of adequate gas storage could potentially result in the following:
• Black- or brown-outs during unexpectedly warm summers, resulting in a lack of electric

power for items such as lights, electronics, and air conditioners;
• Lack of natural gas to heat homes in the winter;
• Lack of power generation for commercial and industrial sectors;
• Increased need for larger and more expensive transmission lines to transport the full
volume of natural gas from the point of generation to the end-user; and
• Increased price volatility.
9
Chapter 2
Regulatory Framework of Underground Gas Storage
a. Federal
Until early 2017, federal regulation did not provide operational, safety, or environmental standards for
the subsurface portions of underground natural gas storage facilities (wells, reservoirs, caverns) – the
subject of this guidance document. The Natural Gas Pipeline Safety Act of 1968 has been found by a U.S.
District Court to provide authority to the PHMSA over such facilities, but until 2017 the agency declined
to develop regulations around them, stating in a 1997 Advisory Bulletin that operators should consult
industry guidelines and state regulations on the subject.
Responding in part to the Aliso Canyon incident that began in October, 2015, the U. S. Congress passed
The Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016 (PIPES Act), which
provided in Section 12 that PHMSA would develop safety standards relating to underground natural gas
storage facilities, with a similar jurisdictional power-sharing arrangement with states to that described
below for pipelines (i.e., states could certify with PHMSA to regulate intrastate facilities to PHMSA mini-
mum safety standards plus state requirements that exceed those standards, but for interstate facilities, states
many only certify to inspect such facilities while regulatory authority remains with PHMSA).
In December 2016, PHMSA introduced an Interim Final Rule (IFR) that incorporated two American
Petroleum Institute (API) Recommended Practices (RP) (API RP 1170, “Design and Operation of Solu-
tion-mined Salt Caverns used for Natural Gas Storage,” issued in July 2015 (17), and API RP 1171, “Func-
tional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs,”
issued in September 2015). (16)The IFR requires operators to comply with both the mandatory and
non-mandatory provisions of the RP, with different sections required for new versus existing facilities;
and for non-mandatory requirements, operators may decline to comply with justification to be reviewed by
auditors. The IFR also provides for reporting requirements for facility operators.
The IFR is effective as of January 18, 2017. Operators have one year to comply with the IFR. PHMSA
accepted comments on the IFR until February 17, 2017, but it is not required by law to respond or make
adjustments to the IFR. PHMSA has signaled an intention to revise the gas storage rule over time.
Notwithstanding safety standards for the subsurface portions of gas storage facilities, the federal govern-
ment has had longstanding general authority over gas pipelines and storage fields. FERC has jurisdiction
over any underground natural gas storage project that is owned by an interstate pipeline and integrated
into its system. In addition, independently operated storage project that offer storage services to inter-
state commerce, also fall under FERC’s jurisdiction. FERC, however, has a very limited role when it comes
to the safety aspects of the facilities it regulates, whether such facilities are pipelines, underground storage
reservoirs or caverns, or liquid natural gas import or export developments.
The Federal agency with safety primacy over gas storage and transportation is the USDOT. USDOT is
mandated to provide pipeline safety under Title 49, U.S.C. Chapter 601. PHMSA’s Office of Pipeline Safety
administers the national regulatory program to ensure the safe transportation of natural gas and other
hazardous materials by pipeline. It develops safety regulations and other approaches to risk management
that ensure safety in the design, construction, testing, operation, maintenance, and emergency response
10
of pipeline facilities. Many of the regulations are written as performance standards which set the level of
safety to be attained and allow the pipeline operator to use various technologies to achieve safety.
PHMSA ensures that people and the environment are protected from the risk of pipeline incidents. This
work is shared with state agency partners and others at the federal, state, and local level, as described
below. Section 5(a) of the Natural Gas Pipeline Safety Act of 1968 provides that a state agency may assume
all aspects of the safety program for intrastate facilities by adopting and enforcing the federal standards
upon application to and approval from USDOT; while section 5(b) permits a state agency that does not
qualify under section 5(a) to perform certain inspection and monitoring functions. A state may also act
as USDOT’s agent to inspect interstate facilities within its boundaries; however, USDOT is responsible for
enforcement action. The majority of the states have either 5(a) certifications or 5(b) agreements, while
nine states act as interstate agents. USDOT pipeline standards are published in Parts 190-199 of Title 49
of the Code of Federal Regulations (CFR). Part 192 of 49 CFR specifically addresses natural gas pipeline
safety issues.
Under a Memorandum of Understanding (MOU) on Natural Gas Transportation Facilities dated January
15, 1993 between USDOT and FERC, USDOT has the exclusive authority to promulgate federal safety
standards used in the transportation of natural gas. Project developers should attest that they will
design, install, inspect, test, construct, operate, replace, and maintain the facility for which a certificate
is requested in accordance with federal safety standards and plans for maintenance and inspection.
Alternatively, the applicant must certify that it has been granted a waiver of the requirements of the safe-
ty standards by the USDOT in accordance with section 3(e) of the Natural Gas Pipeline Safety Act. FERC
accepts this certification and does not impose additional safety standards other than the USDOT stan-
dards. If the Commission becomes aware of an existing or potential safety problem, there is a provi-
sion in the Memorandum to promptly alert USDOT. The MOU also provides for referring complaints and
inquiries made by state and local governments and the general public involving safety matters related to
pipeline under the Commission’s jurisdiction.
FERC also participates as a member of USDOT’s Technical Pipeline Safety Standards Committee which
determines if proposed safety regulations are reasonable, feasible, and practicable. The pipeline and
aboveground facilities associated with any FERC jurisdictional must be designed, constructed, operated,
and maintained in accordance with USDOT Minimum Federal Safety Standards in the CFR section 49
CFR Part 192. The regulations are intended to ensure adequate protection for the public and to prevent
natural gas facility accidents and failures. Part 192 specifies material selection and qualification, mini-
mum design requirements, and protection from a variety of diverse threats including internal, external, and
atmospheric corrosion.
In addition to the new requirements set out by the IFR, Part 192 sets out area classifications for gas storage
and a transportation system based on population density in the vicinity of the system and specifies more
rigorous safety requirements for populated areas. The class location unit is an area that extends 220 yards
on either side of the centerline of any continuous one-mile length of pipeline. For storage projects this
pipeline would be the “pipeline header” connecting the storage project to the interstate pipeline grid.
The four area classifications are defined as follows:
• Class 1 Location with 10 or fewer buildings intended for human occupancy;

• Class 2 Location with more than 10 but less than 46 buildings intended for human occupancy;
• Class 3 Location with 46 or more buildings intended for human occupancy or where the
11
pipeline lies within 100 yards of any building, or small well-defined outside area occupied
by 20 or more people on at least 5 days a week for 10 weeks in any 12-month period; and
• Class 4 Location where buildings with four or more stories aboveground are prevalent.
Class locations representing more populated areas require higher safety factors in pipeline design, testing,
and operation. Pipe wall thickness and pipeline design pressures, hydrostatic test pressures, Maximum
Allowable Operating Pressure (MAOP), inspection and testing of welds and frequency of pipeline patrols
and leak surveys must also conform to higher standards in more populated areas. If a subsequent increase
in population density adjacent to the right-of-way indicates a change in class location for the pipeline,
FERC jurisdictional project sponsors would be required to reduce the MAOP or replace the affected segment
of the pipeline header with piping of sufficient grade and wall thickness, if required to comply with USDOT
code of regulations for the new class location.
b. State
States have regulated gas storage facilities since the beginning of the 20th century. Several states have
dedicated regulatory frameworks for gas storage facilities (these are especially common in states with
significant cavern storage capacity), but in the majority of states with oil and gas development, the states’
core well integrity rules (concerning drilling, casing, cementing, and related topics) apply to gas storage
facilities as well. States are increasingly considering the development of stand alone gas storage facility
rules (hence the development of this report).
While many states have imposed their rules on intrastate and interstate facilities alike, a 2010 decision
by the U.S. District Court for the District of Kansas (Colorado Interstate Gas Company v. Wright et.al, U.S.
District Court, District of Kansas, April 13, 2010) found that Kansas’s regulation of interstate facilities
was pre-empted by federal legislation, even though no federal regulation of gas storage facilities existed
at the time. While the decision was limited to Kansas, this court-created regulatory vacuum for interstate
facilities was part of what prompted increased interest in federal regulation that ultimately led to the
PHMSA IFR described in the previous section.
With the adoption of the PHMSA IFR, the states and the federal government now may formally share au-
thority over the nation’s 400 plus gas storage facilities provided states apply for and obtain certification
from PHMSA to do so. For intrastate facilities, states will now be required to adopt the federal standards
but may certify to act as PHMSA’s agent and to impose its own rules that go beyond the federal standard.
For interstate facilities, states may certify to inspect such facilities to PHMSA standards but may not
conduct enforcement activities nor impose any additional rules on those facilities. These certification
processes have not been developed as of this report’s publication date.
12
Chapter 3
Risk Management
Introduction
Risk management is an imperative aspect of operating a gas storage project. A risk management plan
(RMP)identifies all potential threats and hazards to well and reservoir integrity, as well as to human
health, safety, property, natural resources, and the environment. The plan considers all phases of a gas
storage project including, but not necessarily limited to, well drilling and rework, completion, injection
and withdrawal operations, safety systems, well integrity testing, geological and other hazards, and
monitoring. Risk management is conducted regardless of any statutory or regulatory requirement. Risk
management addresses both generically-conceived potential risks and site-specific risks. Site- and project-
specific planning enables development of risk control and response measures that are appropriate to each
facility.
Risk management is a dynamic and ongoing process. Risk assessments and plans are reviewed and
updated as necessary as changes occur or at a default frequency, or as determined by regulation.
Risk management may include the reasonable tolerance of risk. Risk cannot be completely eliminated.
Regulatory authorities may determine or approve levels or types of acceptable risk. Acceptable risk
refers to the level of human, property or environmental impact that can be tolerated by individuals, com-
panies, regulators, communities or governments and one for which no mitigation or other risk-reduction
effort is made. Acceptable levels or types of risk likely will vary from facility to facility, dependent on
state (e.g., specific laws and regulations), proximity of nearby populations, facilities and infrastructure,
ecosystems etc., and the reasonably modeled events that might occur if an acceptable risk evolves into an
occurrence (event).
Major Issues and Concerns

Risk management is an important element in the operations of storage projects. The major issues and
concerns for risk management include:
• Potential threats and hazards to human health, safety, and the environment;
• Assessment and appropriate ranking of potential threats and hazards to human health,
safety, and the environment;
• Potential threats and hazards to a storage facility that can affect well and reservoir
integrity and performance;
• Preventive and mitigating (P&M) measures to monitor and/or reduce risk; and
• Contingency provisions (e.g., emergency response plans (ERPs); see Chapter 11 of this
document) to guide the response to unplanned or emergency events.
Main Take-Aways
• Risk management is undertaken to identify, assess and make appropriate risk-reduction
measures for threats and hazards associated with gas storage.
• Risk management is a dynamic, ongoing process that requires periodic updates to the plans.
13
Risk Management
a. Plan Elements
Risk management has many elements. Many of these elements are discussed in later sections of this
guidance and only briefly discussed in this chapter. Elements of gas storage risk management include:
i. Well work such as drilling, completion, workover, and conversion;
ii. Geological characterization of the storage reservoir or salt body;
iii. Well and reservoir integrity monitoring;
iv. Critical above-ground systems; and
v. Monitoring and observation wells.
Risk management should be considered during well and reservoir planning, construction, modification
and maintenance. Gas storage operators should consider these factors in combination with local geo-
logical characteristics, the type of storage operation contemplated, and gas product(s) to be stored. Risk
management and mitigation may affect selection, monitoring, and repair/replacement of casing, tubing,
packers, various downhole equipment, and also wellhead components. Maintaining well integrity and
other aspects of a storage facility is the goal of risk management.
Conversion of existing depleted oil and gas wells that were designed for the production of oil and natural
gas is the most common type of development for gas storage facilities. Prior to converting an existing oil
and gas well for use in gas storage, operators should conduct a series of tests to verify both internal and
external mechanical integrity of a well.
Gas storage operations should never be conducted at pressures exceeding either the as-new design
parameters (e.g., strengths) of a well or the strengths as conservatively recalculated following a thorough
evaluation of a well’s current condition (e.g. corrosion or degradation of casing; modern evaluation of
cement outside pipe; etc.). Risk management includes both continuous and periodic monitoring of pressures,
casing thicknesses, and other properties within wells and above ground conveyance and processing
equipment. It also includes installation, maintenance, and testing of safety systems. Relevant safety
systems include both monitoring systems such as Supervisory Control and Data Acquisition system
(SCADA) and mechanical or other systems that may physically prevent a fluid or gas pathway.
b. Identification of Potential Threats and Hazards
Identifying and understanding threats and hazards to gas storage operations is requisite to determining
and prioritizing risks and mitigative measures. (10) API RP 1171 lists common threats and hazards for
safe storage of gas in reservoirs. API RP 1171 groups risks along themes of well integrity, design, opera-
tion, maintenance activities, well intervention, third party damage, outside forces/natural causes, geologic
uncertainty, and reservoir fluid incompatibility. (10) Table 1 in API RP 1171 separates these risks into
categories to account for threats to storage wells, reservoirs, and surface facilities. (10)
14
Risk assessment can be performed in various ways. Gas storage operators should utilize an appropriate
risk assessment method to “identify potential threats and hazards to a storage facility; evaluate likelihood
of events and consequences related to the events; determine risk ranking to develop preventive and
mitigating measures to monitor and/or reduce risk; document risk evaluation and decision basis for
P&M measures; provide for data feedback and validation; and review and update risk assessments to
update information and evaluate risk management effectiveness.” (10) P&M measures may not be
necessary for all identifiable risks and threats. (2)
The IOGCC document on storage in hard rock caverns lists various factors that should be included in a
Process Hazard Analysis (PHA) for storage in hard rock caverns. The document also recommends that
personnel performing a PHA for gas storage have engineering and cavern operation experience and
knowledge of the specific PHA being utilized. (2) Identification of threats or hazards to salt cavern stor-
age operations should consider general safety, potential loss of product, subsidence effects, and possible
environmental impacts with specific regard to potential interactions with abandoned wells within ¼ mile
of the cavern or the potential impact on other mining operations in the area. (11)
c. Preventive and Mitigative Responses to Threats and Hazards
API RP 1171 defines preventive measures for reservoir storage as those actions reducing the likelihood
of risks to storage facilities and mitigative measures for reservoir storage as those actions reducing the
consequences of threats to storage facilities. (10) Some examples of these actions are delineated in Table
2 in API RP 1171 by categories such as wells, reservoir, or surface, and the potential threats and mitiga-
tive or preventive measures commonly employed by storage operators. (10)
Some practices should be implemented regardless of storage medium. These practices include regular
inspections and testing of instrumentation, valves, pumps, emergency equipment, control systems, shut-
down valves, wellheads, and associated pressure monitoring systems. (2) Additionally, caverns, whether
in hard rock or salt, and well casings should be tested prior to starting storage operations and regularly
after that by an approved method. (2) Subsidence is a risk of cavern storage and such gas storage should
include a program to monitor for subsidence. (2) Appropriate security should be in place at any gas storage
facility with additional safety and security measures typically necessary during extensive well work. (2)
Cavern gas storage operators should consider the potential for each subsurface activity to adversely
impact cavern and facility integrity. (2) Such impacts may include potential loss of product, subsidence
effects, and possible environmental impacts with specificity concerning the potential for interaction with
activity, current or future, which could have a significant impact on the water table level and allow for
gas migration, or other aspects of safe and prudent operation. (2) Wells with long design lives should
be constructed to monitor groundwater depth and/or chemistry in the vicinity of storage cavern(s). (2)
Cavern storage facilities should be equipped with fail-safe devices which automatically operate in the
event of an unauthorized or unsafe condition or status of the facility or in case of other emergency. (2)
d. Approval and Certification Requirements
Gas storage operators should appoint a multi-disciplinary evaluation team, with engineering and geo-
logical expertise to institute and conduct reviews of RMPs. (2) Prior to approving or certifying RMPs,
regulators may consider using As Low as Reasonably Practical (ALARP) principles in their review of the
plans to establish an acceptable level of risk. ALARP is similar to a cost benefit analysis, but takes other
components into consideration. (12) ALARP establishes an area for the storage operator to work within
different risk thresholds. The thresholds consist of an upper limit that is intolerable and a lower limit
15
that is broadly acceptable. At some point, the money spent by the storage operator to mitigate a risk may
be grossly disproportionate to the associated reduction in risk or the risk has been reduced below the
lower threshold where it is classified as broadly acceptable. (12) Regulators should assess whether further
mitigation steps justify the costs which will be passed onto the users, and operators must evaluate the
conditions surrounding their storage project to react as necessary to keep risk at an acceptable level. (12)
e. Updating Plans
Risk management is an ongoing and dynamic process. Risk assessment and management should be
periodically (and additionally as prudent) reviewed and updated process. (10) Operators of cavern gas
storage should use a team with appropriate expertise to write and review/update risk assessments and
RMPs to verify they correspond to current conditions. (2) The functional integrity of storage operation
is the underlying purpose of risk monitoring and management and should include continual review and
improvement cycles in risk management activities. (10) Reviews of RMPs should be performed on a
basis that is short enough to account for recent changes but long enough to provide useful data to storage
operators. (10)
16
Chapter 4
State Permitting of Underground Gas Storage
Introduction
The permitting of gas storage facilities at the state level consists of administrative and technical reviews
of an application submitted by a gas storage operator. The purpose of these reviews is to assure that the
construction and operation of the storage facility will be conducted in a manner that protects the envi-
ronment and prevents the migration of gas out of the storage zone. The nature of the review depends
upon several factors, including the location of the facility, the depth to protected groundwater, the type
of storage media (porosity or cavern), the location and condition of existing wells in the storage project
area and the operation specifications of the particular storage project.

The main technical goals of the UGS permitting process are two-fold. First, the applicant must demon-
strate that the proposed storage zone, whether a depleted reservoir, aquifer, or salt cavern has the
geological and geomechanical properties that render it suitable for secure gas storage over the life of the
facility. Gas storage must be confined to the defined storage reservoir or cavern. Second, the applicant
must demonstrate the storage operations will not endanger groundwater resources, public safety, human
health, or the environment. Groundwater protection is accomplished by both selecting a suitable storage
zone and also via suitable well design, construction, and subsequent facility operation. While the oper-
ator of a proposed gas storage project should perform initial site screening on its own and only propose
what it views as suitable projects to the regulatory authority, the permitting process is the best opportu-
nity for the regulatory authority to eliminate what it views as any unsuitable storage proposals or com-
ponents of a proposal. The regulator’s application review efforts should ensure that any storage project
is properly sited and designed to be protective of public safety, natural resources, human health, and the
environment.
The nature of gas storage, in any setting, will place large volumes of gas in underground formations.
Ensuring this pressurized gas, stored in formations or caverns, does not have avenues for migration is the
focus of effective permit application review.
The construction of new gas storage fields is a major capital investment for any company, and will involve
many levels of study and review to determine if the site is appropriate for UGS. It is in an applicant’s
interest to have as much information as possible about a location for a storage field before ultimately
pursuing a permit to operate the storage field. Permitting of federally regulated, interstate natural gas
facilities will have a mandated permitting process regulated by FERC before receiving any required FERC
certificate. Features of the FERC application process will be useful to the state regulator in considering its
permit requirements.
The permitting of intrastate facilities, which are not regulated by FERC, will most likely have more bur-
den of oversight placed on the state regulators. Many elements of a FERC approved facility should also be
considered in state permitting. An equivalent of protection should be maintained in intrastate facilities
as in federally regulated interstate facilities.
17
Main Take-Aways
• The regulatory review of a permit application for gas storage should focus on evaluating
the geological and geomechanical properties of the proposed location, proposed well
construction, previous oil or gas activity in the surrounding vicinity, and the ability of the
project to be protective of public safety, natural resources, human health and the environment.
• While the main reservoirs used for UGS are either porous media or caverns, the focus of
the regulatory review remains the same.
• On-site inspections by regulators are a vital part of the permitting review process.
Inspections allow for the verification of all reported and expected site conditions.
• The three main portions of a technical permitting review are focused on geologic review,
engineering controls, and the AOR.
State Permitting of Underground Gas Storage by Reservoir Type

a. Geologic Site Characterization General Comments
Geologic site characterization should be required prior to the development or expansion of an under-
ground storage facility. This assessment should be done in conjunction with and coordinated with engi-
neering studies. For existing facilities, the site assessment should be periodically updated during the life
of the project as new data becomes available or if there are operational or geologic risk concerns.
The site characterization provides the basis for a practical understanding of the site-specific geology
using maps and cross-sections constructed from available data such as well logs, cores, geophysical sur-
veys, and historical records. The analysis of these data provides the geologic basis for feasibility, design,
permitting, construction, optimization, and management of a storage asset. It also provides the basis to
delineate and recognize geologic features that could potentially compromise the integrity of or be prob-
lematic for storage operations.
Creating space, storing and cycling product underground in geologic formations (salt caverns or porous
media) creates a potentially dynamic situation in the rock mass that will be altered (i.e. stress, pressure,
fluid contacts, etc.) from pre-storage conditions. The extent and impact of these changes need to
be understood for the prudent design and operation of storage facilities as these altered conditions can
impact technical feasibility, permitting, operations, and assessment of the geologic risk.
The ability to understand the geology in the subsurface will depend upon the availability, quality, quantity,
distribution and type of data available. One aspect of a site characterization is to identify data gaps and
make recommendations on where additional information is required. This may require the acquisition
of additional data such as core data and testing, additional test wells, and well testing or geophysical
surveys, depending upon the type of information required. Uncertainty in the geologic model can equate
to some level of geologic risk. There will always be an element of geologic risk associated with subsurface
work because of the inability to resolve, characterize, or have sufficient understanding of all of the
details of the real world geology and potential risk features associated with a particular site. Therefore,
an operator should continue to acquire, study, and maintain subsurface data throughout the life of a storage
project. Maintaining and updating the geologic database and level of geologic understanding during the
lifetime of a facility will allow for improved geologic risk management and mitigation capability.
Geologic maps are not the end product but are generated to provide the basis to analyze and communicate
subsurface geologic information. It should also be noted that the geologic maps are an interpretation,
18
not necessarily the entire answer. The localized geologic interpretation should be consistent with and fit
within the context of the surrounding sub regional geologic setting. It should also be consistent with not
only the geologic data but also with observations from engineering data, well tests, and operational per-
formance of the wells within the field. The interpretation should be updated and refined during the life of
the storage asset as new information becomes available.
Additional information regarding geologic site characterization for underground storage can be found
in API RP 1170 and API RP 1171. While these documents were written specifically for gas storage in
salt and porous media respectively, the concepts regarding geologic characterization can be applied to
underground storage in general. Additional information can be found in API RP 1114 E2 regarding liquid
product storage caverns. (13)
i. Geologic Site Characterization for Porous Media
Gas can be stored in depleted oil and gas fields and aquifers. Although the focus may vary, the geologic
methodology is basically the same for gas storage in depleted oil and gas fields and aquifers except that
depleted oil and gas fields have demonstrated that they can trap gas of a specific volume over a period of
time and they are generally associated with more well data and have a production history. New aquifer
storage fields are potentially less well understood and may require more extensive exploration programs
and testing prior to the beginning of storage operations to develop sufficient understanding to demon-
strate that they are suitable candidates to store gas.
It should be noted that every reservoir site is geologically unique depending upon local stratigraphy,
reservoir properties, depositional environment and deformational history. The geologic assessment of an
underground storage field in porous media differs from that typically performed for oil and gas devel-
opment in two fundamental ways. First, the reservoir and its sealing capabilities may have been altered
by compaction or damage created by previous fluid extraction (hydrocarbons and formation water) due
to grain repacking of partially fluid-supported sediments, altered pressure conditions, or migrating fluid
contacts. Second, cycling gas in a porous reservoir creates a dynamic system involving pressure differen-
tials and multi-phase fluid interactions that will often be in flux depending upon how and how often the
reservoir is cycled. It is important that reservoir boundaries and potential migration paths are identified
and product containment is demonstrated under the proposed operating conditions of the storage facil-
ity. The potential impact of such changes should be addressed by geologic, geomechanical and reservoir
engineering assessments.
The objective of the site characterization is to evaluate the geologic setting to determine if a specified
volume of gas can be safely contained in a predetermined location, sufficiently isolated from the Under-
ground Source of Drinking Water (USDW) or other protected groundwater, and be cycled and recover-
able in an economic and prudent fashion.
The geologic site evaluation of a porous reservoir should include but is not limited to an analysis of the
following:
ii. Field geometry – areal extent (lateral boundaries), size, structural configuration
1. Reservoir characteristics – lithology, porosity, permeability, capillary pressure,

pore throat size, thickness, depositional environment, reservoir /salt anisotropy
and heterogeneity, effective vs. non-effective reservoir, faulting, reservoir
19
compartmentalization, current and historical fluid contacts, geomechanical

properties, fluid saturation, discovery pressure for depleted field, and others;
2. Type and strength of reservoir drive (water drive, depletion drive, etc.);
3. Top seal/caprock – thickness, lithology, geomechanical strength properties,
permeability, porosity, capillary pressure, and others;
4. Trapping mechanisms – top seal/caprock, structural closure, faulting, stratigraphic
pinchout, gas/hydrocarbon/water contacts, spill points;
5. Base of USDW or other protected groundwater - isolation distance and permeability/
porosity of intervening rock;
6. Hydrocarbon production or injection wells – maintain sufficient isolation from
existing hydrocarbon production, and injection wells, including disposal wells;
7. Potential geologic risk elements (see Chapters 8 and 9 – for more detail) include
but are not limited to:
a) migration pathways to the surface via faults or boreholes;
b) juxtaposition or potential connection of storage reservoir with other
permeable units via scouring, faulting, unconformities and stray sand
development, etc.;
c) fault compartmentalization;
d) spill points;
e) delta pressuring;
f) compromised caprock/top seal; and
g) interference with injection or hydrocarbon production;
8. Proximity to sensitive areas: Design for the protection of public safety, human
health and the environment is of paramount importance during the storage field
design process. This includes a review of safeguards to surrounding culture, sur
face water and groundwaters. The operator may also perform an environmental
impact survey prior to commencing any drilling or facility construction. (10)
9. Setback requirements (10): Operators are encouraged to work with applicable
land use authorities and landowners to ensure proper setbacks from the facility
are applied;
iii. Siting and spacing considerations:
1. Geologic reservoir features

a) Porosity of formation;
b) Permeability of formation;
c) Depth of formation: A minimum depth is required. It may be hard to de-
fine an exact depth, but sufficient depth to ensure the zone is isolated and
will not interact with surface features or people;
d) Confining zone: Formation must have impervious rock;
e) Lateral confinement: The storage horizon must have laterally containing
features. Typically, they can be structural geologic features or other types
of geological barriers that provide traps, pinch outs, adjoining salt dome
deformation, igneous intrusions or others;
f) Define a buffer zone that reflects the geologic uncertainty of the particular
field and risk;
g) Existing wells in depleted reservoir: Existing production wells in a potential
storage field may be candidates for conversion to storage if their design
and completion methods meet the storage standards. All existing
production wells to be converted to storage should be thoroughly inspected
20
for well integrity, including downhole casing inspection logs, and pressure
tested to confirm suitability for storage service. Any well that does not
meet the storage standards should be either reworked to meet those stan
dards or plugged and abandoned; and;
h) Existing boreholes can be used as storage wells providing they meet regu-
latory requirements; and
iv. Operational requirements near sensitive areas:
1. The storage field design can include plans to monitor conditions as they pertain to
well drilling and storage development for protecting the environment and health
and safety of workers and the public. This includes the development of site-specific
plans for known problems like geological and other potential hazards. (10)
2. Site specific requirements include (10):
a) Installation of protective equipment for site security and safety;
b) Development of storage well blowout contingency plans; and
c) Liaison with all pertinent local emergency personnel; and
d) Operators may also consider more frequent inspections or using leak
detectors, downhole shut-off valves, or other safety devices in areas near
populations or gathering spaces, or as determined by the site-specific risk
assessment.
v. Geologic Site Characterization for Solution Mined Salt Cavern Storage
Both liquid and gaseous products can be stored in solution mined salt caverns in bedded, deformed or
domal salt deposits. Gaseous products are also stored in mined salt caverns in bedded salt formations.
Bedded salts are relatively undeformed salt deposits where the internal bedding is still largely preserved
undisturbed. Domal salt generally has flowed several thousand feet vertically breaching the overlying
strata. The internal bedding is often largely broken down into rafted blocks or stringers that parallel the
flow banding. Hence, the geologic concerns for bedded salt differ somewhat from domal salt. Depending
upon the amount and type of deformation, deformed salt will have various degrees of salt flow and pre-
served bedding.
Like porous media reservoirs it is important to evaluate salt cavern storage fields with regard to distance
and isolation from USDW or other protected groundwater, existing or planned subsurface activity (wells,
mines, other salt caverns, etc.) and reservoir quality (geomechanical properties and impurity content of
the salt). For domal and highly deformed salts, a geologic assessment becomes more focused on resolving
structural complexity, precisely identifying the edge of salt and resolving potentially problematic internal
features such as anomalous zones, shear zones and faulting. It is important to remember that domal and
deformed salt are potentially active geologic features whose current configuration and internal material
properties are determined by initial stratigraphy, deformational history, dissolution, etc. Therefore, salt
movement and dissolution can pose risk factors for drilling, well integrity and cavern integrity.
In most cases, as salt is the sealing media, there is no trapping mechanism other than the salt itself.
Therefore, it is critical to demonstrate that there is sufficient good quality salt to develop the storage
caverns, no geologic or man-made features that may provide potential weak zones or migrations paths,
and that sufficient buffer exists from the edge of salt and the cavern, both laterally and vertically above
and below the cavern. When assessing the distance to the edge of the salt, it is important to consider the
density and definitiveness of the available data and the potential for salt quality to degrade towards the
edge. Sufficient salt as determined by engineering studies should be maintained above the cavern to help
support the overburden and caprock (if present) over the cavern roof.
21
Salt caverns are generally constructed in rock salt primarily composed of halite. The strength and creep
properties of rock salt are influenced by its deformational history and impurity content.
Impurities and structurally stressed salt are generally considered to be anomalous and potentially
problematic for salt cavern development. The presence of highly creep-prone or soluble salts such as
Potassium-Magnesium potash salts can create the potential for irregular cavern geometries and high
creep closure rates. High non-salt impurity content can lead to solution mining issues, and increased
potential for roof falls. Sheared and faulted salt (often containing brine, gas or liquid hydrocarbons) can
indicate differential salt movement, weak salt or porous salt that can impact cavern operations, and well
and cavern integrity, or can contaminate the stored product.
In the case of bedded salts, the focus, geologically, is more on internal stratigraphy as the distribution of
dirty (impure) salt or non-salt interbeds laterally and vertically will potentially limit the space for cavern
development in good (pure) salt. Interbeds and dirty salt may be potentially problematic with regard to
roof falls, or casing integrity, and they can create potential for irregular cavern shape and provide zones
of potentially weak or permeable rock. The distribution, thickness, strength properties, fluid compatibil-
ity, and permeability of non-salt interbeds should be investigated. The contacts between non-salt inter-
beds and the salt can be planes of weakness and can result in unanticipated roof falls.
Differential salt movement between different salt spines, along faults or at the salt/country rock interface
can be particularly problematic for well or cavern integrity.
The geologic site evaluation of salt caverns should include, but not be limited to, an analysis of the following:
1. Salt body geometry – areal extent and edge of salt, thickness, structural configuration;
2. Salt quality – salt quality, thickness, geomechanical properties, impurity content (lithology,
amount, distribution), non-salt interbeds, anisotropy and heterogeneity, weak zones,
highly soluble zones, creep prone zones, porous salt, and others;
3. Interbeds - mostly bedded salts and non-gulf coast domal or deformed salt structures.
May be rafted apart where salt flow has occurred;
4. Caprock thickness and lithology (domal salt);
5. Base of USDW or other protected groundwater, - isolation distance and permeability/
porosity of intervening rock;
6. Zones of active water flow or salt dissolution; and
7. Potential geologic risk elements, which may include but are not limited to:
a) Too close to edge of salt, edge of dome, stratigraphic pinchout, bounding faults,
dissolution fronts, non-deposition;
b) Differential salt movement, shear zones and faults within the salt (boundary
shear zones and edge zones);
c) Migration pathways to edge of salt via faults, boundary shear zones, weak salt,
permeable salt;
d) Proximity to existing salt caverns (thin salt pillar), mines or wells drilled into salt; and
e) Caprock faulting and lost circulation zones – pose drilling risk and can compromise
integrity of well casing and cementation.
vi. Geologic Site Characterization for Mined Cavern Storage
Liquid hydrocarbons and LPG may be stored in conventionally mined caverns in undeformed, imper-
meable non-porous rock such as hard shales, carbonates and crystalline igneous or metamorphic rock.
22
While abandoned mines have been used to store liquid product, it is generally accepted that purpose
built mined caverns are less problematic and the better option. Natural gas storage is technically feasible
in mined caverns; however, the increased mobility of natural gas would require some type of lining of the
cavern walls to insure containment.
Like aquifer storage, mined caverns are generally located in areas of sparse well density and subsurface
geologic data. Initial exploration can be done with core wells, hydrogeologic well testing and geophysical
surveys. Unlike other types of storage projects, detailed information for mined caverns will be obtained
during the construction of the cavern. This will include but not be limited to lithologic analysis, geo-
mechanical testing, mapping the distribution and characteristics of fractures and faults, locating water
seeps, etc. This geologic information should be used during construction to update the geologic model
and modify the initial design as required.
The geologic site evaluation of mined caverns should include but not be limited to an analysis of the
following:
1. Geometry of geologic formation of the cavern interval and surrounding rock: - thickness,
areal extent, structural configuration, etc.
2. Lithology, rock matrix impermeability, petrophysical properties and strength properties
of cavern interval and surrounding rock: - needed to demonstrate containment and struc-
tural integrity. The rock formation must be sufficiently impermeable to contain stored
product while also stable enough to withstand the mining process and pressures associated
with input and withdrawal cycles.
3. Distribution and characteristics of fractures and joint systems are critical: - possible product
migration pathway and weak areas for cavern stability. These also may be a safety
element during construction for possible rock falls during construction.
4. Isolation from USDW or other protected groundwater.
5. Seal (above and below): thickness, areal extent, structural configuration, lithology,
impermeability.
6. Hydrogeological characteristics and distribution of hydraulic potential above, around, and
below the cavern.
Potential geologic risks can include:

1. Migration of product through shaft, sump, boreholes, faults, voids, or through surrounding
formation (i.e., more permeable, fractured, or zones with lower hydraulic potential, etc.).
2. Sinkhole formation
Long term monitoring of the hydraulic potential with monitoring wells is recommended
since hydrogeological containment is a dynamic situation. Also injection wells may be
needed to generate pressure curtains so that any fluid migration is in toward the cavern
instead of out of the cavern.
b. Engineering Review
In addition to a geologic understanding of the proposed storage reservoir, the impact of installing and
operating wells or caverns within the reservoir must also be considered. A detailed discussion of well
drilling and operation can be found in Chapters 5 and 8, respectively. General topics to consider when
evaluating a storage project from an engineering perspective follow:
23
i. Engineering Considerations for Porous Media
1. Engineering analyses including: (10)

a) An examination of well records to determine which current wells and
abandoned wells have penetrated the formation (See Section c. of this
chapter for more information on AOR);
b) A review of the wellbore mechanical integrity for suitability for the
intended design and operation of the well and protection of the reservoir’s
integrity. This review applies to both new wells and existing wells that are
proposed to be converted to storage service. This should include a review
of the following:
1) Casing materials;
2) Casing configuration;
3) Set depths;
4) Cement;
5) Placement depths;
6) Completion records; and
7) Geologic setting.
2. An analysis of abandoned and plugged wells to verify effectiveness of plugging
methods and materials used as well as the placement of any plugs to prevent
migration.
3. An analysis of the chemistry of reservoir fluids to determine characteristics and
potential impacts on storage well drilling, completion and stimulation, and
storage operations.
ii. Engineering Considerations for Solution Mined Caverns
When evaluating a salt formation for development of solution mined caverns, in addition to the issues
discussed previously in the Engineering Considerations for Porous Media, the following issues specific to
solution mined caverns should be considered:
1. The placement of the cavern from the edge of the salt

2. Faulting within the salt formation
3. Spacing between storage caverns
4. The proposed size and shape of the cavern, particularly as it relates to cavern
stability
5. The maximum and minimum storage pressure within the cavern, with special
attention to the fracture gradient of the salt and the minimum pressure needed to
minimize salt creep
iii. Engineering Considerations for Mined Caverns
Development of a mined cavern will begin with a main shaft or well. The main shaft is large diameter and
used for moving equipment and people into the cavern to begin the mining process. (14) This main entry
point and some additional wells will be utilized for input and extraction of stored product. Wells proposed
for storage operations should be permitted and constructed in accordance with existing oil and gas
well construction standards. The number and distribution of wells for a storage project depends on the
nature of the storage and deliverability desired. In addition to wells to be used for input and withdrawal,
24
the storage operator should be required to install and monitor an observation well or wells depending
upon the size of the storage project and local conditions. See monitoring section for more detail on wells
outside the cavern boundaries.
The mined cavern must undergo integrity testing prior to the commencement of storage operations. (2)
To isolate potential avenues of migration, all penetrations into the cavern should be tested for mechanical
integrity separately prior to testing the cavern as a whole. These individual well integrity tests can be
performed using tubing and packer or during construction following the cementing of production casing.
The storage operator and regulator should work together to agree upon criteria for successful integrity
demonstration. Storage operations should not begin until a successful integrity test has been completed
and approved by the regulator. In addition to cavern and well integrity, all conveyances should be individ-
ually tested prior to beginning service. This ensures integrity of pipelines, connections, valves, and any
other potential sources migration or leakage.
c. Area of Review (AOR)

i. Size
1. An AOR will differ depending on type of storage facility. Reservoir and aquifer
storage areas most likely have a wider buffer boundary that may be determined
by the particulars of local geology, historic and current oil and gas and gas storage
development and site specific storage area construction details. Solution mined
cavern storage must also consider local geology and may have a smaller, better
defined lateral extent.
2. The development of an AOR may consider whether it applies to the entire storage
area and a buffer zone around the area, or to individual wells and buffer
zones around them.
3. The size of the AOR of a new storage facility should be first determined by the
geologic setting of the storage and regulatory requirements. Reservoir storage
is often located in domed, anticlinal geologic features, stratigraphic or other
geologic structural traps, with an impervious confining zone. Cavern storage
AOR should also include an area overlying the storage horizon, considering all
potential avenues of migration.
4. The lateral extent should include a horizontal zone of influence where the pressure
of injected storage gas may:
a) have an effect on nearby production wells; or
b) exert pressure sufficient to force the migration of the gas or formation
water into zones that present a hazard associated with loss of control of
pressure gradient. These hazards could include; effects on USDWs or
other protected groundwater,increased pressure in nearby wells, or the
migration of gas to the surface, or other geologic horizons.
5. The AOR must also consider the lateral extent of geologic confining structure, to
ensure gas does not leak out of the intended geologic structural or stratigraphic
feature.
ii. Configuration
1. The configuration of the AOR for reservoir, aquifer, or cavern storage should consider:
a) Geologic setting of reservoir, aquifer, or cavern;
b) Prevailing directional dip of the formation(s);
c) Size, structure, history, evaluation, and depth of salt domes or beds;
25
d) Potential sensitive surface features;

e) Potential USDWs or other protected groundwater;
f) Potential avenues of gas migration;
g) History of subsurface drilling and underground activities (mining, solution
mining, waste disposal); and
h) Structural setting (faulting, folding, fracturing, and others).
iii. Elements of an AOR
1. The focus of an AOR must be to ensure that the storage area does not contain
avenues of migration for fluid outside of the planned storage area, or if avenues
of migration potentially exist that the development and operating plan have
contingencies to investigate these avenues and address the risk if a migration
avenue is subsequently found to exist.
2. The AOR elements may share certain features as listed below, and any other local
condition, particular to that region that may impact the integrity of the storage
area, the integrity of particular wells or any surrounding area. Knowledge of local
conditions; history, geologic setting, land use patterns, and demographics is vital
to performing an adequate AOR.
3. An AOR evaluation must contain a review of all available records for wells that
were drilled in the AOR and buffer zone. This review should determine the location,
depth, history, plugging history, cement integrity, and any other information
necessary to ascertain the degree of risk to which existing wells pose a threat for
fluid migration. Wells that are known to have penetrated, or were completed in
the storage horizon, or are vertically proximate to the storage horizon should be
of primary interest.
4. A review of all plugged well records and their surface locations must be per-
formed to determine if they were constructed and have been plugged in a manner
that prevents a man-made pathway for the movement of gas or associated fluids
from the storage zone. Particular interest must be focused on wells that penetrate
into or through the proposed gas storage zone.
5. The applicant may consider all the local history, to consider possible activity that
was not permitted in the modern era, and for activities that may have not been
adequately documented. Historical research and due diligence is of high impor-
tance. Historical research could include studies, papers, and reports on the geology
of the field and any related engineering review or analysis.
6. The applicant may also perform any practical physical reconnaissance that could
reveal historical features of concern, such as aerial photographs, Light Detection
and Ranging data, ground evaluation, seismic surveys, magnetic surveys, and
resistivity, or conductivity surveys.
7. Geologic factors such as faulting, folding, sinkholes, seeps, formation depth,
permeability of surrounding rock, confining zone characteristics, and any other
known features must be reviewed for all storage facilities for the potential to have
adverse impacts to storage area.
8. The collective evaluation of the AOR data must be a factor in determining the suit-
ability of the area to be used as a storage facility.
9. An AOR must include extensive documentation of the review process, including
maps with all known wells, all relevant features, cross-section profiles, geologic
characteristics, indices or copies of reviewed documents, historical studies, recon-
naissance reports, and all relevant information that was studied.
26
iv. Corrective Action Strategies
1. Any known safety risks to storage area integrity should be addressed and mitigated
prior to beginning storage operations. A remediation plan should be developed to
address any issues and the plan submitted as part of the permitting process.
2. Any plugged wells that are identified in the AOR must be reviewed to confirm that
they were constructed and plugged adequately. Historical plugging practices may
not be adequate to prevent migration of gas, so plugged wells should be frequently
monitored during the first few years of a new storage project and periodically
monitored throughout the life of the storage project.
3. Unplugged or inadequately plugged wells of concern should be identified for
further review.
4. Inadequately constructed or plugged wells that penetrate into or through the
storage zone must then be properly reworked or adequately plugged.
5. Laterally offset wells within the buffer zone that penetrate the storage horizon,
and that will remain in place, may be used as observation wells to look for com
munication with storage zones.
6. Initial testing of storage horizons may evaluate the AOR for any adverse impacts,
early signs of which may require mitigation, or reevaluation of suitability of the
area as a storage location.
d. Siting and Spacing Considerations
i. Physical Features Advantageous for Storage
1. A geologic structure with suitable capacity and flow potential to be commercially

viable given its relative location to intended markets and pipeline infrastructure.
2. Close proximity to markets, which provides for storage near the end users, and
offers fast response to demand.
3. Close proximity to existing pipeline infrastructure, which makes storage near
major pipelines a source for storage gas, as well as outlets.
4. Close proximity to a source of gas.
5. Rural setting. Storage facilities constructed in areas with lower population density
present a lower risk to human health and likely fewer land use conflicts.
6. Pipeline right-of-way access. Maintaining secure pipeline right of ways, free from
encroachment, is important for safety.
ii. Physical Features Not Advantageous to Storage
1. High population areas.

2. Opposites to all the above, inadequate geologic properties, distant to source gas,
markets, pipeline infrastructure, etc.
3. Existing old oil and gas wells
a) Areas with a long history of oil and gas production, with many abandoned
and undocumented wells. These wells could become potential vertical
migration pathways causing serious safety issues at the surface.
b) Storage fields with a large number of production wells that penetrate the
caprock inherently pose a higher integrity issues than a field with fewer
caprock penetrations.
27
iii. Lease History and Neighboring Oil and Gas Production
1. Some areas of the U.S. have a long history of oil and gas production, with many
oil and gas lease holders. A potential storage field operator may need to control
significant acreage for the field and buffer zones. Nearby oil and gas wells, may
interfere with safe storage operations.
2. In certain areas, other subsurface mineral extraction activities, such as coal mining,
may also be ongoing or have surface or subsurface lease interests in land being
considered for storage. Storage operators should conduct a thorough review of
the mineral ownership in their storage projects to identify potential conflicting interests.
iv. Proximity to USDWs or other protected groundwater for Depleted Reservoir Storage
1. There are areas in the U.S. where oil and gas horizons are very close vertically to
USDWs or other protected groundwater. There should be adequate vertical
separation, and a confining zone between the two.
2. The storage wells should be constructed with adequate casing and cementing to
protect the USDW or other protected groundwater.
3. For new facilities a survey of water quality from water wells adjacent to the facility
is important to consider when evaluating the siting of the facility.
e. Operational Requirements Near Sensitive Areas
i. The storage design should include plans to monitor conditions as they pertain to well
drilling and storage development for protecting the environment and health and safety
of workers and the public. This includes the development of site-specific plans for known
problems like geological and other hazards. (10)
ii. Site specific requirements should include (10):
1. Installation of protective equipment for site security and safety;

2. Development of storage well blowout contingency plans; and
3. Liaison with all pertinent law enforcement agencies and first responders.
iii. Operators may consider using leak detectors, downhole shut-off valves, or other safety
devices in areas near populations or gathering spaces, if risk assessment indicates they
are needed. See Chapter 3 for more information on Risk Assessment.
f. Drilling Through Storage Reservoirs by Type
i. Drilling through porosity reservoirs
1. New third party wells within either the vertical or lateral buffer zone should be
drilled and completed so the third party wells isolate the storage reservoir as
recommended by the storage operator and approved by the regulatory authority. (10)
2. The entity drilling the well should provide sufficient notice to both the storage
operator and the regulatory agency. (15)
28
ii. Drilling through cavern storage
1. Any situations in which an entity would propose to drill through a salt or hard
rock cavern to reach a productive or disposal zone beneath is not recommended.
2. In bedded salt, unlike with a depleted reservoir, the stored gas is contained within
the storage cavern and does not freely flow over a large lateral area. Therefore,
precautions must be taken to ensure any well passing through the bedded salt
zone does not penetrate a storage cavern or come too close to the edge of the cavern.
In order to preserve the integrity of the storage cavern, wells passing through the
salt should be located at least a distance of 2D from any cavern wall, where D is
the maximum diameter of the cavern, or 200 feet, whichever is greater. A cavern
located closer than 100 feet to any point on the salt’s perimeter is not recommended.
29
Chapter 5
Well Drilling, Construction, and Conversion
Introduction
The drilling, well construction, completion, or conversion of wells associated with underground storage
of gas has been accomplished by the gas storage industry for many years. While the vast majority of
wells utilized by the gas storage industry in the U.S. are conversions of existing oil and natural gas production
wells associated with depleted hydrocarbon reservoirs, new wells are drilled and completed to replace
older storage wells, to extend existing gas storage field utilization, and to develop new UGS fields. In
addition to formerly depleted hydrocarbon reservoirs, new wells may be drilled into salt or hard-rock
mined caverns, or aquifers. Widespread development of new natural gas producing wells with significant
liquids production has increased the interest in new LPG storage fields. Well construction and completion
will vary extensively between the different types of storage reservoirs (depleted oil and gas horizons, salt
caverns, hard-rock caverns, and aquifers) and addressing the various differences must be considered.
Perhaps the most important issue to be addressed with the drilling or conversion of any well for storage
is to ensure that the construction and completion of a well prevents pathways of gas or liquids migration
out of the storage reservoir and zonal isolation of the storage field reservoir from other formations. The
biggest concern is that many of the wells converted from oil and gas production in depleted reservoirs
are fairly old, may not meet current or contemplated regulatory requirements, and commonly require ex-
tensive workover, testing, and remedial action in order to operate with mechanical integrity. Long-term
well integrity and functionality depend upon proper consideration of life-of-the-field and life-of-the-well
operations and maintenance, including changes in the reservoir, fluids, rates, stimulation, workover and
remediation, offset, surface conditions and parameters, and plugging and abandonment. Essential con-
tinual monitoring of current conditions with comparison versus design and expected future conditions
will indicate the integrity and functionality during each life-of-well.
Main Take-Aways
• Well construction and completion can vary considerably between the different reservoir types.
• The majority of wells are vertically drilled and completed; however, some storage fields
may include a well construction option for drilling horizontally in the production or
injection zone, since gas can be injected or withdrawn at a higher rate per well. These
wells generally do not add any additional risks with regard to well integrity or zonal isolation.
• Well drilling, construction, cementing, and completion practices should be accomplished
in the safest manner possible to enhance well integrity and to ensure pathways for leakage
are prevented and the gas storage reservoir or cavern is isolated.
30
Well Drilling, Construction, and Conversion

a. Goals of Drilling, Cementing and Completion
The goal of drilling, cementing, and completion of new wells and conversion of older wells in a gas storage
reservoir is to maintain long term well and reservoir integrity. Guidelines for well drilling, construction,
cementing, and conversion practices have been established in a number of API RPs and in the Canadian
Standards Association should be considered by all gas storage operators and regulatory authorities
where applicable to gas storage wells and facilities.
i. The design of a well casing program in UGS operations should: (16) (17) (10) Provide for
control of pressures and fluids encountered by the well;
ii. Prevent losses of fluids;
iii. Prevent contamination of aquifers or other uphole and downhole porous or fractured
zones; and consider the following:
1. Wellbore conditions during the running and cementing of casing;

2. Range of operating pressures and temperatures for the well;
3. Composition of the hydrocarbons being injected into and withdrawn from the
reservoir;
4. Cyclic mode of storage operations;
5. Projected life of the well and facility;
6. Integrity of the geological formations being penetrated and fluid content of each
formation; and
7. Depth of the well.
Additional considerations as to the yield strength design, collapse and tensile design, service conditions,
casing setting depths, number of casing strings, pressure testing, and others need to be evaluated. A
cementing plan should be designed to provide for isolation of the gas storage reservoir from all sources
of porosity and permeability. Primary cementing job designs for gas storage should take into consider-
ation the following: (17) (10) (16)
i. Types of formations being cemented, including unconsolidated formations and their

effect on cement properties:
1. The use of salt-saturated cement across salt zones;

2. Bottom-hole pressure and its effect on lost circulation and gas cutting of the cement;
3. Bottom-hole temperature and its effect on cement thickening and curing times;
4. Mud displacement; and
5. Casing centralization and rotation.
ii. Additional cementing considerations should include:
1. Compressive strengths;
2. Cement tops;
3. Cement placement;
4. Preflushes;
31
5. Cement equipment accessories;

6. Pipe movement during cement placement;
7. Wiper plugs;
8. Pressure testing and evaluation;
9. Cement bond evaluation;
10. Cementing records;
11. Specialty cementing considerations; and
12. Remedial cementing.
Operators should determine the maximum and minimum operating pressures that each gas storage
well and each gas storage facility component will be subjected to during the well or component lifetime.
These pressures should be reviewed, evaluated, and approved by the regulatory agency. The operating
pressure range of each well and component, along with other load and condition factors, should be used
in each original design, re-design, and operational plan.
Periodically the operational plan should be reviewed and confirmed as applicable to each well and com-
ponent, so that operators do not exceed the minimum and maximum operating pressure of each.
Prior to each workover or remediation, the above factors should be reviewed in light of future use or
potential plugging and abandonment.
b. Drilling Process for Porosity Storage (Depleted and Aquifer Storage Reservoirs)
The following processes need to be considered for drilling or conversion of porosity storage wells:
i. Wellhead control and drilling considerations and capabilities (drilling into existing storage
fields under pressure and prevention of reservoir formation damage and contamination);
ii. Protection of USDWs or other protected groundwater: (may preclude use of drilling fluids
not compatible with protected groundwater);
iii. Addressing the many wellbore issues – corrosion zones, flow zones, lost circulation zones,
disposal zones, over pressurized and under pressurized zones, sloughing shales, zones
prone to differential sticking, and commercial hydrocarbon-bearing zones;
iv. Directional drilling and deviation surveys;
v. Formation integrity and other pressure testing; and
vi. Open-hole and cased hole geophysical logging considerations
c. Casing Program Development for Porosity Storage
The development and designing of a well construction casing program needs to address the potential
protection of USDWs or other protected groundwater and isolation of other zones, while providing for
control of wellbore conditions, prevention of migration pathways, and isolation of the storage reservoir.
i. Types of casing considerations – drive pipe, conductor, mine string (if necessary), surface,
intermediate(s), liners, and production casing strings; and
ii. Consideration of casing depths, diameters, weights, types, and use of centralizers with
utilization of API and CSA standards.
32
d. Wellhead Construction for Porosity Storage
All wellheads and christmas tree assemblies should be constructed so that the fittings, valves, and flanges
are rated for pressure greater than the maximum pressure exposure to the wellhead and christmas tree
assembly. (18). All wellhead equipment and associated fittings, flanges, and valves should conform to API
RP 6A. (18) Additionally, wellhead design should include evaluation of the following: (10)
i. Treating and stimulation pressures;
ii. Flow rates;
iii. Fluid chemical composition of produced fluids and fluids used in well stimulation;
iv. Possible solids production;
v. Possible increases in maximum operating pressures;
vi. Intended flow path; and
vii. Accommodation for pressure and/or temperature monitoring of tubular and annular
spaces.
A review and evaluation of existing state and federal regulatory requirements for wellhead construction
should be considered, but gas storage wellhead construction may require additional designs beyond current
regulatory standards to ensure well integrity and safety issues.

e. Well Cementing and Evaluation for Porosity Storage
The purpose of cement in the construction of a new or converted gas storage well is to maintain the
integrity of the storage reservoir by providing isolation of the reservoir from communication with other
permeable and porous geological formations through the drilled wellbore. (10). Cement should meet or
exceed quality standards set in API RP 10A. (19) Gas storage wells should have a primary cementing pro-
gram for each casing string that ensures isolation of zones and elimination of migration pathways. (19)
Such a program needs to provide for on-site necessary changes to cementing programs based upon
actual wellbore conditions, which may include changes to the types of cement, changes to cementing
equipment, and the use of variety of additives to ensure a successful cement job and provide wellbore
and reservoir integrity.
Evaluation of cement placement and quality is accomplished to determine that a competent seal exists
to prevent migration of gas and/or fluids from the storage reservoir or other geological formations of in-
terest. (10). Evaluation of the cement is done through assessment of the cementing records and through
cement evaluation logging. Cement evaluation logging should consider the cement cure time determined
in the cement design and recognize that it may take time for the cement to reach a sufficient compressive
strength for accurate interpretation of cement placement and bond quality.
33
f. Well Completion Methodology for Porosity Storage
The gas storage operator should design and conduct any well completion or stimulation operations in
such a manner to verify that pressure, flow rates, and other mechanical conditions have no adverse im-
pacts on the storage reservoir, confining zone(s), or mechanical integrity of the well, or causes communi-
cation between the storage zone and other porous geological formations. (10).Completion methodology
in porosity storage can include:
i. Open-hole completions/ re-completions;
ii. Cased-hole perforations/ re-completions;
iii. Coiled tubing jet cleaning;
iv. Acid treatments or hydraulic fracturing stimulation; and
v. Liner and screen placement.
For all wells in porosity storage additional completion methodology may include:
i. Cemented pipe with perforations; or
ii. Open hole with a slotted liner and sand screen; or
iii. Liner/ production casing with packers; or
iv. Gravel pack completion.
g. Drilling Wells for Bedded and Domal Salt Cavern Storage
The following processes need to be considered for drilling or conversion of salt cavern storage wells:
i. Wellhead control considerations and capabilities (drilling into existing storage fields
under pressure);
ii. Protection of USDWs or other protected groundwater– may preclude use of drilling fluids
not compatible with protected groundwater;
iii. Addressing the many wellbore issues such as corrosion zones, flow zones, lost circulation
zones, disposal zones, and commercial hydrocarbon-bearing horizons;
iv. Directional drilling and deviation surveys;
v. Preparation for drilling into an existing storage reservoir – pressure issues (including
inflow or loss of circulation);
vi. Use of salt-saturated drilling fluid in the drilling operations into the salt to prevent disso-
lution of the salt and protection of the top of the salt; and
vii. Open-hole and cased hole geophysical logging considerations.
34
h. Casing Program for Bedded and Domal Salt Cavern Storage
i. Development and design of a well construction casing program that addresses the potential
protection of USDWs or other protected groundwater, and isolation of other zones, while
providing for control of wellbore conditions, prevention of migration pathways, and isolation
of the storage reservoir;
ii. Types of casing considerations – drive pipe, conductor, mine string (if necessary), surface,
intermediate(s), and production casing strings;
iii. In domal salt wells, two casing strings should be set into the salt. (17) These casing
strings are the last intermediate and production casing strings; and experience has shown
that setting the last intermediate casing between 150 to 200 feet into the salt may
be necessary for isolation of the confining zone(s).;
iv. Consideration of casing depths, diameters, weights, types, and use of centralizers and
utilization of API and CSA standards;
v. Utilization of tubing string in cavern development and salt dissolution well connectivity
in bedded salt deposits;
vi. The use of a mule shoe at the bottom of the hanging string adds additional protection to
an overfill event. As the interface of the product in the cavern starts to uncover the top
of the mule shoe only a portion of the product starts to come up the hanging brine string
(instead of a full diameter return of product to the surface in an overfilling event) which
minimizes the impact of the overfill and is helpful if the weep hole has salted over for
some reason; and
vii. Additionally a weep hole should be a placed at a calculated distance from the top of the
mule shoe. The location of the weep hole is dependent on the diameter of the cavern (barrels
per foot) and the typical filling rate. This allows the desired or required margin of safety
to be calculated.
i. Wellhead Construction for Bedded and Domal Salt Cavern Storage
All wellheads and christmas tree assemblies should be constructed so that the fittings, valves, and flanges
are rated for pressure greater that the maximum pressure exposure.. All wellhead equipment and associ-
ated fittings, flanges, and valves should conform to API RP 6A. (18) Additionally, wellhead design should
include evaluation of the following: (17)
i. Treating and stimulation pressures;
ii. Flow rates;
iii. Fluid chemical composition of produced fluids and fluids used in well stimulation;
iv. Possible solids production;
v. Possible increases in maximum operating pressures;
35
vi. Intended flow path; and
vii. Accommodation for pressure and/or temperature monitoring of tubular and annular
spaces.
A review and evaluation of existing state and federal regulatory requirements for wellhead construction
should be considered, but gas storage wellhead construction may require additional designs beyond
current regulatory standards to ensure well integrity and safety issues. Typically, two separate wellhead
designs are used during the service life of a cavern system: One for solution mining development of the
caverns and one for gas storage service. (18) The wellhead design for gas storage service typically in-
cludes a snubbing or shut-off valve to allow for well workovers under pressure. (18)
j. Well Cementing and Evaluation for Bedded and Domal Salt Cavern Storage
The purpose of cement in the construction of a new or converted gas storage well is to maintain the
integrity of the storage reservoir by providing isolation of the reservoir from communication with other
permeable and porous geological formations through the drilled wellbore.. Cement should meet quality
standards set in API RP 10A (19) or exceeds the requirements set in these standards. Each gas storage
well should develop a primary cementing program for each casing string that ensures isolation of zones
and elimination of migration pathways. Salt-saturated cements should be utilized in the cementing of any
casing strings completed within the salt deposits.
Such a program needs to provide for on-site necessary changes to cementing programs based upon
actual wellbore conditions, which may include changes to the types of cement, changes to cementing
equipment, and the use of variety of additives to ensure a successful cement job and provide wellbore
and reservoir integrity.
Evaluation of cement placement and quality is accomplished to determine that a competent seal exists
to prevent migration of gas and/or fluids from the storage reservoir or other geological formations
of interest. (15) Evaluation of the cement is done through assessment of the cementing records and
through cement evaluation logging. Cement evaluation logging should not take place until the cement
cure time determined in the cement design has allowed the cement to reach a sufficient compressive
strength for accurate interpretation of cement placement and bond quality.
k. Well Completion Methodology for Bedded and Domal Salt Cavern Storage
After initial drilling and well completion, dissolution of the salt is undertaken to create the cavern. Cav-
ern development is initiated by salt dissolution utilizing either the direct circulation or reverse circula-
tion method. Direct circulation involves the injection of water or under saturated brine down the longest
hanging string, which starts dissolution of the salt at the bottom of this string. The saturated brine is then
pumped out of the shortest hanging string back to the surface. The reverse circulation method involves
the injection of water or under saturated brine down the shortest hanging string and then the saturated
brine is returned to the surface through the longest hanging casing string. During the cavern creation
process, care must be taken to ensure the cavern grows in size and shape as it was engineered and
designed. In bedded salt deposits, multiple salt cavern well completions are utilized and single hanging
strings are typically used once the wells have been connected within the salt.
36
A cavern can typically be developed in phases. There may be as many as three distinct phases needed for
gas storage in salt caverns and these phases can include: (17)
i. Initial development of the sump only (using direct circulation);
ii. Sump and chimney creation (utilizing the direct circulation method); and
iii. Development of the upper cavern and roof (using reverse circulation method).
Completion methodology can be different if storage of LPG versus natural gas is utilized.
l. Drilling Process for Wells in Hard Rock Cavern Storage
Typically, hard rock caverns are created by mechanically mining out hard rock using the “room and pillar”
method at relatively shallow depths ranging from approximately 230 to 650 feet below the surface. (10) (2)
The rock must be hard enough for cavern stability and the rock types typically utilized are non-porous, such as
chalk, shale, limestone, dolomite, and granite. The construction and well drilling processes need to consider:
i. Wellhead control considerations and capabilities (drilling into existing storage fields
under pressure);
ii. Protection of USDWs or other protected groundwater (may preclude use of drilling fluids
not compatible with protected groundwater);
iii. Addressing the many wellbore issues such as corrosion zones, flow zones, lost circulation
zones, disposal zones, and commercial hydrocarbon-bearing horizons;
iv. Preparation for drilling into an existing storage reservoir – pressure issues and prevention
of reservoir formation damage and contamination;
v. Formation integrity and other pressure testing; and
vi. Open-hole geophysical logging considerations
Figure 5-1 is a photograph of a hard rock

cavern under construction in shale in
Middletown, Ohio in 1959.
Source: http://caplaconference.com/
wp-content/uploads/2015/04/Piplines.
37
m. Casing Program for Mined-out Cavern Storage
A casing program may seem less complex due to the shallow depths of most of these caverns but can
become complicated by the large diameter casing strings involved, which are not normally found in other
types of storage programs. Development and design of a well construction casing program that addresses
the potential protection of USDWs or other protected groundwater and isolation of other zones, while
providing for prevention of migration pathways and isolation of the storage reservoir is critical. Depths
of casing, diameters, weights, types, use of centralizers, and utilization of API standards must be consid-
ered. Many off-the-shelf tools are not available for large diameter boreholes and casing string.
n. Wellhead Construction
Wellhead configuration of hard rock caverns is entirely different from other gas storage reservoirs due to
the larger casing diameters and completion methodology. Figure 5-2 illustrates a typical wellhead design
for a hard rock cavern and is often called the “dome.”
Figure 5-2: Example of wellhead configuration of hard rock cavern storage.

Source: http://caplaconference.com/wp-content/uploads/2015/04/Piplines.pdf
38
o. Well Cementing and Evaluation for Hard Rock Cavern Storage
Development of a cementing program for each casing string to ensure isolation of zones and elimination
of migration pathways is very important. Operators need to adjust cementing programs based upon
actual wellbore conditions. An operator should maintain cementing records and conduct cement evaluation
logging as needed. One of the most critical components of the hard rock cavern well is cementing of the
last casing string, especially around the casing shoe. (2)
p. Well Completion Methodology for Hard Rock Cavern Storage
Completion methodology is different than other types of storage due to density differences with LPG
versus natural gas. Figure 5-3 illustrates the typical completion methodology developed for hard rock
caverns.
Figure 5-3: Example of a well construction diagram of a hard rock cavern. Source: http://ca-
placonference.com/wp-content/uploads/2015/04/Piplines.pdf
39
q. Plugging and Abandonment of Shafts
Mine shafts used for creating the cavern mined out in the rock and for operation needs to be properly
plugged and sealed to prevent migration and to isolate the storage reservoir. The concrete plug to seal the
shaft should be designed to be sufficiently long enough and to have adequate capacity against shearing. (20)
40
Chapter 6
Well Integrity Testing
Introduction
Mechanical integrity testing of underground gas and hydrocarbon storage wells is a critical aspect of
long-term success for any gas storage project. Gas storage wells vary broadly in age and construction
around the country and can include wells that are over 50 years in age, converted from oil and gas
production wells, or completed into bedded or domal salt deposits or mined-out caverns, and new wells
specifically designed for injection and production of stored gas or other hydrocarbons. As such, testing
and evaluation methods for assessing mechanical integrity can vary considerably. Furthermore, regu-
latory scrutiny of well integrity and its assessment has increased due to recent incidents and the risk of
new incidents. This section will review objectives and details pertaining to approaches and methods of
assessing the integrity of gas and/or hydrocarbon storage wells using a holistic approach to the evalua-
tion of well integrity.

One of the greatest threats to gas or hydrocarbon storage is the loss of well integrity. Approximately 79
percent of existing gas storage fields in the U.S. was converted from depleted oil and gas reservoirs, with
a large percentage of the wells in these fields being rather old so that wells were often not drilled and
completed to today’s standards. Consequently, well integrity is an ongoing issue in many storage reser-
voir fields that must be addressed using the proper (i.e., modern) well integrity testing methodologies
and remediating any well integrity deficiencies. In addition, injection/withdrawal wells represent a
significant potential vulnerability in cavern storage facilities and their integrity is of critical importance.
Main Take-Aways
• Lack or loss of well integrity is one of the greatest threats and risks to any gas storage project.
• There are a variety of well integrity testing methods, but no single testing method alone should
be used to determine well integrity.
• Assessment of well integrity requires a holistic, risk based approach.
Objectives, types and methods of mechanical integrity testing

a. Objectives of Integrity Testing
Mechanical integrity is the design, installation, operation and maintenance of all well equipment to
a standard that ensures the safe containment of well fluids and injectate for the life of the well. (21)
Simply put, mechanical integrity is a lack of significant leakage within the well and wellbore. Ongoing
routine mechanical integrity testing is a critical aspect of the long-term success of any gas storage project
and can help ensure the following objectives are met:
i. Protection of USDWs or other protected groundwater,;
41
ii. Proper well configuration for the demands of underground gas and hydrocarbon storage;
iii. Safety and risk prevention; and
iv. Meeting regulatory goals and operational demands.
A holistic, risk based approach to mechanical integrity testing should be used to facilitate the determina-
tion of well integrity. This type of an approach does not rely on any single tool, but evaluates overall well
integrity using a variety of industry standard tests and logs that have been refined to achieve specific
testing objectives. While any one test may indicate a potential concern, a compilation of tests in a holis-
tic approach will help to refine and/or clarify whether a well has mechanical integrity. The holistic well
integrity assessment process should include a series of analytical reviews and tests which includes but is
not limited to the following:
i. Well casing and cementing review;
ii. Well integrity testing;
iii. Well logging; and
iv. Routine monitoring.
Test objectives and methodology should be tailored for gas storage wells. Often, industry standard
practices that were developed for production and water injection wells may not be appropriate for the
assessment of gas storage wells. In order to be effective, specific testing methods that are appropriate for
gas storage wells, together with detailed implementation expectations (e.g., fluid-filled annulus, logging
speeds, etc.) and explicit requirements for test results (e.g., pressure testing to maximum allowable internal
pressure, etc.) must be established.
It should be noted that some types of tests, particularly tests that require the removal of tubing, change
of downhole conditions (e.g., filling the well with liquid), or an insertion of new tools downhole intro-
duce some risk to well operation during those times. Thus, the risks associated with performing tests
should be considered when determining testing schedules, and the application or development of tests
that require less invasive changes in the well operations should be encouraged. This fits very well into a
holistic, risk-based approach, where some types of tests should be performed more frequently than others
based on the information that they give, the well-specific risks that have been determined, and the risks
associated with the testing, among others.
b. Types of Well Integrity
When evaluating well mechanical integrity, both internal and external integrity must be considered and
evaluated for a complete assessment. Internal and external well integrity considerations are illustrated
in Figure 6-1 and discussed in further detail below. Certain integrity considerations are not always appli-
cable to salt cavern and hard rock mined storage.
42
Figure 6-1: Diagram Illustrating Internal and External Mechanical Integrity Considerations
Source: ALL Consulting, Inc., 2017
i. Internal Integrity: Internal well integrity generally refers to the portion of a well extending
from the production casing inward and including all components in that space from the
wellhead to the bottom of the casing. This includes but is not limited to casing, tubing,
packers, plugs, and well head components. Thus, when testing the internal integrity of
a well, the testing is aimed at the current condition of well components, changes in the
condition of the components between tests, and the ability of those components to
contain and control the movement of fluids and or gases between the target formation or
cavern and the surface.
ii. External Integrity: External well integrity generally refers to the portion of a well
extending from the production casing outward to the wellbore contact with the forma-
tions surrounding the well and including all the components in that space (e.g., cement).
When testing a well’s external integrity, the testing will reflect the adequacy and condi-
tion of the well components and their effectiveness in protecting USDWs or other protected
groundwater, prohibiting communication of fluids and gases between geologic zones, and
limiting the flow of fluids and gases to/from the target zone to the production casing.
iii. Other Integrity Considerations: Although not specifically addressed within this document,
other items that should be considered with a holistic evaluation may include well pad,
pits, impoundments, tanks, trucks, pumping equipment, other surface equipment, and
pipelines.
c. Well Integrity Testing Methods and Technologies
The following paragraphs discuss a variety of internal well integrity testing methods and technologies.
Table 6-1 indicates which of these technologies are most appropriate for testing internal vs. external
integrity and also notes which can be used for either. The list of testing methods comprised here is not
entirely comprehensive and does not account for future testing developments.
43
Mechanical
Internal or
Integrity
External Test/Log Objective Well Preparation Comments/Considerations
Testing
Integrity
Methods
Mechanical Integrity Test
 Wellbore and well must be
full of fluid  Pass/Fail Criteria can be established
Standard  Demonstrate no leaks in the  Must stabilize temperature in  Can be used on any well
Annular Internal casing-tubing annulus well and annulus  No unapproved fluid additives
Pressure Test  Casing/packer leak detection  Must pull tubing and set  Testing pressure should be equal to at least the
bridge plug for wells without maximum allowable injection pressure
a packer
 Pass/Fail Criteria can be established
 Interpretation is relatively straightforward (type curves are
 Annuli and casing must be available for comparison)
External bled to 0 psig prior to  Test can be influenced by outside factors such as
Annular
(including  Identify gas flow outside of initiating test barometric pressure, mud clogging or freezing of lines,
Pressure
wellhead) casing (annular pressure)  Shut-in annuli should be etc.
Build-up Test
& Internal allowed to vent for a period  Gauges must be properly sized for the anticipated
of time prior to testing. pressures
 Continuous data recording are important to confirm
quality of results
 Pass/Fail Criteria can be established
 Simple interpretation
Annular  Identify flow of gas to  Shut-in annuli should be
External &  Two test types:
Venting Flow surface as an indication of a allowed to vent for a period
Internal  Manometer Tests: Quantitative assessment of flow
Rate Test leak of time prior to testing.
 Balloon Test/Bubble Test: Qualitative assessment of
flow (used when flow is below quantifiable rates)
44
45
Table 6-1: Mechanical Integrity Testing Matrix
d. Internal Well Integrity
i. Standard Annular Pressure Test (SAPT)

The Standard Annular Pressure Test (SAPT) is a common method used to demonstrate
internal well integrity. The SAPT assesses the ability of the annulus of a well to maintain
an applied test pressure, thereby indicating the presence or absence of leaks in the system
(i.e., packer, tubing, casing, and wellhead).
ii. Downhole Video Log

This tool consists of a light source and video camera that can record a continuous video
image of the internal surfaces of a well. Some tools are configured to allow a view looking
either straight down the well or laterally out to the side to provide greater detail of the
internal casing surfaces. These videos are useful for well integrity evaluations where they
can provide a visual image of scale, corrosion; mechanical wear, etc. See Figure 6-2 for an
example.
46
Figure 6-2: Downhole Video Tool and Snapshot from Video Log Showing Exposed
Casing Threads at a Pipe Joint
Source: EXPRO, 2016
iii. Nitrogen-Brine Interface Test (Cavern Wells)

The Nitrogen-Brine (or product) Interface Test can be used to assess the internal integrity
of a storage well and/or the integrity of a cavern. Nitrogen is injected into the well,
displacing brine or product until the nitrogen-brine interface is either just above the base
of the casing (casing test) or below the bottom of the casing (cavern test). Geophysical tools
are used to monitor the nitrogen-brine interface if there is a leak above the interface. A
calculated leak rate can be derived from interface movement measurements. It is recom-
mended that all stored product be removed from the reservoir to the extent possible
when performing this test.
iv. Freshwater-Brine Interface Test (Cavern wells)

The Freshwater-Brine Interface Test is used as an alternative test method where use of
the SAPT is impractical. (22) The test requires that the reservoir be filled with brine and
then freshwater is injected into the wellbore, displacing brine to about 50 feet from the
bottom of the well. Wellhead pressure is monitored, which will indicate an upward movement
of the freshwater-brine interface. To distinguish this pressure change from variations
caused by changes in cavern pressure, it is compared to pressure measured either at a
nearby reference well or the pressure in a column of fluid in the injection tubing may be used.

v. Infrared Imaging
The infrared (IR) camera provides a reliable, qualita-
tive screening tool with which to identify fugtive
hydrocarbon emissions from surface equipment (see
Figures 6-3 and 6-4). The sensor in the IR camera
detects specific wavelengths that correspond to
the absorption wavelengths of chemicals present in
the atmosphere. IR cameras are particularly
useful for the evaluation of wellhead and equipment
integrity. They provide real time identification of
leaks which in turn allows for informed decision
making and for repair/remediation tasks, some
Figure 6-3: Surveying Wellheads
of which can be conducted very quickly
for Potential Fugitive Emissions
and at limited expense.
Source: ALL Consulting, 2015
47
Figure 6-4: Photographs of a Cellar in Visible Light (Left) and in Infrared (Right)
Source: ALL Consulting, 2015
e. External Well Integrity
i. Pressure Build-up Testing

Pressure build-up testing should be a main component of any routine monitoring and
assessment of external mechanical integrity. A pressure build-up test consists of closing
the vent for the well annulus being tested and allowing pressure to build-up on the annulus
for a specified duration of time. The results can then be interpreted to assess the pres
sure within an annulus and the nature of the pressure build-up rate. Considerations of
this testing includes:
1. The continuous collection of pressure data using transducers with data loggers is
preferred over periodic observation of gauges.
2. Transducer pressure ranges and error bands should be based on anticipated pres-
sures to ensure accuracy of test results.
3. Proper planning and preparation are vital to prevent testing errors and anomalous
conditions (mud in annular risers, freezing of test assemblies during winter
months, and leaks in connections points of test assemblies).
4. Static shut-in annular pressure should be bled-off and the annulus allowed to vent
for a period of time to allow the wellbore to stabilize prior to initiating the pressure
build-up test.
ii. Annular Venting Flow Rate Test

Annular venting flow rate tests are performed to quantify the volume of gas that may be
present in the casing or annulus of a well. In conjunction with shut-in pressure build-up
tests, they help to identify and characterize wellbore gas intrusion and are a key component
in the routine assessment of well integrity. Elements of annular venting flow rate testing are:
1. Two quantitative devices are appropriate to measure annular flow rates in gas
wells: the orifice well tester and the critical flow prover. They are appropriate for
testing wells with different pressure ranges: (23)
a. Orifice Well Tester: For use when upstream pressure is less than 15 psig.
b. Critical Flow Prover: For use with higher flows and where pressure on the
upstream side of the plate or choke is at least twice as large as the down
stream pressure.
48
2. Testing is conducted using a manometer. The pressure differential on the manometer

is cross referenced to established flow rate tables which are based on laboratory
results. (23)
3. Two qualitative methods may be used when flow rates are too low to be measured
using the manometer: (24)
a. Balloon Test: The balloon test consists of allowing a small balloon (4 to 6
inches) to inflate for 10 minutes. Photographic documentation of the balloon
is taken at the completion of the 10-minute interval.
b. Bubble Test: A bubble test is performed by running a 3/8-inch or 1/2-
inch diameter tube from the casing riser into a 5-gallon bucket that is half-
filled with water. Bubbles floating to the top of the water in the bucket are
counted and recorded over a 10-minute period.
iii. Geophysical Logs
1. Temperature Log
Temperature logging is an industry- and regulatory-accepted tool for evaluating
both internal and external mechanical integrity. It is based on the fact that
temperature typically increases uniformly with depth in natural settings unaffected
by human influence. A deviation from that normal gradient can result from the
presence of a fluid derived from a different depth (and hence a fluid at a different
temperature) or gas entering the wellbore. (25) Considerations in temperature
logging include:
a. Standardized logging practices should be used and the well must be properly
prepared in order to ensure quality of logging results.
b. The tubing must be removed, the wellbore must be 100 percent filled with
fluid, and the well should be allowed to stabilize for a minimum of 12 to
24 hours prior to initiating logging activities.
c. The temperature log should be completed on the down-pass with a
consistent speed of no more than 30 feet per minute.
d. Temperature logs are predominantly conducted and interpreted in con
junction with audio logs.
2. Audio Log
Audio logging equipment and techniques have been refined to become indus
try- and regulatory-accepted tools for evaluating external mechanical integrity.
Simply, an audio log is a series of audible sound measurements recorded by a
hydrophone at prescribed intervals throughout a wellbore. By analyzing the
frequency structure, amplitude and depth of recorded noise, the type of flow,
magnitude of flow, and origin of flow can be identified. (26) Audio logging consid-
erations include:
a. As with temperature logs, the tubing must be removed and the wellbore
must be 100 percent filled with fluid.
b. The audio log should be completed by stopping at stationary intervals of
no more than 250 feet, allowing the noise to stabilize for a minute or more
as needed, and recording the ambient noise.
c. Additional stationary intervals should be completed above, adjacent, and
below casing shoes, perforations, and any anomalies identified on a
temperature log.
49
3. Ultrasonic Noise Log

Ultrasonic Noise Logging is a relatively new sound log that focuses on monitoring
sound characteristics of gas leaks through casing. Unlike normal audio logs, which
record acoustic energy between 200 Hz to 6 KHz, ultrasonic logging measure energy
in the 40 KHz range where energy from a small casing breach is likely to occur.
Detection of leak rates as small as 0.0024 gallons per minute is reportedly possible.
4. Cement Evaluation Logs
Cement evaluation is a critical component of the assessment of external mechanical
integrity. In combination with casing and cementing records review, the comple-
tion and analysis of cement evaluation logs provide insight into the presence of
cement behind casing along with the level of cement bond to both the casing and
formation. (27) Additionally, cement evaluation logs can also identify cement
conditions such as micro-annulus, channeling, and compromised cement. (28)
A wide variety of cement evaluation logs are available to assist with the assessment
of casing and cement integrity. These can be generally grouped into acoustic and
ultrasonic logs. Cement evaluation logs are often run in combination to provide a
more robust evaluation of cement and cement bond. Examples of each are provided
below along with a brief description of the tool.
a. Cement Bond Log (CBL): The acoustic CBL is the most commonly used
cement evaluation log. (29) The CBL is an acoustic logging tool that measures
the changes in the acoustic signal as an indication of the integrity of the
cement bond. However, CBL’s are a qualitative tool because they do not
measure the bond through the entire 360 degree circumference of the well.
b. Radial Cement Bond Log (RCBL): Similar to a CBL, an RCBL is an acoustic
logging tool that measures the changes in the acoustic signal as an indication
of the integrity of the cement bond. It incorporates eight radial receivers
that provide 360 degree coverage of the surveyed casing section.
c. Cement Evaluation Tool (CET): A CET log is an ultrasonic tool utilizing 8
transducers located at 45 degree increments for full wellbore coverage.
The CET is capable of identifying cement channels and contaminated
cement. It also provides a determination of cement compressive
strength and casing corrosion.
d. Segmented Bond Tool (SBT): An SBT is an ultrasonic tool that uses 6
padded receptors to measures cement bond integrity for full 360 degree
coverage of the casing. SBT has advantages over conventional tools (i.e.,
acoustic tools) because is less sensitive to borehole conditions (e.g., bore
hole fluids, fast formations, tool centering, etc.).
e. Ultrasonic Imager Tool (USIT): A USIT log is an ultrasonic tool that uses a
rotating receiver to measure 360 degree coverage of cement bond integrity
as well as casing wall thickness and corrosion detection. As with other ultra
sonic tools, interpretation of USIT log is not as dependent on wellbore conditions.
f. Isolation Scanner: The Isolation Scanner combines pulse-echo technology
with an ultrasonic technique of flexural wave imaging to evaluate cement
job and casing condition for a wide range of cements – heavy, traditional
to light weight cements. The older CBL/USIT logs may make it difficult to
evaluate cements with low acoustic impedance or cements contaminated
with mud while the isolation scanner differentiates between high-perfor-
mance light weight cements from liquids and maps annulus material as
solid, liquid, or gas.
50
5. Radioactive Tracer Survey

A radioactive tracer survey is commonly used to test the mechanical integrity of
an injection well by detecting the movement of fluids tagged with a tracer. If
mechanical integrity is compromised, the tracer fluid will be observed to split and
travel in different directions. This survey is based on the presence of liquid in the
wellbore; as such, it has minimal applicability to gas storage wells.
6. Spinner Survey
Spinner surveys make use of bladed spinners to measure the velocity of fluid flow
in a well and are typically used in fluid injection wells or oil/gas production wells.
This survey is based on the presence of liquid in the wellbore; as such, it has minimal
applicability to gas storage wells.
iv. Corrosion Logging

Corrosion is a natural chemical process that is almost impossible to prevent. Consequently,
controlling and monitoring of corrosion rate is often the preferred approach to managing
corrosion. It is of concern throughout the life of the well and therefore must be monitored
throughout the life of the well. There are several general categories of corrosion:
1. Electromechanical: includes crevice/pitting and stray current corrosion.

2. Chemical: hydrogen sulfide, polysulfide, sulfur, carbon dioxide, strong acid,
concentrated brine, and biologically-influenced corrosion.
3. Mechanical and mechanical/corrosive effects: cavitation, erosion, corrosion fatigue,
sulfide stress corrosion, chloride stress cracking, embrittlement and stress corrosion
cracking.

The tools/techniques used for corrosion monitoring include:
1. Multi-Finger Caliper Log: Caliper feelers on the logging tool deflect as the tool is
run through the casing. This deflection of each feeler is used to identify where
corrosion is occurring and the percentage of casing wall thickness that has been
lost to corrosion.
2. The CPET, or Corrosion Rate log, measures potential differences and casing resistance
between electrode pairs to calculate radial current density from which the casing
corrosion rate is computed.
3. Electromagnetic Casing Inspection Log: The Electromagnetic Pipe Scanner Tool
measures the average thickness of the casing pipe and also discriminates between
damage on the inside of the casing from damage on the outside. The Electromagnetic
Pipe Scanner can be run inside tubing.
4. Magnetic Flux Leakage Tool: This tool induces a magnetic field and then measures
perturbations in that field resulting from variations in the thickness of the casing.
5. USIT and Ultrasonic Casing Imager: Both tools use pulse-echo ultrasonic energy
to reflect off of and resonate within the casing wall. Frequency analysis of the
resonant signal allows computation to determine the thickness of the casing. In
turn, the internal radius and computed thickness allows an assessment of both
internal and external loss of original casing thickness.
v. Additional Information
1. An assessment of mechanical integrity should also include a thorough geologic

review and evaluation of potential migration pathways. All available open-hole
51
geophysical logs and mud logs as well as drilling records should be evaluated with
particular attention paid to the occurrence of gas shows above the gas storage
reservoir as well as zones with potential for high transmissivity. Potential gas
sources and pathways include but are not limited to the following:
a. Shallow gas-bearing zones: Natural gas can occur naturally in shallow

near-surface zones. Therefore, the presence of shallow gas would not
necessarily indicate a breach in the integrity of a gas storage reservoir at
greater depths.
b. Coal seams and underground coal mines: Methane gas naturally occurs in
coal seams and underground coal mines. Therefore, the presence of natural
gas in and near coal seams would not necessarily indicate a breach in the
integrity of a gas storage reservoir at greater depths.
c. Legacy oil and gas wells: Active and abandoned oil and gas wells proximal
to gas storage reservoirs may act as conduits for natural gas to migrate
into other strata including shallow aquifers. Legacy oil and gas wells, par-
ticularly historic wells that were drilled, completed, and plugged and/or
abandoned prior to implementation of modern drilling techniques, well
construction, cementing, and plugging practices, can present avenues for
gas migration from gas storage reservoirs.
f. Evaluating Mechanical Integrity Testing
A complete assessment of mechanical integrity requires a holistic, risk based approach. This holistic
approach should use a combination of investigative procedures to assess mechanical integrity and draw
results based on an overall well evaluation analysis, as opposed to focusing on one single test or well log,
and should consider risks of testing and of testing histories. No single test or log can provide a proper
determination of mechanical integrity. Routine monitoring, testing, and record keeping for the life a well
can ensure mechanical integrity objectives are met.
52
Chapter 7
Reservoir Integrity
Introduction
Reservoir integrity is defined by the geologic conditions for safe operation of UGS facilities beyond the
wellbore. It specifies the volume, operating pressure, and integrity of the gas storage reservoir or cavern.
Likely risk points for gas leakage are breaches of vertical and lateral confinement caused by man-made
penetrations (wells), and naturally occurring faults, fractures, confining zone/caprock sequence, and
stratigraphy. This chapter includes an overview of factors affecting reservoir or cavern integrity. Regulatory
and risk management elements, including API and International Organization for Standardization (ISO)
recommendations, are discussed. The important issue of reservoir monitoring is considered in Chapter 9.

Although wells constitute a fundamental risk element for product loss, the geological and geomechani-
cal integrity of the reservoir itself is also of primary concern (30). Hydrocarbons (gas and liquids) can
escape confinement from their intended subsurface zone by means of multiple mechanisms including
accessing faults and fracture sets (31) (32), failure of confining zone (caprock) sequences, and structural
spill points. Failures of reservoir integrity and migration of gas and liquids are well documented for all
main types of gas storage facilities (depleted oil and gas fields, aquifers, and caverns), along with storage
in abandoned mines or purpose-built mined-rock caverns (33) (34) (35) .
Storage operators should be aware that, while a reservoir being operated as a production field may
have sufficient isolation from adjacent production fields, when operated as a storage field there may be
communication with those adjacent fields due to the significant pressure differentials, particularly with
boundaries with spill point(s) or boundaries consisting of stratigraphic trapping mechanisms, i.e. porosi-
ty and permeability pinch outs. Similarly, a dry hole or observation well drilled on the perimeter of a field
during the field’s production era may not be “dry” during the field’s storage era. The operator should
also take into consideration during the field’s design that operating above the discovery pressure may,
depending on the field’s specific characteristics, increase the risk of communication and gas movement.
Risk registers can be assessed and mitigative practices developed in the oil and gas (36), geothermal
(37), and carbon dioxide sequestration (38) (39) (40) (41) industries. Standard practices for risk
management include multiple-barrier models such as bowties (diagrams used to analyze risks and
responses) (42) (43) and workflows that include well integrity, reservoir integrity, and operational/or-
ganizational elements. Design of monitoring programs to ensure reservoir integrity can be informed by
analytical and computational reservoir and cavern models and regular assessments of the results.
Main Take-Aways
• Gas or liquids can leak or move from an underground storage facility of any type, if
reservoir or cavern integrity is compromised, even when well integrity is maintained.
• Geologic and geomechanical characterization of storage reservoirs and cavern scan identify
applicable risk elements for potential gas or liquid migration including faults, fracture
sets, confining zone/caprock sequence failure, and structural spill points.
53
• Based on reviews of publically available literature and data, the frequency of gas migration
or leakage from UGS facilities is generally very small. The lowest frequency is for solution-
mined caverns in salt and the largest for depleted hydrocarbon formations.
• This is likely because such depleted formations may have older wellbores that were converted
from production to storage.
• Risk mitigation should include management of reservoir and cavern pressures to minimize
the risk of confining zone/caprock sequence failure.
• Risk management programs that include reservoir and cavern integrity issues should
address the goals of available standards (such as API and ISO) and Federal legislation
(PIPES Act of 2016).
Reservoir Integrity
a. Relevance of Reservoir Integrity to Underground Gas Storage
According to data from the U.S. Energy Information Administration (EIA), and shown in Figure 7-1, the
majority (329, or 79 percent) of the 415 natural gas storage facilities in the U.S. (data as of 2015) utilize
depleted oil and gas fields; 47 (11 percent) occupy depleted aquifers, and 39 (9 percent) are in mined
salt caverns. Porosity storage then represents 91 percent of UGS fields, with solution-mined salt caverns
comprising the remainder. The values compiled by EIA and noted here do not include approximately 70
additional facilities developed in mined hard-rock caverns such as coal mines that store LPGs such as
propane.
Figure 7-1 Geographic locations of Underground Storage facilities in the U.S.

Source: U.S. EIA www.eia.gov
54
Many examples are available in the literature that document migration of gas and liquids from their
intended subsurface zone, even when wellbore integrity is maintained. These have been compiled and
discussed by Evans and Folga et al. with additional events noted in this chapter. Although loss of well in-
tegrity is the primary cause of gas or liquid leakage events in the U.S. and worldwide for depleted oil and
gas fields, loss of subsurface integrity is the dominant cause for depleted aquifer fields, salt cavern fields,
and mined cavern fields.
The first use of abandoned mines for hydrocarbon storage (44) was in Sweden in 1947-1950 (20). A
worldwide survey of underground mines repurposed for oil and gas storage by Peila and Pelizza (45)
lists eight such mines globally, including six mines in the U.S., that were used for petroleum storage as of
1995 (their table 4). Of those eight mines, only three (one in the US (the Leyden mine and two in Bel-
gium) were used to store gas according to Lu. At least five LPG storage facilities located in mined cav-
erns were reported separately from Ohio alone, with leakage reported from one of these in 2013 (46).
A report to the USDOE in 1998 (47) cited from an unpublished earlier study that a total of 1,122 UGS
caverns were in operation in the U.S. for LPG as of 1991; of these, 70 were in hard rock caverns and 1,052
were in salt caverns. The Leyden storage facility northwest of Denver, Colorado utilized an abandoned coal
mine that was in operation until 1950 (48).
Mined rock caverns are often at shallow depths below the ground surface, unlined, have depths exceeding
about 150 feet, and typically utilize hydrodynamic containment (water curtains) (49) approaches when
used to store oil and gas. (20) General guidance for natural gas and especially LPG storage in mined rock
caverns is given by IOGCC (2) which emphasizes the role of mitigating limitations in the geology (such
as fracturing or pillar strength) to promote safe operation of these facilities. Subsidence of the ground
above mined caverns may promote an increased risk of product leakage and needs to be monitored and
managed for this type of storage facility.
Of the 415 natural gas storage facilities in the U.S. (3), 74, or 15 percent, have experienced some type of
product leak (liquid or gas) at some point in their operational life-cycle through 2005. (33) Following stud-
ies by Papanikolau et al. (54) and Folga et al. (50) the approximate average incident frequency estimates for
underground natural gas storage are listed and compared in Table 7-1. (After Schultz) (61) The values
from the latter two studies combine different degrees of severity and therefore overestimate the rates of
significant leakage events, such as those with fatalities and/ or property damage.
The values listed in Table 7-1 suggest that the frequency of leakage (in the subsurface) from all types of
underground natural gas storage facilities in the U.S. ranges between approximately:
• 8.4 x 10–4 /facility/year, or once in about 1,192 facility years (54);

• 6.2 x 10–3 /facility/year, or once in about 161 facility years (50), which incorporates incidents
through 2016 but uses facility years and well-year values from dating from approximately
2005); and
• 5.1 x 10–3 /facility/year, or once in about 197 facility years (50) with facility years and
well-years estimated for 2016, the date of their study).
Correspondingly, the frequency of an incident involving a loss of well integrity at all types of underground
natural gas storage facilities in the US ranges between approximately:
• 1.0 x 10–5 /well/year, or once in about 98,943 well-years of well operation (which incor-
porates incidents through 2016 but uses facility years and well-year values from dating
from approximately 2005); (50) and
55
Table 7-1: Migration frequency from underground natural gas storage facilities
(1) Incidents were not broken out into separate causes or degrees of severity
(2) First value listed uses facility year and well-year frequencies from 2005 (54); second value listed uses estimated
frequencies through 2016.
• 5.6 x 10–6 /well/year, or once in about 178,041 well-years of well operation (with facility
years and well-years estimated for 2016). (50)
The data in Table 7-1 and summarized above confirm that solution-mined salt cavern storage is the least
likely to leak (e.g., (51)), with aquifer storage having a greater average leakage frequency. Many UGS
facilities in the U.S. have been operated for about a century and their average leakage rate is orders of
magnitude smaller leakage rates of above-ground facilities such as tanks and pipelines. (33) In general,
loss of well integrity is the primary factor in UGS leakage events with failures of subsurface integrity and
operations being important secondary contributors.
Leakage events from UGS facilities have occurred from a number of causes (Table 7.1). Many can be
related to a loss of well integrity, whereas others can be attributed to a loss of subsurface integrity (such
as confining zone/caprock sequence failure, salt movement, or roof collapse) or operations (for example,
procedures not followed). Many events are related to multiple causes and not all leakage events can be
attributed solely to a loss of well integrity. In many cases the facilities were operated according to established
guidelines, while at others operators failed to follow procedures. In all cases the risk of leakage events
could potentially be reduced by improved guidelines for wells, geologic characterization, and operations.
56
Bruno et al. (52) showed that 22 leakage events from a total of approximately 485 porosity-storage
facilities worldwide could be attributed to gas migration through the confining zone/caprock sequence,
corresponding to about 10 percent of all reported migration events investigated in their study. Of these,
half were due solely to failure of the confining zone/caprock sequence itself, a quarter were due solely to
undetected or incorrectly characterized faults or fractures in the sequence, and the remaining quarter were
due to a combination of confining zone/caprock sequence failure and seal bypass mechanisms. Aquifer
storage accounted for about 10 percent of the worldwide total (but more than 31 percent of U.S. facilities;
Table 7.1) but 65 percent of those 22 confining zone/caprock sequence-failure events.
The values noted in this chapter were computed as simple averages, following prior work in the literature
on incident frequency (e.g., [ (54) (55) (50)]). More robust methods such as those described by Hubbard
(56) may lead to different probabilities or frequencies of facility and well leakage rates, and a corresponding
difference in risk, for UGS facilities. For example, depending on the actual distribution of events and their
magnitudes, the average frequency may overestimate the median, leading to an underestimate of the
frequency of occurrence of large-magnitude events and a corresponding increase in risk (and decrease in
time interval between them) for those larger events.
The underground storage of LPG in hard rock caverns is based on a principle of natural hydraulic
containment, which involves keeping the hydrostatic pressure of the groundwater in the host rock higher
than the vapor pressure of the stored product. (2) Reservoir integrity must be evaluated throughout the
operations by: (2)
• Checking the stability of the cavern by continuous surveillance of acoustic emissions

(seismic monitoring);
• Periodic subsidence monitoring;
• Permanent monitoring of the hydrogeological system through observations wells
equipped with piezometers; and
• Ensuring that hydrogeological conditions necessary for the hydrodynamic containment of
the stored product are maintained at all times.
b. Guidance from Existing Standards
Risk mechanisms and mitigation strategies for reservoir and cavern integrity are discussed in several
applicable standards, including API RP 1170, 1171, and ISO 55000. (57) Risk mechanisms and mitigation
strategies are listed in Table 2 of API RP 1171. Previous guidance for regulators produced by IOGCC is
also incorporated into this chapter. (11)
ISO 55000 is an international standard for asset management. (57) It replaced Publicly Available Standard
(PAS) 55, a 28-point checklist of requirements developed in 2004 for effective physical asset manage-
ment in 2015. The PAS and ISO standards are currently being used by at least one U.S. public utility
company that operates UGS facilities. (58)
API RP 1170 was developed in 2015 to provide recommendations for salt cavern facilities (cavern storage)
used for natural gas storage service and covers facility geomechanical assessments, cavern well drilling and
completion design, and solution mining techniques and operations, including monitoring and maintenance
practices. API RP 1170 essentially updated and consolidated similar documents for UGS in solution-mined
salt caverns published by the API, including API RP 1114 Recommended Practice for the Design of Solution-
mined Underground Storage Facilities (13) (59) and API RP 1115 on Operation of Solution- Mined Under-
ground Storage Facilities. (60) API RP 1171 is a new RP for natural gas storage in porous formations. (10)
57
Tables 1 and 2 in API RP 1171 list a set of risks and mitigation strategies for porosity storage of natural
gas. Taken together, these tables resemble a bowtie diagram correlating risks (their Table 1) and mitigations
(their Table 2). There is no corresponding set of risks or mitigations for natural gas storage in salt rock in
API RP 1170.
There are three main groups of risk areas identified for porosity storage in API RP 1171, with several
subcategories, as listed here:

i. Surface
1. Third-party damage
a. Surface encroachment
b. Intentional/unintentional damage
2. Outside force: natural causes such as weather-related or ground movement
ii. Reservoir
a. Drilling, completion, and workover activities
b. Production, injection, or disposal operations
2. Geologic uncertainty
a. Extent of reservoir boundary
b. Expansion, contraction, and migration of storage gas
c. Failure of caprock
3. Contamination of storage reservoir by foreign fluids; wellbore damage or corrosion
iii. Wells
1. Well integrity (corrosion, material defects, erosion, equipment failure, annular flow)
2. Design
3. Operations and maintenance
4. Intervention
6. Outside force: natural causes such as weather-related or ground movement
c. Risks and Mitigation Strategies in Underground Facilities
Reservoir integrity issues may be categorized by considering wellbore integrity and subsurface integrity
as separate but interacting categories. (61) Gas or liquids may migrate out of their intended zones even if
wellbore integrity is maintained due to unforeseen pathways in the subsurface, such as confining zone/
caprock sequence failure or seal-bypass events above a producing reservoir. Based on experience with
producing oil and gas and carbon dioxide sequestration fields (62), some of the risk factors that might be
considered in subsurface integrity assessments for underground gas and liquids storage include:
i. Over-pressuring relative to formation or confining zone/ caprock sequence strength;
ii. Frictional stability of major faults in a compartmentalized reservoir;
58
iii. Availability of conduits such as faults, fractures, and stratigraphy that might connect to
freshwater aquifers, storage horizons, or the ground surface; and
iv. Exceedance of specified limits on injected volumes, or pressure in the storage facility,
dependent upon settings and maintenance of surface control equipment, such as safety
valves.
As far as geologic or geomechanical risks are concerned; only confining zone/caprock sequence integrity
was noted in API RP 1171. Additional risk elements related to the geology include stress state determi-
nation, faults, and potential seal-bypass mechanisms.
Mitigation of risks of fluid migration or leakage (through the confining zone/caprock sequence) falls into
several categories.

i. Mitigation strategies for geologic uncertainty of the reservoir, following API RP 1171, include:
1. Collect and review regional data;

2. Collect new data from nearby wells;
3. Acquire new data (seismic, new wells, gas tracer);
4. Establish a buffer zone (vertically and horizontally) for evaluation the regulating or
governing agency;
5. Conduct semiannual tests for inventory verification;
6. Acquire property and mineral rights;
7. Establish observation wells;
8. Inspect older wells that were used in production of hydrocarbons, injection wells
previously used for pressure maintenance or stimulation, or converted to storage; and
9. Inspect plugged and abandoned wells, review records for all wells.
ii. Mitigation strategies for confining zone/caprock sequence failure, following Bruno et al.
(52), involve three areas of risk: (a) the mechanical state, including stress state, reservoir
pressure, and the presence of faults that cut into the confining zone/caprock sequence
from the reservoir; (b) the confining zone/caprock sequence-reservoir system, including
extent, thickness, and depth of reservoir and confining zone/caprock sequence, plus
confining zone/caprock sequence characterization; and (c) operations, including well density
and number of cased vs. uncased wells. These strategies apply to porosity storage and to
salt storage. The basic mitigation strategies developed by Bruno et al (2014) to reduce
the likelihood of confining zone/caprock sequence failure, and thus fluid movement, include:
1. Reservoir pressure: must be less than the fracture pressure (for normal and
strike-slip faulting regimes) and critical pressure of the fault reactiviation of the
confining zone/caprock sequence;
2. Caprock characterization: confining zone/caprock sequences that are thicker than
about 30 meters, strong, low permeability values, homogeneous, and composed of
multiple intercalated sealing lithologies provide the safest barrier zones against
fluid movement from the reservoir;
3. Faults and natural seismicity (63): confining zone/caprock sequences that are cut
by faults, especially those which are close to wellbores, pose greater risk for fluid
movement than those with few to no faults. UGS in seismically quieter areas have
59
a lower likelihood for faults to be reactivated under fluid injection/withdrawal

conditions, permitting larger values of reservoir pressure; and
4. Reservoir thickness and depth: thicker and deeper reservoirs are safer than
shallower ones for confining zone/caprock sequence integrity since these impose
smaller stress and displacement changes onto confining zone/caprock sequence
and overburden.
Pre-existing or abandoned wellbores including previously pressurized or depleted areas, and previously
generated hydraulic fractures should also be considered as risk elements.
In the industry, fluid leakage through the confining zone/caprock sequence is usually mitigated by re-
ducing reservoir pressures and, in extreme cases, closing the storage facility, as damaged confining zone/
caprock sequence in general cannot be repaired. Geologic, geophysical, and geomechanical characteriza-
tion of a UGS site that can inform the mitigation strategies provide the basis for assessing and potentially
reducing the degree of subsurface integrity risk.
d. Rock Mechanics Aspects of Geologic Storage
As described above, there are in general four types of geologic structures used for UGS: depleted oil and
gas formations, aquifers, solution-mined caverns in salt formations, and mechanically mined rock for-
mations. The rock-mechanical properties of each are somewhat different, and these different properties
require consideration for gas storage operation, as well as for the development of regulations to ensure
reliable operation and safety. Depleted oil and gas formations and water aquifers are of similar rock type
and will addressed together as porosity storage. Salt formations used for solution-mined salt caverns
have properties quite different from porosity storage rocks in that the porosity and permeability of salt
are negligible in comparison. Finally, mechanically constructed mines, such as in coal or salt, are consid-
ered as a distinct fourth type of UGS facility.
Two of the principal properties of rock that are of vital importance to underground storage of natural gas
are porosity and permeability. These concepts are defined as follows and illustrated in Figure 7-2:
Porosity – Rock is composed of solid materials, grains, and pore space, as illustrated in Figure 7-2. In
the subsurface, the pore space is filled with gas (e.g., air or natural gas) or liquids (e.g., oil or water). For
example, the pore space in typical oil and gas formations is filled with pressurized oil, natural gas, and
brackish/ saline water. The pore space fluids are pressurized due to depositional and geochemical pro-
cesses. Porosity is the ratio of the pore space to the total volume of rock, usually expressed as a percent-
age. For the purposes of UGS, higher porosity means greater volume of gas that can be stored. Table 7.2
summarizes the porosity of some rock types.
Permeability – Permeability is the measure of the ability of a fluid to flow through rock. For a rock to be
permeable, it must have not only pores, but the pores must be connected to provide a path for flow. This
property is also indicated in Figure 7-2.
With regard to Table 7-2 and UGS, there are two important points to be considered with regard to porosity
and permeability. First, porosity governs the volume of gas or liquid that can be stored in a porous rock
formation. The total volume of a porous rock formation that can be used for storage is dependent on the
thickness of the formation, its lateral extent, and the deformability (i.e., compressibility) of the formation.
Sandstone has an obvious advantage over salt for porous rock storage, based on porosity. On the other
hand, salt is soluble in water, and sand is not. So, to create volume in salt for storage, a well is drilled into
60
Rock type Porosity - % Permeability - Darcy

Sandstone 10 – 30 0.1 – 5.0
Salt 0.01 – 1.0 10-22
Table 7-2: Typical ranges of porosity and permeability of UGS rocks (64)
Figure 7-2: Cross section of porous and permeable rock
a salt formation, concentric tubing strings are installed in the wellbore, freshwater is pumped into the
inner tubing, and brine is produced from the annular space between the concentric tubing strings. This
process is called solution mining. Large caverns can be created to store gas or hydrocarbon fluids using
solution mining methods, as much as 2,000 feet tall and 350 feet in diameter.
Second, permeability governs how easily gas and liquid can flow through a rock formation. Sandstone has
a much greater permeability than salt (assuming a small to modest degreee of diagenesis and cementa-
tion between the grains), so gas can flow or migrate very quickly and for large distances in sandstone. On
the other hand, since salt has such a small permeability (i.e., it is almost impermeable), gas cannot flow
through it and thus salt can be used to trap gas in a cavern.
Though salt may be considered to be nearly impermeable, and thus ideal for hydrocarbon storage, it is
known that salt domes or beds may not be perfectly homogeneous. Salt bodies may include discrete thin
zones of higher permeability than the bulk of the salt body, such as splines, clay layers, and faults. Thus,
in preparation for hydrocarbon storage design, careful geological investigations should be conducted.
61
To give some physical meaning to the storage space comparing solution-mined caverns in salt and
sandstone depleted oil and gas reservoirs, consider the results of some realistic examples. An ideally
shaped cylindrical solution-mind cavern could be 2,000 feet tall and 300 feet in diameter, which results
in a storage volume of 141,371,669 cubic feet. Now, considering the pore volume of the same cylinder
2,000 feet tall and 300 feet, but in sandstone with 20 percent porosity, the storage volume would be only
28,274,334 cubic feet. But, a hypothetical depleted sandstone formation 300 feet thick, but with a diam-
eter of 2,000 feet would have a pore volume for storage of 188,495, 559 cubic feet. In fact, the idealized
diameter of a typical depleted formation may be many times larger than 2,000 feet, and in fact may
sometimes be as large as 20,000 to 40,000 acres in size; so depleted formations can have a much greater
volume than a single cavern.
Two important operational volumes in UGS of gas are the working and cushion volumes. Cushion gas, or
pad gas, is the volume of gas that must remain in a cavern or in the pore space at all times. The reservoir
pressure support provided by the cushion gas serves two purposes. First, the pressure support permits
the storage field to have deliverability high enough to meet its design day market requirements fairly
late into the withdrawal season. Second, cushion gas also provides enough pressure support for average
day deliverability to be high enough to permit the working gas volume to be withdrawn in a relatively
short period of time, i.e. typically the 5-month winter season for most reservoir and aquifer storage and
shorter periods of time for salt cavern storage. The volume of cushion gas makes it easier to withdraw
gas during withdrawal periods. Cushion gas is also required to maintain the structural stability of a
solution-mined cavern, as will be explained below. The working gas volume is the volume that is storage,
which is injected and withdrawn over time.
e. Pore Storage Considerations in Depleted Formations
The advantages and disadvantages of porous rock formations, such as depleted oil and gas reservoirs and
aquifers, are summarized in this section.
i. Reservoir characteristics
A schematic cross section of a depleted oil and gas formation is shown in Figure 7-3.
Depleted reservoirs originally contained and produced oil, natural gas or both. The
reservoir rock itself must have sufficient porosity and permeability to allow the gas to be
easily pumped into the rock and migrate through the reservoir in the first place, and the
easily allow withdrawal of the stored gas when needed. Injection and withdrawal cycles
can take place as many as five times per year. Higher quality depleted reservoirs, those
with high porosity and permeability, also have lower cushion gas requirements. Depleted
oil and gas formations are generally the least expensive to develop, operate and maintain.
The factors that determine whether or not a depleted reservoir will make a suitable storage facility are
both geographic and geologic. Geographically, depleted reservoirs must be in a location with access to a
customer market, either residential, commercial, industrial, or a combination. The facility should also be
close to pipeline and transmission infrastructure.
ii. Vertical and lateral confinement

To ensure containment within a depleted reservoir (a requirement for any gas storage
facility) there must be an impermeable cap rock/ confining zone above and either structural
or stratigraphic containment on the flanks of the formation. A competent overlying cap
rock (the confining zone/caprock sequence) is required to seal the storage formation
62
Figure 7-3: Depleted hydrocarbon formation storage

Source: http://www.gwpc.org/sites/default/files/event-sessions/Alleman_Nathan.pdf
and prevent vertical fluid movement. Preventing or minimizing horizontal fluid movement can be a more
difficult challenge, particularly for stratigraphic trap type fields. Monitor wells are placed strategically
at the perimeter of the field, with the pressure monitored and the composition of the gas checked from
samples. In some cases, faults might be considered geological horizontal barriers, but faults are often not
always impermeable, (65) and may be activated as leakage pathways under sufficiently elevated stresses
or reservoir pressures. In other cases, geological pinch-outs can serve as a boundary.
iii. Operating pressure design

In order to maintain pressure in depleted reservoirs, up to about 50 percent of the natural
gas in the formation must be kept as cushion gas. Depleted natural gas reservoirs require
less injected cushion gas because some native gas still remains. Operating pressures are
customarily dictated by the fracture strength of the formation rock and the pressure
integrity of the casing shoe. Gas migration may also be a consideration in establishing the
maximum storage pressure, since the rate of gas flow in a porous and permeable formation
increases with increasing storage pressure.
The MAOP should be determined after a thorough analysis of a variety of factors including
the rock fracture strength (or the fracture gradient) and critical frictional strength of any
nearby faults at the bottomhole location, the water gradient, initial formation pressure,
caprock seal integrity, geomechanical testing, and other considerations. The pressure
63
required to inject intended gas volumes, particularly at total inventory, should be limited
by reservoir rock strength, well integrity, wellheads, piping, or associated surface facilities.
The minimum reservoir pressure should not be less than historic minimum operating
pressure, unless reservoir geomechanical competency can be demonstrated. The impacts
of intended minimum reservoir pressure should be accounted for in a regional review of
the geologic formation as it relates to geomechanical stress, subsidence, reservoir liquid
vertical influx as gas is withdrawn, surface facility gas cleaning and liquid handling, and
liquid disposal, all of which affect the maximum cycling capacity of the storage field and
can impact mechanical integrity of the facilities. (10)
f. Pore Storage Considerations in Aquifers
As summarized in API RP 1171, (10) if depleted hydrocarbon reservoirs are not present in a geographic area
where storage is desired, aquifers exhibiting the qualities of a hydrocarbon reservoir may be utilized.
Aquifer reservoir storage dates back to 1946. (10) As of 2015, there were 51 operating aquifer storage
reservoirs in the U.S. and Canada representing over 2,300 reservoir-years of operation, with a maximum
inventory capacity of 1.3 trillion cubic feet, accessed and monitored by more than 2,600 wells.
Aquifer reservoirs are similar to depleted hydrocarbon reservoirs in terms of the nature of the porous
rock media used to contain the gas and the methodology for assessing the reservoir. The storage suitability
of an aquifer reservoir requires careful investigation on an individual basis, using a number of means to
evaluate reservoir integrity, well integrity, and existing fluid chemistry.
i. Reservoir characteristics
As shown schematically in Figure7-4, aquifer storage is similar in many ways to depleted
hydrocarbon storage. Aquifers are underground porous and permeable rock formations that
act as natural water reservoirs. Some quifers can be used as natural gas storage facilities.
As they are more expensive to develop than depleted reservoirs, these types of storage
facilities are usually used only in areas where there are no nearby depleted reservoirs.
Traditionally, because of the requirement to fill slowly while pushing water back, these
facilities are operated with a single winter withdrawal period.
Aquifers can be the most challenging and most expensive type of natural gas storage facility for a number
of reasons. First, the geological characteristics of aquifer formations are not as thoroughly understood
when compared with depleted reservoirs because of lack of history that includes site characterization
(e.g. drilling and production logs). A significant amount of time and money goes into discovering the
geological characteristics of an aquifer, and determining its suitability as a natural gas storage facility.
Geophysical testing must be performed, similar to what is done for the exploration of potential natural
gas formations. The area of the formation, the composition and porosity of the formation itself, and the
existing formation pressure must all be characterized prior to development of the formation. In addi-
tion, the capacity of the reservoir is unknown, and may only be determined once the formation is further
developed. Lastly, confining zone/caprock sequences that would promote gas containment may be of
unacceptably poor quality (e.g., thin, fractured, or even absent; Bruno et al.). (52)
In aquifer formations, cushion gas requirements average about 70 percent of the total capacity and can
be as high as 90 percent. While it is possible to extract cushion gas from depleted reservoirs, doing so
from aquifer formations could have negative effects, including loss of effective permeability. As such,
most of the cushion gas that is injected into any one aquifer formation may remain unrecoverable, even
64
Figure 7-4: Aquifer storage

after the storage facility is shut down. Most aquifer storage facilities were developed when the price of
natural gas was low, meaning this cushion gas was not very expensive. When gas prices are higher, aquifer
formations are increasingly expensive to develop.
ii. Vertical and Lateral Confinement

The lateral and vertical confinement is essentially the same as depleted oil and gas formations.
Vertical confinement may be more challenging in part because aquifers are generally shall lower.
iii. Operating Pressures

The basis for operating pressures for aquifer storage is essentially the same as for depleted
hydrocarbon formation, since the rock type is usually similar (i.e. sandstone). Aquifers are
generally shallower than depleted hydrocarbon formation, thus requiring some
additional considerations. Aquifer storage reservoirs operate at pressures above and
below the pressure of the water in the aquifer, resulting in potential water efflux and
influx, and changing gas reservoir size. Therefore, semiannual surveys, which are essentially
the summer and winter time frames, may not be effective in inventory assessment (some
states, such as Louisiana, require quarterly assessments of solution-mined caverns). In
addition, extended shut-in periods, whether at high or low inventory levels, result in
changes in the reservoir volume that could be detrimental to the reservoir’s operation. (10)
65
g. Salt Cavern Storage Considerations
Construction of the first solution-mined salt caverns in the U.S. created specifically for the storage of nat-
ural gas began in the Eminence Salt Dome in Mississippi in the late 1960s by Transcontinental Gas Pipe
Line. (66)
i. Geological characteristics
As shown schematically in Figure 7-5, salt caverns are located in underground salt formations
either in salt domes or in salt beds. The caverns are typically solution mined by injecting
fresh water through a well drilled into the salt, dissolving the salt into brine with the fresh
water and withdrawing the resulting brine for disposal in underground rock formations
near the salt cavern. The produced brine is frequently used commercially as feedstock in
chemicals manufacturing.
Essentially, salt caverns are formed out of existing salt deposits. These underground salt
deposits may exist in two possible forms: salt domes and salt beds. Costs for salt dome-
based caverns are typically lower than the development costs for bedded salt-based
caverns; usually due to the size of the caverns (caverns in salt domes are typically larger
than caverns in bedded salt).
Figure 7-5: Solution mined caverns in salt dome (left) ; bedded salt formation (right)
66
Salt cavern storage facilities are primarily located along the U.S. Gulf Coast, as well as in
the northern states. Salt cavern storage is well suited for peak load storage since the gas
can be quickly withdrawn compared to depleted porous formations. Salt caverns can
readily begin flowing gas on as little as one hour’s notice, which is useful in emergency
situations or during unexpected short term demand surges. There are significant cost
and schedule advantages to using suitable existing caverns for gas storage rather than
solution minig new caverns specifically designed for gas storage . As discussed earlier in
this chapter, salt caverns are typically much smaller than depleted gas reservoirs and
aquifers. Thus, salt caverns generally cannot hold the volume of gas necessary to meet base
load storage requirements. However, deliverability from salt caverns is typically much higher
than for either aquifers or depleted reservoirs, so caverns can accommodate more frequent
withdrawal and injection cycles.
Salt domes: Salt domes are thick formations created from natural salt deposits that, over
time, flow up through overlying sedimentary layers to form large dome-type structures.
They can be as large as a mile in diameter, and 30,000 feet in height. Typically, salt domes
used for natural gas storage are between 1,000 and 2,500 feet beneath the surface, al
though in certain circumstances they can exist much closer to the surface.
Salt beds: Bedded salts are shallower, thinner formations. These formations are usually
no more than 1,000 feet in height and are commonly composed of multiple thin layers.
Because salt bed are wide, thin formations, once a salt cavern is introduced they are more
prone to deterioration, due to potential flexure of the roof of the mined cavern. (52)
ii. Vertical and lateral confinement

Lateral confinement of gas within a solution-mined cavern is governed by the low
permeability of salt. Careful geological investigations are required, however, to determine
the presence of anomalous high-permeability layers or stringers. Vertical migration is
governed by the overlying cap rock, which may be composed of anhydrite, gypsum, and
calcite cap above many salt domes that is formed by consolidation, cementation, and
alteration of insoluble residue left by salt dissolution. In domal salts, which are created by
the upward deformation of salt formations, the cap rock may be fractured, thus cap rock
must be adequately characterized in detail, and a wellbore penetrating the cap rock may be
difficult to cement efficiently. (52)
iii. Operating pressure design

As compared to reservoirs or aquifers, salt caverns offer high rates of injection and with-
drawal relative to the amount of working gas capacity. The result is that the working gas
capacity in salt caverns can be cycled many more times than either reservoirs or aquifers,
typically in the range of 12 annual cycles of working gas capacity. Salt caverns also require
less cushion gas; usually 20 percent to 30 percent of the facility’s working gas volume, as
compared to depleted formations.
The MAOP is based on the fracture pressure of the salt at the casing shoe. But geomechanical
analysis should also be used as a basis for determining possible microfracturing of the salt
under high cavern pressure.
67
The minimum pressure in a storage operation is dictated by the creep closure of the cavern.
The minimum pressure is specified to minimize surface subsidence and creep closure.
Creep closure and cavern roof deformation (sagging) can result in high stress and strain
on wellbore casing strings, which should be considered in cavern operations, including
long term shut in, operating cycles, and abandonment. (67)
iv. Geomechanical Modeling

Geomechanical modeling is the analytical or, numerical or computational modeling of
geologic materials to predict and understand deformations and loads due to changes
in stress or fluid pressure on rocks or soils. A rich literature exists on this topic. In the
context of UGS, geomechanical modeling is used to assess the stability of caverns in solution-
mined salt caverns, and the deformation of depleted formations and their caprock/
confining zone sequences. Cyclic deformation and stresses during injection and withdrawal
cycles can cause undesirable loads on wellbores, which can affect overall integrity of the
storage system. Currently, there are no specific state regulations or requirements for
geomechanical modeling of UGS facilities. PHMSA, however, has recently promulgated
regulations on UGS which incorporate by reference API RP 1170 and API RP 1171, which
may make geomechanical modeling of UGS facilities mandatory, at least regarding solution
mined caverns in salt. Some considerations of geomechanical modeling of UGS include:
1. Salt Cavern Storage Considerations: Sections 5.4 and 5.5 of API RP 1170 address
geomechanical site characterization and numerical modeling for gas storage in
caverns solution mined in salt. Section 5.4 covers the types of core tests and their
results that are recommended for characterizing the behavior of the salt, and the
quantitative results recommended as input into numerical geomechanical models.
Section 5.4 provides recommendations for numerical geomechanical modeling:
“The structural stability and geomechanical performance of natural gas storage
caverns in salt should be assessed using numerical models that represent the geometries
of the caverns, their development history and operating conditions during gas storage,
the geologic structure around the caverns, the mechanical properties of the salt and
nonsalt units, and the preexisting in-situ conditions. In particular, the numerical models
should simulate the time-dependent creep deformation that is distinctive of rock salt
and other evaporites.” RP 1170 states that the geomechanical model should be
of sufficient detail to produce results to judge the structural stability and mechanical
integrity of a cavern during gas storage operations, such as cavern shape and size;
cavern proximity to other caverns and the edge of the salt deposit; depths of casing
seat, roof, and floor; wellbore and cavern roof design; minimum and maximum
storage pressures and cycling; and estimation of surface subsidence.
API RP 1170 does not provide recommendations for the type of geomechanical
method to be used, but in general the published literature includes the numerical
approaches as explicit or implicit finite element methods, and the finite difference
method. Whichever method is used, it is important that the method include a verified
constitutive model for creep behavior of the salt (e.g. with values determined by
the laboratory tests on salt from the cavern). An example of such geomechanical
modeling for UGS in solution mined salt caverns, which includes references to
other similar geomechanical methods, is given in Hilbert and Saraf. (67) Analysis
for a bedded salt deposit is presented in Bruno. (52)
68
2. Depleted hydrocarbon formations and aquifers: API RP 1171 for gas storage in
depleted hydrocarbon formations and aquifers does not include any recommen-
dations for geomechanical modeling. Geomechanical modeling for storage in
depleted formations may be considered to determine stresses on wellbores,
potential shearing of wells due to slip on faults or at geologic unconformities, and
surface subsidence or heave during injection and withdrawal cycles. For UGS in
nonsalt porous rocks the methods and techniques are similar to the techniques
used for reservoir modeling in the upstream oil and gas industry. An example of a
geomechanical computational model for UGS can be found in Teatini et al. (68)
69
Chapter 8
Injection and Withdrawal Well Operations and Maintenance
Introduction
Gas storage wells and fields require proper operations, practices, and regular maintenance and assessments
to ensure integrity and intended use throughout all stages of life – from start of initial testing, injection
and withdrawal from storage, up to final plugging and abandonment. Since each gas storage field and its
wells are different, general processes are covered here that apply across all fields and wells. Recently
formulated and earlier documents covered proper operations practices and regular maintenance, and
they are referenced here with additional suggestions.

In porosity storage, gas storage wells often are converted former oil and gas producing wells, and whether
converted or newly drilled and completed, these dedicated storage wells will have extended lives. Long-
term well integrity and functionality depend upon proper field and well operations and maintenance,
including changes in the reservoir, fluids, rates, stimulation, remedial work, offset drilling, and surface
conditions and parameters. Essential continual monitoring of current conditions, and comparison versus
designed and expected future conditions, will indicate the integrity and functionality issues during
facility and well life. Accordingly, monitoring, access and control need to be implemented at all times and
under all conditions.
LPG salt cavern storage wells have significant differences in operation compared to natural gas storage in
porous reservoirs. LPG salt cavern storage well systems have a brine side and a product side to the operation.
These systems are kept separate for safety and environmental considerations. Brine is injected into a
tubing string to displace product out the annulus and when product is emplaced into the cavern, the dis-
place brine is then retained and stored in surface impoundments or injected into another formation.
The brine storage impoundments can be designed to prevent leakage which can result in contamination
of the environment. Safety equipment such as gas separators directed to flares should be used to handle
any LPG that enters the brine system. Gas detectors may also be deployed around the perimeter of the
impoundment as an added safety feature. One should be concerned with the containment not only of the
LPG, but also the brine.
Hard rock cavern storage relies on geomechanical stability which can be addressed by the appropriate
geomechanical analysis techniques. (2) The main issues and concerns with hard rock cavern storage are:
• Roof collapse;
• Pillar collapse; and
• Surface subsidence.
Main Take-Aways
• Gas or liquids can leak or migrate from an underground storage facility of any type, if
wellbore integrity is compromised, even when reservoir or cavern integrity is maintained.
• Well maintenance, operations, and well integrity can vary considerably between the
different types of reservoirs.
70
• Well workovers and operations can be conducted to evaluate or restore functional

mechanical integrity of a wellbore and should be accomplished to ensure well integrity.
• Periodic well integrity testing is an important tool for operators to assess the changing
functional integrity of downhole and wellhead assets. Testing methods discussed are:
annular pressure monitoring and casing inspection. Frequency of integrity re-assessment
should be driven by the operator’s risk assessment procedure as discussed in Chapter 3.
• Operators should establish standard operating procedures for well reporting, and compli-
ance with State and Federal agencies.
Well Operation and Maintenance

a. Long Term Well Integrity
i. API RP 1170 and API RP 1171 – Guidelines established in API RP 1170 and API RP 1171
may be used by gas storage operators wherever these API RP are applicable to natural gas
storage wells and facilities.
ii. Minimum and maximum operating pressure –
1. Operators determine the maximum and minimum operating pressures each gas
storage well and each gas storage facility component will be subjected to during
the well or component lifetime. A starting point for maximum operating pressure
analysis is a field’s discovery pressure. If an operator chooses to operate the facility
above the discovery pressure then additional reservoir and cap rock analyses are
required to be able to justify safe operations at that pressure level. The minimum
pressure should be established to meet minimum customer deliverability require-
ments, but in no case should the minimum pressure allow for detrimental subsidence
or other integrity complications.
2. The operating pressure range of each well and component, along with the gas
pipeline system demands, should be used in each original design, re-design, and
operational plan.
3. Periodically, the operational plan should be reviewed and confirmed to be applicable
to each well and component. During the operational plan review storage operators
should ensure that operating pressures do not exceed the minimum and maximum
operating pressure at storage well or wellhead.
4. For salt or hard rock caverns, it is extremely important that the maximum operating
pressure gradient remain below the fracture gradient to maintain reservoir or
cavern integrity.
5. When assessing field-wide risks, a probabilistic model is recommended where
the risk can be quantified and maintained within acceptable limits as determined
by physical limitations, regulations and industry standard practices.
iii. Construction (See Chapter 5)
iv. Workovers
1. Major workovers typically include drilling rigs and/or service-type pulling units
that operate in situations where the wellhead christmas tree is removed and
wellbore is accessible for work. If the current wellhead assembly does not allow
for workovers under pressure, the operator should consider installation of a
71
master shut-off valve or snubbing valve on the production casing for additional
well control. Major workovers include:
a) Running or pulling existing casing;
b) Drilling;
c) Running or pulling tubing; and
d) Casing repairs, including:
1) Casing patches;
2) Casing liners; and
3) Remedial cementing;
e) Milling;
f) Fishing jobs;
g) Hydraulic fracturing; and
h) Re-completions.
2. Minor workovers typically are methods conducted through existing completions
(whether the completion has tubing or not), that provide remedial and/or
enhanced well operation. Minor workovers often are performed via workover
rigs, coiled tubing and/or wireline methods, for a variety of purposes, including
but not limited to:
a) Downhole sensor work;
b) Wellbore stimulations (e.g., acid jobs, coil tubing cleanouts, etc.);
c) Casing integrity logs;
d) Perforating;
e) Subsurface safety valve work; and
f) Well cleanouts.
3. Operators should develop standard operating procedures addressing records
retention and key records retained for the life of the storage field.
4. Operator staff and contractors should be appropriately trained for their assigned
tasks and their competency should be periodically reviewed to ensure job proficiency
5. Protection of the public health, safety, property, and the environment must be
taken into consideration when planning a workover. A blowout preventer and/ or
other well control methods are used.
6. Where appropriate the operator should evaluate and implement additional site
security measures while well work is ongoing and equipment is on site.
b. Periodic Well Integrity Testing
i. Annular monitoring
1. The operator should monitor each well annulus that is not cemented to the
surface by placing a valve on the wellhead, and the measurement device should
have an isolating valve between it and the wellhead annulus, so the measurement
device can be removed and/or changed safely and efficiently without disturbing
the well operation. Some contributors to this report advocate for monitoring all
annuli, regardless of whether they are cemented to surface, to identify potential
cementing problems.
2. Annulus monitoring may be by simple visual analog dial measurements and/or
digital remote sensing methods.
3. The operator may also consider the continuous monitoring of all annulus pressures,
establishing SCADA limits and alarms.
72
ii. Casing inspection
1. Operators may use a variety of casing inspection methods and tools to ascertain
an original baseline, and subsequent changes, in casing integrity and condition. A
detailed list of these methods and tools are discussed in Table 6-1.
iii. Inspection and integrity testing frequencies
1. Frequency of casing inspection is based upon the operator’s risk analysis for each
field, area in the field, and well and should be included in the operator’s field and
well operating plan. Regulatory guidelines must also be taken under consideration.
2. The operator will integrate the latest casing inspection results with the design
data for the well in addition to any prior inspection results as part of the current
analysis. Significant changes in a well’s condition or the remaining life of casing
will be further investigated.
Develop and
Perform Risk
Assessment of
Storage Wells
Create Baseline
Assessment
Schedule
Perform Well
Integrity Inspections
Analyze Integrity
Well Data and
Compare to Risk
Assessment Model
Perform Well
Immediate Repairs
Workover and Y
Required?
Complete Repairs
Update Risk
Assessment with
Integrity Inspection
and/or Workover
Data
Well Re-Assessment
Based on Updated
Risk Model
Figure 8-1: Flowchart of casing inspection frequencies based on risk assessment

3. Frequency of casing inspection is included in the operator’s field and well operating
plan, based upon the risk analysis in item 1 above. Regulatory guidelines must
also be taken under consideration. The flowchart shown as Figure 8-1 can be
utilized by regulatory agencies to determine if an operator’s re-assessment schedules
follow risk management principles and are reasonable:
1. Based on operator’s threat and risk assessments wells can be inspected at

different frequencies. Wells that have more redundant safety features
should lower the overall well risk and therefore can have longer re-assess-
ment intervals. Some redundant safety features are listed below:
a) Annular pressure monitoring via SCADA;
b) Production casing cement to surface;
c) Casing, packer, tubing design;
d) Established corrosion rate estimate;
e) Surface or sub-surface emergency shut-off valves;
f) Well’s isolation from populated areas; and
g) Other factors that may be identified
2. As general guidance casing inspection re-assessment frequencies are
determined based on the operator’s risk assessment procedure and the
information derived from baseline evaluations.
a) For re-assessments greater than 15 years substantial safety features
and remaining life on the casing should be calculated using the
established well corrosion rate from previous inspections.
iv. Volume, rate, pressure monitoring
1. Each well should have a method of estimating or measuring the injection pressure
and withdrawal/production rates from the well.
2. Monitoring of each well’s injection and withdrawal/production rates and pressures
may be done by methods which do not disturb normal operations.
3. Measurement sensors are calibrated with accuracy, resolution and repeatability
metrics that are appropriate for the expected measurement ranges within well
and environmental conditions and during extended testing and/or operating periods.
4. The operator may also consider continuous monitoring of injection/withdrawal
pressures.
v. Subsurface leak detection
1. Subsurface leak detection may include various singular or combined methods

based upon the operator’s risk analysis and operational plan.
2. Changes in a well’s surface and/or downhole measurements may indicate a wide
range of conditions, and measured changes may or may not be attributable to
subsurface gas migration.
3. The operator should use a variety of measurements from each well suspected of a
downhole leak, and combine information from adjacent and similar wells within
the field area and zones of interest to decide which further investigative methods
well be applicable to diagnose whether and where a downhole leak is occurring.
As needed integrity assessment tools as described in Table 6-1 can be deployed to
identify the wellbore leak.
74
vi. Subsidence and cavern storage
1. Surface subsidence occurs when the surface of a well or group of wells, or established
monuments, subside below a baseline surveyed elevation. Subsurface caving or
formation collapse may or may not manifest itself by surface subsidence or by sink-
hole formation.
2. Wellbore and reservoir integrity may be affected by subsidence.
3. Operators should monitor wellheads, well locations, and established monuments
for any indication of subsidence, and if subsidence is indicated, measure the rate
at which subsidence is occurring over field operating cycles and external conditions,
and compare any measurements against the risk analysis and operational plan
which should include established standards.
4. Various analytical methods developed to analyze subsidence data may be utilized
to evaluate subsidence. These methods can include graphs of elevations versus
time and field subsidence rate maps.
5. Consideration should be given for all cavern storage facilities to establish surface
survey loops and conduct a monument grid survey on an annual basis to detect
ground surface movement. All wells should be included in the monument grid
network. The frequency of the subsidence surveys should be based on the operator’s
experience and as required by regulations.
vii. Inventory tracking
1. Operators can calculate base/pad gas storage volumes and monitor injections
and withdrawals/production continually. That information can be evaluated using
periodic inventory reconciliations, and analyses can becompared to measured data.
2. Cavern operators should monitor injections continuously with periodic inventory
reconciliations, such as resetting the inventory in the cavern based on emptying
or by wireline measurement referencing the most recent sonar survey.
3. For depleted reservoirs semi-annual shut-in tests should be performed to verify
storage inventories as recommended in API RP 1171.
4. Operators can further analyze apparent anomalies when mass balance and other
calculations vary from expected data.
c. Periodic Wellhead Inspections
i. Refer to Section 12.b.vi-vii for information on wellhead inspections.
d. Periodic Wellsite Inspections
i. Operators should create periodic wellsite inspection procedures following API RP 1171
Section 10.5 (10) to verify the functional mechanical integrity of natural gas storage wellsites.
1. Such procedures may include:

(a) Reason for the inspection;
(b) Identification of operation personnel and training requirements;
(c) Directions to conduct the inspection;
(d) Frequency of the inspection;
75
(e) Reassessment of hazards and potential threats; and,

(f) Documentation, reporting, and recordkeeping requirements.

The operator may choose to combine wellhead and wellsite inspections into a single procedure.
e. Maintenance Requirements and Schedules
i. Operators should include a maintenance schedule in the field operational plan.
ii. Maintenance requirements are based upon the operator’s risk analysis for the field, each
field area, and each well based upon the risk factors, well and wellhead design, and historical
experience operating the facility, wells, and equipment.
iii. Maintenance schedules are based upon the frequency with which wells and wellhead
components require work, and all maintenance should be regularly recorded and tracked
for risk analysis reviews.
iv. Records are typically maintained for the life of the facility.
f. Water Wells
i. Gas storage fields may also have water wells drilled and completed for various purposes,
including water source and monitoring.
ii. Operators may include water well operation and maintenance in their field operating
plan with the same or similar considerations as included herein for gas storage wells.
iii. For aquifer storage facilities all water wells that see some gas pressure throughout the
year should be designed according to Chapter 5 guidelines.
g. Well Reporting and Compliance
i. Reporting requirements
1. Operators can centrally record all measurements and analyses performed across
field operations, including injections, withdrawals/production rates and volumes,
pressures, maintenance, conditions, and other.
2. Operators may periodically analyze the reported data for trends, issues, risk analyses,
and reporting to outside agencies and organizations as appropriate.
ii. Compliance schedule
1. Operators should be familiar with all regulatory requirements, agencies, and other
outside organizations’ required information and dates for proper reporting compliance.
2. Operators should have a written procedure for proper and timely reporting to
government and outside organizations.
76
iii. Agency notification and approval of changes to wells/operations
1. Operators should have a written procedure for proper and timely reporting to
regulatory agencies of any required notices and requests for approval when required
for changes to wells/operations.
2. Operators are advised to keep a written record of all notifications and approval
requests and responses from agencies.
h. Procedures, Training, and Record Retention
i. Operators should create a storage operation and maintenance procedure manual and an
operator qualification program for UGS injection and withdrawal well activities. For cavern
storage operators refer to API RP 1170 Section 9.7 for details. For porosity storage operators
refer to API RP 1171 Section 11.
77
Chapter 9
Introduction
Monitoring and observation wells associated with the underground storage of gas have been utilized by
the gas storage industry for a many years. One purpose for the construction of these wells is to monitor
for the potential horizontal and vertical migration of storage gas. These wells can be the first evidence of
potential issues with gas storage reservoir integrity. The placement of these wells is of high importance
to ensure adequate monitoring of the gas storage reservoir is accomplished. The use of and type of obser-
vation wells vary greatly with each storage project, and some storage projects may not require them.

Addressing physical surface location placement, proposed depths, and geological considerations are major
issues and concerns regarding monitoring and observation wells associated with gas storage facilities.
A geologic formation selected for monitoring must have sufficient porosity and permeability to ensure
monitoring is feasible. Locations and spacing of monitoring wells should be based on the geology and
hydrogeology, including but not limited to flow paths, flow directions, and formation pressure gradients.
Depth considerations of these wells can be critical and placement of some monitoring wells needs to
be within the first porous and permeable zone directly above the gas storage reservoir. Monitoring or
observation wells being considered for placement directly into the geologic formation(s) utilized for gas
storage can be limited to the buffer zone (which is established outside of the delineated gas storage field)
to potentially detect additional pathways of gas migration out of the gas storage reservoir within the storage
field. The use of and need for observation wells may be determined as part of the risk assessment for
each new gas storage project.
Main Take-Aways
• Observation and monitoring wells serve as the early detection and warning system for gas
storage reservoir integrity; and for LPG storage, they can also serve to monitor the integrity
of the brine system, including brine storage ponds.
• Placement of these wells both on the surface and in the correct subsurface geologic zone is
critical to the success of an observation/monitoring well program.
• Proper well construction, integrity, and monitoring are important aspects of these wells.

a. Reasons and Justification
i. Monitoring and observation wells serve as an early detection and monitoring system for
identifying potential gas migration and reservoir integrity issues. These wells can be
utilized to establish baseline conditions and allow for monitoring of gas, and liquid conditions
and changes. Groundwater monitoring wells can also be used to detect changes in
groundwater quality that could be indicative of contamination.
78
ii. Strategically placed observation or monitoring wells in the vicinity of reservoir spill
points, within an aquifer, and above the confining zones in porous and permeable formations
should be installed and monitored to detect the presence or movement of gas or LPG.
Observation wells can be placed above, below, or laterally within the gas storage reservoir
depending upon the geology of each gas storage project. (10) These wells need to be
placed within porous and permeable geologic formations capable of being monitored. The
location and design of observation and monitoring wells should take into consideration
(16) the following:
1. Location relative to the storage zone. Monitoring wells located within the storage
zone that are suitable for monitoring reservoir pressure, can be considered but
should be placed within the buffer zones in order to limit artificial penetrations
within the gas storage field reservoir;
2. Potential migratory paths from the reservoir to another formation;
3. Fluid interface monitoring at the location of the reservoir spill point;
4. Permeable zones and stratigraphic traps above the storage zones; and
5. Low-permeability zones, formations or fields adjacent to and in communicatio

with the storage zones.
iii. Gas analysis from observation wells may provide proof of the arrival of storage gas when
the hydrocarbon, inert gases, and/or isotopic composition of the storage gas is noticeably
different than that of the native gas.
iv. Monitoring wells completed in aquifers to determine groundwater quality should also be
considered where appropriate. Groundwater monitoring at LPG storage operations
should include placement and monitoring around the brine storage impoundments.
These wells should be sampled initially for baseline fluid chemistry and then sampled
periodically using a set of chemical parameters (including chloride), to determine if
changes in groundwater quality have occurred.
b. Well Construction
Perhaps the most critical aspect of any well drilled within a gas storage field is an appropriate well con-
struction plan. Observation and monitoring wells should consider:
i. A well construction plan designed to ensure proper placement of well casing, cementing,
and completion practices. It should provide for adequate safety, monitoring and sampling.
It should also provide for the zonal protection and isolation of other reservoirs and aquifers
intersected by each monitor and observation wellbore per regulatory requirements;
ii. Appropriate testing protocols that can demonstrate the well integrity;
iii. In salt cavern construction, use of salt saturated cement through salt zones when cementing a
casing string set into the salt. A mule shoe and weep hole should be located a minimum of
one foot above the bottom of the brine tubing to assist in the early detection of overfilling
the cavern with product; and
79
iv. Well construction of shallow monitoring wells in gas storage fields utilized for groundwater
monitoring and baseline sampling needs to be as stringent as the deeper, observation
wells. Construction, must meet minimum jurisdictional requirements and approvals.
c. Monitoring Type and Frequency
After initial observation or monitoring well completion and baseline recording and/or sampling have
been accomplished, development of a monitoring, recording, and sampling plan needs to be undertaken.
This plan should consider:
i. Analysis for hydrocarbon, nonhydrocarbon gases, and/or isotopes.
ii. Monitoring of pressure changes and fluid-levels. Sampling should be considered on a

case-by-case basis by the regulatory agency as necessary.
iii. Criteria for measurement sensors. Sensors may be located at the surface and/or downhole,
with calibrated accuracy, resolution, and repeatability per manufacturer’s specifications
that is sufficient for the expected measurement ranges within well and environmental
conditions during extended operating periods;
iv. Monitoring and sampling frequency. The frequency of monitoring should take into account
seasonal variations, and may change over time as the storage field transitions from activation to
the mature stage.
d. Reporting Requirements and Alarms
Significant changes in pressure or the migration of gas into the monitoring or observation well borehole
indicating a potential loss of gas storage well or reservoir integrity should require an immediate notifica-
tion to the appropriate company representatives and to the appropriate regulatory agency or agencies.
Additional observation or monitoring well reporting requirements for the presence of gas, pressure
and fluid-level monitoring, and groundwater sampling should be developed cooperatively between the
regulatory agency or agencies and the gas storage operator prior to installation. Additionally, real-time
electronic monitoring on observation or monitoring wells at the surface should be considered and should
utilize alarms set for significant changes in pressure or presence of gas at the lower explosive limit (LEL)
beyond the original baseline readings.
e. Observation Well Operations and Maintenance
i. Operations should refer to the relevant recommendations from Chapter 8: Injection and
Withdrawal Well Operations and Maintenance, to ensure functional mechanical integrity
of observation wells located in gas storage zones. Relevant areas are:
1. 8.a.ii.1: Minimum and maximum operating pressure;

2. 8.a.4: Workovers;
3. 8.b.i: Annular monitoring;
4. 8.b.ii: Casing inspection;
5. 8.b.iii: Inspection and integrity frequencies;
6. 8.b.v: Subsurface leak detection;
7. 8.b.vi: Subsidence and cavern storage;
8. 8.c: Periodic wellhead inspections;
80
9. 8.d: Periodic wellsite inspections;

10. 8.e: Maintenance requirements and schedules;
11. 8.g: Well Reporting and Compliance; and,
12. 8.h: Procedures, Training, and Records Retention.
81
Chapter 10
Wellhead and Surface Facilities
Introduction
The surface equipment at gas storage wells is the interface between the wells themselves and the compressor
and pipeline systems used to transport the gas offsite. The handoff point between gas storage agency
jurisdiction and pipeline agency jurisdiction may vary from state to state and even within facilities. Opera-
tors should work with oil and gas agencies to clearly delineate this point at each facility, and agencies may
consider establishing MOUs with sister agencies to manage regulatory overlap and gaps. This report’s scope
focuses on the wellhead itself, the various valves and monitors found on the wellhead, the physical interface
between jurisdictions (often a pipeline isolation valve), and surface leak detection related to the wellhead.

Properly designed and functioning wellheads efficiently direct gas flow while providing operators with
information about subsurface well integrity and preventing unintentional gas leaks at the surface. Designs
consider issues like appropriate pressure ratings, valving, ability to perform workover and maintenance
operations under pressure, pressure monitoring devices, emergency safety systems, and leak detection.
Considerations include which systems to require, what kind of maintenance is appropriate, and what
information should be reported to the regulator.
Main Take-Aways
• Wellhead configurations depend on a variety of factors, but there are manufacturing and
testing standards for each component.
• The use of safety devices depends on well architecture, risks intrinsic to each well’s history
and location, and regulator risk tolerance with respect to safety and environmental
considerations.
• Special attention should be paid to the point of regulatory handoff between the agency
regulating the well and the agency regulating the pipeline network to ensure seamless
regulatory coverage and cooperation
• Pressure monitoring is a common method for determining overall well integrity; regulators
should consider appropriate measurement frequency and reporting requirements based
on well history and other risk factors.
• Surface leak detection technology is rapidly evolving, and can play a role in a comprehensive
leak detection program.
Surface Facilities
a. Overview
This section provides detailed guidance to help regulators develop rules and analyze operator plans
related to wellheads, surface equipment between the wellhead and the point of hand-off to CFR 49 Part
192’s pipeline regulations, pressure management and monitoring, and surface leak detection. The sub-
sections below go into extensive detail on these topics, with cross-references elsewhere in the document
as appropriate. (69)
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b. Wellhead
i. General principles
1. The design criteria for wellheads at gas storage facilities should include, but is not
necessarily limited to:
a) MAOP and maximum flow rate;
b) Number and size of casing and tubing strings;
c) Number and type of valves on the tree assembly;
d) Injection/withdrawal fluids composition;
e) Potential for solids production;
f) Pressure and/or temperature monitoring of annular spaces; and
g) Full bore access for well workovers.
Figure 10-1: Example of a Depleted Reservoir or Aquifer Gas Storage Tubing

and Casing Wellhead Configuration
Source: SoCalGas
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Figure 10-2: Example of a Depleted Reservoir or Aquifer Gas Storage Casing

Injection/Withdrawal Wellhead Configuration
Source: Anonymous
2. Wellhead equipment, fittings, valves, and flanges should conform to API Specification
6A, (18) and should be rated to a MAOP which exceeds that of the storage field.
The potential for future expansion of the facility to a higher MAOP may also be
considered, if feasible, so that the wellhead remains fit for purpose in the event
of an expansion. Varioustypes of valves may be used as part of the tree assembly,
though typically gate valves or ball valves are the valve of choice because of their
superior sealing capability and resistance to seal failure. The chemical composition
of the injection and withdrawal fluid streams should also be considered. Trace
amounts of CO2 or H2S in the withdrawal stream may result in detrimental effects
to the wellhead internals and seals if the proper service trim level is not specified.
Likewise, the potential for solids production and erosion should be evaluated and
factored into the wellhead selection and design/specification. Full bore opening
valves should also be considered in the design to enable passage of workover
equipment and tools.
3. Other design criteria must also be considered. For example, the potential for
hydraulic fracturing of the well, the use of surface and/or subsurface safety
valves, whether downhole chemical injection may be necessary, and for cavern
wells, the use of different wellheads for solution mining versus gas storage.
Representative wellhead configurations for porosity storage reservoirs are shown
in Figures 10-1 and 10-2. Figure 10-1 illustrates an example wellhead configuration
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of a depleted reservoir or aquifer gas storage well where injection and withdrawal
would be possible through both the production tubing and production casing.
Figure 10-2 illustrates a wellhead configuration where injection and withdrawal
would be done through the production casing.
4. API Guidance Document HF1, which provides guidelines for well construction and
integrity, may be referred to if the gas storage well may undergo hydraulic fracturing
during its life cycle (regulators may also be interested in API RP 100-1, which is
an update of HF1). (69) If subsurface safety valves are determined to be necessary,
the wellhead selection must accommodate passage of the safety valve and provide
porting for safety valve control lines, or other small diameter lines for chemical injection.
5. For cavern wells, the hanging string may undergo potentially damaging oscillation
during periods of de-brining/re-watering the cavern. Accelerometers should be
installed on the wellhead to detect and respond to this condition. Also, a wellhead
designed specifically for solution mining which allows for the injection of raw
water, return of brine, and the injection of a blanket material to protect the cavern
roof are required for proper control of the cavern design. The design of the wellhead
should be based on site-specific conditions, which includes consideration of
corrosion resistant internal coatings. Once solution mining is completed and
prior to the commissioning Mechanical Integrity Test (MIT) and de-brining, a
wellhead designed specifically for gas storage purposes must be installed. Wellhead
components exposed to raw water and brine during solution mining should not
be reused for gas storage service. API RP 1170, Sections 6 and 9 provide specific
guidance related to the design of wellheads for cavern storage facilities. Figure
10-3 illustrates a typical wellhead configuration of a salt cavern well during the
Figure 10-3 Example Salt Cavern Well Wellhead Configuration During Solution Mining
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Figure 10-4: Example Salt Cavern Well Wellhead Configuration During Gas
Storage Operations
solution mining phase when fresh water is being pumped into and brine is being
circulated out of the cavern during its development. Figure 10-4 illustrates a typical
salt cavern wellhead configuration once development is completed and the cavern
is being used for gas storage purposes.
6. Finally, if the wellhead is located in close proximity to roads, railways, airports,
active farming operations, flood plains, or areas where landslides may occur,
consideration should be given to the use of “Jersey” barriers, bollards, fencing, or
other barrier methods that afford physical protection and limit unauthorized
access to the wellhead.
7. Wellheads should be routinely monitored for operability, leaks, and mechanical
faults, and annually inspected and tested to ensure functionality. Monitoring
should include wellhead injection pressure and flow rate for unexpected, rapid
changes in pressure or flow which may be indicative of a mechanical problem or
abnormal operating condition. Annuli pressures should also be monitored for
changes which may indicate an abnormal operating condition.
8. Emergency shutdown valves which are integral or adjacent to the wellhead tree
assembly may be appropriate based on an analysis of site-specific risks. These
types of valves may be activated by conditions such as over-pressuring, excess
flow, gas leakage, and/or heat detection.
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ii. Master valve
1. UGS wellheads should consist of at least one master valve. This applies to casing
only or casing-tubing-packer completions. Master valves give operators additional
well control and isolation options and allow them to perform certain maintenance
activities under pressure such as snubbing or wireline operations.
a) Valves should be inspected and function tested for operability and sealing
capability at least once per year, (or as required by regulations) and inspection
and test results documented. More frequent inspections may be appropriate
based on site-specific risk factors or conditions which include produced
fluids which are corrosive, solids production, prior to and immediately
after workovers, and following hydraulic fracturing or other well stimulation
activities.
b) Valves should be lubricated and serviced as indicated by the manufacturer
and in accordance with the operator’s routine maintenance programs.
iii. Isolation valves
1. Valves which isolate the wellhead from the gathering system or pipeline should
be inspected and function tested for operability and sealing capability at least
once per year, and inspection and test results documented. More frequent inspection
may be appropriate based on regulations and on site-specific risk factors or
conditions similar to those mentioned above for master valves. This is particularly
true for wellhead wing valves which serve as isolation valves between the wellhead
and gathering system/pipeline.

iv. Other valves (snubbing unit, wing, etc.)
1. Other valves may also be incorporated into the wellhead including swab valves
(snubbing unit) which may be located above the master valve or at the very top of
the wellhead tree, and wing valves on the side of the tree, as previously mentioned.
Swab valves are used for isolation during other well work activity such as wireline
work or coiled tubing work, and wing valves (also known as side gate valves) may
provide another means of injecting into the well during kill operations. Inspection,
testing, and maintenance activity on the other valves listed here should be performed
at least once a year and inspection and test results documented.
v. Emergency shut-down devices
1. Surface Safety Valves: A surface safety valve can be installed on a wellhead (typically
a type of master valve) or located as a wing valve and small diameter low pressure
check valves on the annular spaces in certain instances to prevent oxygen access
to the annular space. Surface safety valves are typically designed to automatically
close (fail safe) based on conditions that may include excess flow or pressure,
gas detection above LEL, erosion, or fire. Small diameter check valves are typically
spring-loaded and normally closed; they open only in an “overpressure” condition.
Circumstances where use of surface safety systems may be appropriate should be
addressed as part of an overall site-specific evaluation of threats and potential
consequences (risk analysis). All components of safety valve systems should be
tested on a regular schedule, based on operating conditions and historical perfor-
mance or as required by regulations
2. Subsurface safety valve: A subsurface safety valve is typically installed on or in
a tubing string below the wellhead. The purpose of a subsurface safety valve is
to allow an operator to shut-in the well below the surface in the case of a surface
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emergency or if the wellhead is damaged. Subsurface safety valve are typically

designed to automatically close (fail safe) based on conditions which may include
loss of the wellhead, loss of functionality of the wellhead, and surface conditions
such as fires that may endanger the wellhead from functioning as designed.
Circumstances where the use of a subsurface safety valve may be appropriate
should be addressed as part of the overall site-specific evaluation of threats and
potential consequences (risk analysis) and performed on a per well basis.
3. API RP 1171 Section 6.2.5 provides guidance concerning emergency shut-down
valves in general, and when and where such systems may be appropriate. This
includes both surface and sub-surface safety valves. Considerations include but
are not necessarily limited to:
a) Distance from dwellings, occupied structures, playgrounds, etc.;
b) Distance between adjacent wellheads or other production equipment;
c) Gas or fluid composition and maximum flow potential;
d) Proximity to roads, railways, airports or other rights of way;
e) Current and future development potential;
f) Alternative measures that could afford physical protection to the wellhead; and
g) Added risk created by installing and servicing safety valves.
h) Other considerations, which may include:
1) proximity to environmentally or culturally sensitive areas;
2) proximity to seismically active areas, faults, floodplains, or land
slide potential; and
3) risk of sabotage.
Where installed, these systems should be function tested at least annually and in
accordance with API RP 14B. (70)
vi. Wellhead Seals such as gaskets, packing and welds
1. Seals, gaskets, and welds should be inspected as part of routine wellhead inspections.
Gaskets, including, ring and conventional flat-faced, should be replaced and not
reused any time the seals are broken during maintenance activity or when evidence
of leakage is detected. Packing materials, such as injectable plastic, may be used
for remedial purposes in sealing minor wellhead leaks on wellheads equipped
with injection/test ports.
vii. Corrosion/Erosion inspection
1. Routine inspection of surface equipment and development of a corrosion management

program are integral to effective wellhead integrity demonstration, verification,
and monitoring.
2. Corrosion coupons may be useful in concert with other monitoring methods, such
as produced fluids sampling and analysis, for monitoring internal corrosion rates
and/or the effectiveness of corrosion inhibitor treatment programs.
3. Acoustic sensing devices (ultrasonic probes) may be useful in detecting both
internal corrosion and erosion. A program of periodic surveys at pre-defined
locations on valve bodies, elbows, and/or other fittings where flow impingement
occurs can be effective in assessing internal integrity where other methods are
not possible or practical.
4. Corrosion probes, also known as electrical resistance probes, provide another
option for monitoring internal corrosion rates. The action of corrosion on an
exposed metal element reduces the cross-sectional area of the element, thereby
increasing its electrical resistance. The value of the resistance increases in a
predictable manner with the depth of corrosion, which permits an accurate deter-
mination of the corrosion rate.
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5. Sand probes work on a similar concept as corrosion probes. Sand and abrasives
erode a sacrificial sensing element that is inserted through a sealed high pressure
assembly. Abrasives eventually erode through the probe, exposing the sealed
assembly to working pressure, which is detectable via pressure gauge or alarm.
6. Other inspection methods and procedures may be employed if microbially-influenced
corrosion is suspected or likely. This would likely include obtaining fluid samples
and culturing the samples for the presence of viable bacteria, such as sulfate
reducing bacteria. If active cultures are detected, treatments with the appropriate
biocides should be considered.

viii. Cathodic protection (CP)
1. Considerations and justification of whether wellhead and well casing should be

protected is a site-specific issue. Buried gathering lines and pipelines at storage
facilities typically have impressed current applied to them for corrosion protection.
Some storage facilities apply CP to well casing strings and wellheads while others
install insulating flange gaskets, washers and bushings to isolate the wellhead and
casing strings from electrochemical corrosion. Factors such as the corrosivity of
soil and strata above the gas storage zone, the presence or absence of fully
cemented casing strings, and the risk of damaging stray current should be evaluated
when considering whether or not to apply CP to the storage wells.
ix. Atmospheric coatings
1. All wellheads and exposed connected piping shall be coated to prevent atmospheric
corrosion.
c. Pipeline Isolation Valve / Equipment Between Wellhead and Hand-off to USDOT Jurisdiction
The pipeline isolation valve is the location at each storage facility where regulatory oversight transitions
from the regulatory agency that has responsibility for gas storage wells, to the regulatory agency that has
responsibility for pipelines. The location of this valve might be different for each storage facility depending
on whether the facility is an intrastate or an interstate facility; it may also vary from state to state.
In many states the hand-off point between well and pipeline regulatory responsibility occurs at the point
of interconnect between the downstream flange of the wing valve on the wellhead to the flange of the
gathering line/pipeline which connects it to the wing valve. However, this convention is not universally
applied. In some instances, the hand-off point may be further downstream (closer to the storage field
compressor station or transmission line), and there may be additional equipment between the wellhead
and the hand-off point between regulatory agencies. This equipment may include, but is not limited to,
wellhead measurement facilities, separators, sand/solids traps, chemical injection facilities, or other
production related equipment such as pig launchers/receivers.
Regulators from these two different agencies (wells and pipelines) should consult with each other and
with the storage operator and agree on the specific location where the transition occurs, and operational
considerations related to the hand-off point. This will ensure clarity for all affected parties, minimize
uncertainty concerning regulatory compliance requirements, and best serve the interests of public safety.
It may also help avoid potentially conflicting or confusing directives.
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d. Pressure Management/Monitoring
i. Equipment
1. Equipment associated with pressure management and monitoring at gas storage

facilities includes, but may not be limited to:
a) Pressure control valves;
b) Pressure relief valves and emergency shut-down systems (ESD);
c) Calibrated dead-weight pressure gauges;
d) Calibrated digital and analog pressure gauges;
e) Temperature-compensated pressure transducers; and,
f) check valves.
2. Pressure control valves are typically used to reduce storage field gathering system
pressure down to the pipeline transmission system pressure. These types of
valves are oftentimes located between a storage well and a pipeline isolation
valve, though some facilities exist where the pressure control valve is on the well
head. They may at times be used to control station inlet pressure to a storage
field compressor station. These types of valves are typically automated valves
that are controlled via station automation systems, electronic data monitoring
system, or SCADA systems. Pressure control valves may also be used at individual
wells, though that is a less common application. Routine inspection and mainte-
nance on these types of valves should be per manufacturer’s specifications and in
accordance with the operators routine operations and maintenance procedures.
3. Pressure relief valves and ESD systems are designed to protect the storage
facility by preventing exceedance of the facility MAOP including compressor
station piping, brine lines and fresh water lines for caverns, and storage field
gathering system piping, against a situation where MAOP is exceeded. Relief
valves are typically installed on the discharge piping at a storage field compressor
station and other locations within the storage field piping immediately down-
stream of where there is a reduction in the maximum allowable operating pressure
(specification break) in the piping. They may also be installed on pressure vessels
such as separators and other process equipment where an overpressure condition
could occur. Relief valves are subject to federal USDOT testing/verification
requirements under 49 CFR Part 192 for natural gas storage facilities and under
Part 195 for liquid hydrocarbon storage facilities. The flow capacity of relief
valves must be verified and documented annually by the operator to ensure they
meet federal safety standards.
4. All ESD systems should be tested annually, or more often, depending on operating
conditions and performance history, to ensure they perform as intended in the
event of an emergency. For cavern wells, ESD valves are typically located on or
near the wellhead and are automatically activated in the event of excessive pressure
or flow. They should allow for local and remote activation, electrically and
mechanically. All components of the system should be tested including, valves,
transmitters, switches, and other end devices. Results of all inspections, maintenance,
repairs, and testing of this equipment should be documented by the operator.
Inspectors for the regulatory agency with jurisdiction should be afforded the
opportunity to witness testing of these and all other safety systems.
5. Other types of pressure monitoring equipment commonly used at storage facilities
include dead-weight pressure gauges, analog gauges, digital electronic gauges,
and electronic temperature compensated pressure transducers. These instruments
should all be subject to periodic calibration and function testing (at least annually)
against a known calibrated standard gauge to ensure accuracy. Malfunctioning
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equipment is repaired or replaced, and equipment that can’t be calibrated within

manufacturer’s specifications is replaced.
6. Pressure check valves may also be used in some instances where fluid flow is
acceptable in one direction, but not in the other. These may include flow lines
which are used for storage withdrawals only, and on the annular spaces of wells
to prevent oxygen from entering the annular space. Inspection and maintenance
of these types of valves should be in accordance with manufacturer’s specifications.
ii. Protocols
1. Storage operators monitor operating pressure of their storage facilities on a

real-time basis for the purposes of evaluating facility performance and monitoring
system integrity. This should include developing and implementing procedures
for routine monitoring, recording, and analysis of the tubing and annulus pressure
conditions at individual wells to aid in identifying abnormal operating conditions
and potential wellbore integrity issues. Pressure readings may be obtained and
recorded either manually or via automated readings from an electronic data
monitoring system or a SCADA system. The frequency and type of monitoring
that is required should be based on site-specific conditions and a risk assessment
to identify potential threats and hazards to the storage operation. But in any
case, pressures should be monitored at least daily, and operators should keep
adequate logs of these results.
2. Operators should develop and implement procedures for investigation and re
mediation of abnormal tubing and/or annulus pressure conditions. This includes
but is not necessarily limited to:
a) Safely validating anomalous pressure readings to confirm whether a loss
of integrity has occurred;
b) Internal and external notifications to company officials, regulators, and
local first responders, if a leak is confirmed;
c) Determining whether a leaking well can/should be isolated from the
gathering system;
d) Conducting follow-up testing including gas sampling and analysis to
determine the source of the leak;
e) Performing further evaluations by temperature/noise surveys, and other
surface and downhole assessments to identify the source of the leak;
f) Performing remedial repairs if possible or plugging and abandonment of
the well;
g) Documenting all steps taken to address the issue; and
h) Implementing contingency procedures where necessary.
iii. Automation
1. An electronic data monitoring system or SCADA system may be used to monitor and
control storage facility process flow conditions in real time. These systems may
be associated only with compressor station operations at some facilities, or may
be more complex (due to the requirements for wired or wireless communications
equipment) and include real time monitoring and control of each of the storage
wells or storage caverns, as the case may be. They may be configured for monitoring
only, for on-site control only, or remote (off-site) control, including routine start/
stop capability of process equipment and flow; and they may include system
alarms (audible and/or visual) and automatic shut-down in the event of process
upsets or abnormal operating conditions.
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2. At cavern facilities during solution mining operations, SCADA systems may be used
to monitor and control the solution mining process. These systems generally
incorporate instrument control and shut-down capability to safely isolate the cavern/
well in the event of abnormal operating conditions and emergency situations. They
alert operators to system upsets that may require further investigation and/ or
operator response. This includes, but is not necessarily limited to, rapid increases
in brine outflow rates, oscillation of the hanging string during debrining, and complete
or partial failure of the leaching or debrining string.
3. Electronic data monitoring systems may be used to monitor and control gas injections
and withdrawals on a real time basis. This may include the capability to monitor and
control system pressure, flow rate, and shut-in capability. It may also include the
capability to control pressure and flow from individual wells at some facilities. ESD
systems should be integrated into the overall electronic data monitoring system or
SCADA system at any storage facility. Both audible and visual alarms should be
incorporated into SCADA control to alert operators to process upsets and abnormal
operating conditions. The electronic data monitoring system or SCADA system func-
tionality and system safety components should be tested periodically to ensure all
instruments are properly calibrated and functioning per design capability, all alarms
function properly, and the system performs as intended in the event of an emergency.
All components of the system should be tested and results recorded and documented
according to regulatory requirements and/or operator procedures. Often a Control
Room Management Plan is required per 49 CFR 192 and 195; this plan will give
details on required procedures and SCADA design and management.
e. Surface Leak Detection
Surface leak detection appropriate for surface equipment at storage well sites leverages heavily on
methods utilized at other oil and gas infrastructure, including production wells, compressor facilities and
distribution networks. Active leak detection programs are often structured in Leak Detection and Repair,
where leaks are detected utilizing a variety of techniques, scheduled for repair or monitoring, and then
repaired. Surface leak detection has evolved rapidly in recent years. Currently deployed processes often
utilize staff to perform leak detection and assessment. In addition, new technologies are in development,
allowing for reliable and low-cost continuous leak detection over short distances. The different surface
leak detection technologies can be used in concert, with some specializing in detection and others in
location (to facilitate repair). When considering new technologies for regulatory requirements, or in
approving an approach as part of a RMP, regulators should consider pilot projects to test the efficacy and
cost effectiveness of different setups in different circumstances, and should endeavor to audit the results of
leak detection systems to ensure functionality meets expectations.
i. Typical leak survey processes in current use:
1. States may consider requiring leak surveys at regular intervals with appropriate
levels of reporting for tracking and control.
2. Optical Gas Imaging - Leak surveys of well sites can be performed using an Optical
Gas Imaging (OGI) camera, a type of IR camera which filters light to highlight
methane in escaping gas. During a leak survey a trained camera operator walks
through the site (e.g. a well pad), and observes every potential leak point, including
unions, gauges, valves, separator equipment, etc. A leak is typically defined as an
observed plume in the OGI camera viewing screen. (Example: 40 CFR 98.234 -
Monitoring and QA/QC requirements) The operator then records and, optionally,
tags the leak for future tracking. Large leaks are reported to repair teams immediately.
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Approach Example Type Frequency Status Pros Cons Brand

Technologies Examples
Ground-based Forward Handheld Daily to IR camera Able to High capital cost; FLIR;
Optical Gas Looking Weekly widely visually high labor cost; OPGAL;
Imaging infrared used; identify leaks; detection only Rebellion
(OGI) camera; hyperspec- Highly during surveys; Photonics
hyperspectral tral efficient detection limit
camera cameras survey time dependent on
emerging operator skill and
weather
conditions
Aerial surveys Forward Aerial Periodic Emerging Able quickly Only can identify Leak Surveys,
Looking survey large the largest leaks Inc; Kairos
infrared camera number of Aerospace
(low elevation); sites
Infrared
imaging
spectrometer
Point Flame Handheld Periodic Method 21 Measurements Handheld Los Gatos;
measurements ionization widely identify measurements Bascom
(Handheld) detector; used; individual only detect during
tunable diode leaks surveys;
laser
Point non-dispersive Stationary Continuous Emerging; Provide Requires data
measurements infrared sensor Pilot continuous analysis for leak
(Stationary) programs measurements detection; Can be
in costly in wide
California spaced fields.
and other
states
Open Path tunable diode Stationary Periodic/ Emerging / Stationary Handheld Boreal; Heath
Infrared laser Continuous In use in monitors measurements RMLD
some states provide only detect during
continuous surveys;
measurements continuous
monitors require
data analysis for
leak detection
Table 10-1: Leak Detection Approaches
a. The efficacy of OGI surveys is well respected, though the technology

and practice continue to evolve. Several cautions should be noted. First,
OGI effectiveness is highly dependent on wind conditions – smaller leaks
are difficult to pinpoint during higher wind conditions. For example, one
vendor provides detection limits ranging from 0.8-11 g/hr, based upon
degree of mixing and wind speeds from 0-5 MPH.(Benson et al.). States
should consider maximum wind limits for which an OGI survey is considered
valid. Wind limits are available from some of the camera vendors. Second, the
IR image in an OGI camera is the combination of both light absorption by
methane and temperature gradient against the background or reflected
light source. Leaks may be difficult to detect in low-contrast conditions,
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and teams should observer key locations on a site from different

angles to maximize the opportunity to highlight the leak against the background.
b. Some operators have already begun to implement OGI as part of regular
facility inspections, with both in-house and third-party contracting firms
performing this work. In addition, several local and state agencies are
using OGI equipment within surveys and audits as part of normal inspection
and enforcement efforts to determine the presence of leaking components
As more inspections and research are performed, the additional data on
OGI use should be collected and analyzed. At the same time, operators
should be exploring the use of OGI as an additional tool for surface facility
integrity verification.
c. Increasing frequency of OGI inspections, in theory, will detect leaks sooner
and provide multiple opportunities to identify any one leak. However,
operator fatigue that builds with many repetitious surveys may reduce
survey efficacy, and states should be cautious about unduly increasing the
frequency of OGI surveys.
3. Remote leak detection – typically using laser absorption instruments (e.g.Heath
RMLD™) – may be an effective compliment to OGI. Laser instruments can quickly
scan components, identifying leaks to a small area, which can then be inspected
with OGI to localize to a specific leak source. As with OGI, laser detectors are sensitive
to wind conditions and should only be utilized in below a maximum threshold
wind speed.
4. Leak detection with quantification - If emission rates measurements are desirable,
most leaks at well pads may be measured using high-flow instruments, (e.g.
Bacharach Hi Flow® sampler). Due attention should be paid to calibration of
these devices, at least daily or after any contact with wet gas, in alignment with
manufacturer’s specifications. (“Bacharach Hi-Flow Sampler, Instruction 0055-
9017, Operation and Maintenance” 2015; Howard, Ferrara, and Townsend-Small;
Howard; Allen, Sullivan, and Harrison). In addition to high flow samplers, some
monitoring companies (e.g. Rebellion Photonics) have developed OGI based systems
that are paired with sophisticated computation algorithms to quantify emissions
rates and volumes from leaking components.
5. Non OGI point-source leak detection – Methane leak detection has been occurring atc
sites across the country for decades, either using hand held equipment or stationary
equipment. States may consider requiring point-source leak detection at some or
all gas storage wells, depending on facility architecture, weather patterns,
topography, and safety and environmental risk tolerances – such systems are
being piloted at facilities in California and elsewhere. Mobile leak detection tech-
nology (leak detection affixed to mobile detection equipment), while also rapidly
evolving, is generally more expensive to operate, but can help in initial surveys
to determine baseline leak information, in finding leaks once detected by a point-
source device, in quantifying leak flux rates when desirable, and in verifying the
success of repairs and remediation programs. Equipment types available for this
purpose include:
a. Stationary Point Source Gas Detectors – Various types of equipment are
available for leak detection at storage fields, and the appropriate technology
may vary depending on a variety of factors such as the source of a potential
leak being monitored (surface emissions from subsurface leakage or well
pad emissions), the proximity of wells to one another, and the overlying
94
topography of the field (water flooded, topographic fluctuations, etc.)

These factors may greatly affect both the quality and consistency of
detection and the cost effectiveness of this solution. Point detectors
typically use Non-Dispersive Infrared (NDIR) sensors calibrated for Methane.
Point Detectors need to be strategically deployed in sufficient numbers at
proper locations to compensate for day-to-day changes in wind speed and
direction. Analytical models such as Gaussian Plume analysis can be
employed to aid in determining detector placement. Networks of point
detectors can be made much more robust if combined with on line data
analytics that overlays data from all detectors in the system and adds other
data such as local wind speed, local wind direction, pressures at key
points in the system, and position of control valves. The density of sensors
required to adequately cover a gas storage field varies widely with facility
architecture, weather patterns, and topography, and will change both the
effectiveness and cost efficiency over time with the advent of newer sensor
technologies.
b. Other Types of stationary gas monitors may also be utilized for detecting
and quantifying surface emissions from localized areas, or for establishing a
perimeter monitoring system to evaluate a larger area. Whatever the area,
stationary monitoring technologies exist that can detect methane concen-
trations at very low levels and automatically alert operators of the elevated
presence of methane. These technologies include open path infrared gas
detector technologies and extractive analyzers that also use NDIR detectors.
c. Mobile monitors – several types of monitors and monitoring techniques
exist for use in handheld, vehicular, airplane based, drone based and satellite
based applications. These systems generally employ sophisticated
infrared imaging technology. The selection of deployment method (e.g.
airplane, hand-held, vehicular, or satellite based systems depends largely
on the reason for the monitoring activity.) These systems have been
demonstrated as effective at locating leaks. These technologies generally
required a highly trained operator to correctly interpret the data gathered
by the devices. These technologies are generally expensive in terms of
initial cost of the devices, cost of operating the mobile equipment and cost
of labor for trained operators. Generally, these technologies are cost prohib-
itive for routine daily monitoring but are important for periodic surveying
of sites, locating the specific source of hard to find leaks identified by fixed
systems, and confirmation of remediation of discovered leaks.
d. Strengths and weaknesses of existing inventory methods: Traditional
inventory methods for natural gas storage fields, like other oil and gas
segments, have tended to undercount actual emissions as determined by
more advanced techniques. Due to the presence of super emitters, and
potentially inaccurate emissions factors, higher than expected component
numbers, and equipment fatigue/ corrosion processes have led to higher
emissions than expected. Due to advancements in aerial survey techniques
and peer reviewed research developed in the field, inventories that utilize
aerial surveys may increasingly be seen as a leading practice
e. New technologies for continuous monitoring are becoming more widely
available and are offered at reduced costs. These technologies allow
advanced monitoring using stationary gas detectors, both in arrays of
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point detectors, and area monitors (open path and extractive.) Applica-
tions are being developed and deployed at several oil and gas sites. Al
though some of these sites have used expensive infrared imaging systems
that require continuous onsite personnel, new continuous monitors that
use both infrared (NDIR) point detection and infrared laser-based detection
(open path detection) do not require significant facility personnel to
operate, and can communicate remotely with existing computer (Distributed
Control System or Programmable Logic Controller) and/or facility SCADA
systems. Such technology may be used to develop sensor networks at
lower cost than infrared imaging systems. Available wireless technologies
may significantly reduce the cost of installing point detectors. Traditionally
point detectors required connection to line power and a direct signal wire
connection to the host controlsystem and/or data analytic system. Wiring
costs will exceed the equipment costs by factors of x 10 or greater. New
developments in wireless self powered instrument technologies now
allows point detectors to operate off grid on long life lithium batteries
and transmit their data using self-organizing wireless mesh networks.
Wireless systems can also be used for monitoring other parameters such
as pressure, temperature, and valve positions using available self-powered,
wireless mesh network instruments. Open source protocol based wireless
mesh network are becoming increasingly common in the oil and gas
industries. Pilot programs are recommended to validate the effectiveness
of this technology under field conditions. Field conditions, such as weather
or topography, may affect the reliability of results and cost effectiveness of
continuous monitoring as a solution.
f. On line data analytical software is available and used by many large oil
and gas companies, and can be provided by third-party contracting firms.
This type of software overlays data from point detectors, open path area
monitors, and other data such as local wind speed and direction, pressures
and temperatures at key points in the system, and valve positions. On line
continuous analysis of the data using algorithms in the software allow
differentiation from normal releases such as bleeding of pneumatically
actuated valves, normal operation of pressure relief valves, or depressur-
ization of systems for maintenance from unintended leakage from the
systems. The data analysis helps to quickly identify the source and
approximant magnitude of a leak and allows maintenance to be quickly
deployed to assess and repair.
ii. Frequencies
1. Daily audio-visual observations are required at some storage sites, with operators
visiting well platforms to observe equipment for odors, noises, and visual cues of leaks.
2. Continuous monitoring equipment is increasingly accurate and sensitive while
costs are falling, and may be considered at natural gas storage field well sites,
within a relatively short distance from well sites (approx. 100 feet), (71) (72) (73)
and along facility fence lines. Several states currently require continuous leak
detection at certain gas storage wells that pose immediate safety risks, while others
are considering continuous leak detection at all gas storage wells. Resources
include the Department of Energy’s ARPA-E MONITOR technology program.
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(https://arpa-e.energy.gov/?q=arpa-e-programs/monitor) and the Environmental

Defense Fund’s Methane Detectors Challenge (https://www.edf.org/energy/natural
-gas-policy/methane-detectors-challenge).
3. For mobile leak detection:
a. In the absence of continuous leak detection, approximately weekly surveys
using OGI or OGI plus laser detector may be appropriate.
b. Leaks should be identified (tagged and recorded) and persistent leak loca-
tions tracked over time. States should consider requiring measurement of
persistent leaks, and requiring repair for leaks above a set threshold with
in a specified time period.
4. States should design regulations so that companies may shift from existing processes
(e.g. OGI surveys) to automated systems as technology advances and costs drop.
iii. Thresholds
1. Technology exists today that allows for rapid detection of elevated levels in parts
per billion of methane above background. States should consider the upfront
and maintenance costs and lifespan of such systems versus parts per million
systems. States may develop standards on appropriate threshold requirements to
investigate elevated methane readings based on proximity to populated areas, the
potential for a large-scale release, and general risk tolerance.
iv. Overview of measurement methods. Notes on quality control by adhering to appropriate

measurement protocols.
v. Considerations for cavern leak detection include both heat and gas detectors.
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Chapter 11
Introduction
Emergencies create safety and environmental risk and disrupt routine business activities. It is therefore
important for operators to develop an effective Emergency Response Plan (ERP) that will enhance protection,
mitigation, and response to the full range of possible emergencies. Thorough preparation and practice
will result in reduced impacts to life, property, and the environment and promote a swifter return to routine
business. ERPs are unique to each site and project. ERP is a dynamic and ongoing process. All ERPs must be
reviewed, modified, and updated frequently to ensure appropriate responses to foreseeable emergencies. The
consequences of outdated or inadequate ERPs can include greater damage to life, property, and environment,
as well as fines and criminal or civil suits.
The purpose of this chapter is to introduce regulators to key elements of an ERP. There is no single template for
an ERP, but they should have at a minimum the topics in this chapter. This chapter is not intended to be exhaus-
tive in coverage. Regulatory bodies and organizations must also consult a number of applicable international,
federal, state, and local standards for guidance in evaluating and developing comprehensive operation-specific
ERPs such as ISO 22301 (71), CSA Z731-03 (72) and NFPA 1600 (73).

Critical components of successful emergency response should be addressed during ERP, including:
• Total commitment of leadership and staff with a clear purpose and scope;
• Identification of needed resources, response team organization, roles and responsibilities,
and comprehensive internal and external communication systems;
• ERP planning that includes goals, objectives, an incident management system, risk
assessments and comprehensive hazard identification;
• Coordination of response actions with government or other emergency response entities;
• Development and implementation of a plan that has clear procedures, recordkeeping,
incident management protocols, and incident termination/recovery steps; and
• A comprehensive training and education program, aimed at training and educating
personnel to consistently display competency in executing the ERP. All exercises and
drills should test the ERP effectiveness with lessons learned and corrective actions
implemented. They should integrate all interested parties/agencies and incorporate input
from all participants.
Regulators may also recommend that operators:
• Coordinate continuous development and modification of ERPs with appropriate authorities

(e.g., fire department with facility jurisdiction, and others);
• Perform a thorough hazard identification and associated risk assessment of all phases of
their operation; and
• Employ an objective, independent and competent audit function to continually assess the ERP.
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Main Take-Aways
• ERPs are used to protect life, property, and the environment. Their design also helps prevent
or mitigate impacts suffered in emergency situations. ERP strategies also include developing
plans to address a comprehensive range of emergency situations.
• ERP and preparation is a dynamic and ongoing process.
• ERP design and update involves multiple stakeholders including first responders, regulators,
internal staff and leadership, and media and community representatives
• Important parts of ERP design are hazard identification and the assessment of associated
risk with effective responses managed through an incident management system.
Emergency Response Program Organization

Protecting life, environment, and property must be a core value that is intimately threaded throughout an
organization. A properly organized ERP communicates deep commitment to the organization and affected
outside agencies and communities. Organizations must address leadership, team structure, roles and
responsibilities, resource allocation and deployment, and communication.
a. Purpose and Scope
An effective ERP will guide personnel in emergency preparedness, response, and management. In so doing,
the safety of personnel, public, environment, and property will be protected to the maximum extent possible.
Recovery times will be reduced for both surrounding communities and routine business activities. A
properly designed and executed ERP (covering unique facility attributes as well) will establish minimum
guidelines for emergency preparedness, response, and management. It applies to all levels of staff and
management, outside emergency response and regulatory agencies, and adjacent communities that may
be affected. The ERP will be applicable to all phases of operations including entities owned or contracted
by the organization.
b. Leadership, Commitment and Policy
The ERP and its support program must have full commitment of leadership, especially at the executive
level. Support must be clearly evident to the entire organization or the ERP and support program will be
marginalized. Developing policy pertinent to the ERP is vital and should be a joint effort of management
and staff reflecting the organization’s core values. ERP policies should be easy to understand and apply,
and must include clear statements of everyone’s commitment to protecting life, environment, and property.
Knowledge, understanding, and implementation of this policy are everyone’s responsibility.

c. Response Team Organization
Many organizations use the Incident Command System (ICS), National Incident Management System
(NIMS), or close variations which are well known with documented success. These systems are flexible
and will cover the full range of emergency situations. They provide an organized set of scalable and stan-
dardized operational templates for structure. It is vital to train the organization to use the ICS or NIMS
templates if selected for ERP implementation as most businesses organize their operations differently.
Important team components are audit and regulatory. The audit function must be objective and indepen-
dent. Audits must be conducted regularly and with a frequency to insure the ERP is performing as designed
and desired. Audits should include detailed records, analysis, summary of plan performance, and corrective
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actions at a minimum. A well trained regulatory staff is vital to keep an organization informed and coor-
dinate with all outside regulatory agencies. The ERP must always adhere to all applicable laws, rules, and
regulations.
d. Roles and Responsibilities
Well-defined roles and responsibilities, and training to understand them, are critical. Many organizations
adopt systems such as RACI (Responsible, Accountable, Consulted, and Informed) to agree upon and
communicate all roles and responsibilities for the entire ERP. Roles and responsibilities must be under-
stood to insure the most effective and efficient ERP.
e. Resource Allocation and Development
Defining critical resources is required for an effective ERP to respond properly to an emergency. Re-
source needs extend beyond money, equipment, and manpower. The organization must devote time,
energy, and expertise to identify resources that will be needed to build and manage a comprehensive
logistics network, and acquire, manage, and deploy all the necessary resources for an effective ERP. The
distribution and logistics function must incorporate a tracking system to insure all staff is supplied with
the necessary resources, training, and up-to-date information. Documenting and tracking extraordinary
costs associated with the ERP and emergencies are needed as well as any alternative authorization levels
in management to avoid confusion or duplication during emergency situations.
f. Communication Systems
The ERP should thoroughly address all aspects of communication. Routine communication networks
should include, but are not limited to, procedures, equipment and personnel deployment (primary and
back-up), and alarms supporting specific operations. Emergency response operations will likely require
communication plans that are specific to the emergency event and location.
A communication plan should include:
i. Public information avenues;
ii. Professional communications personnel;

iii. Links to all outside agencies and regulators; and
iv. Methods to address appropriate internal audiences.

During emergencies it is important to coordinate the dissemination of accurate, timely, and appropriate
information. Communication sources and receptors must be well defined to avoid confusion. There must
be information sharing between facilities, emergency responders, and affected communities. Proper
communication systems and procedures save lives and better protect property and the environment in
emergencies.

The ERP is the culmination of established standards, regulations, experience, and coordinated dialogue
with all stakeholders. It addresses specific needs and applications as well as goals and objectives. ERPs
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vary greatly, but can be dissected into two major components: planning and implementation. The planning
segment may include goals, objectives, design, incident management system, and means of hazard identi-
fication. The ERP implementation section may include prevention and mitigation standards, operational
procedures and recordkeeping, damage assessment and incident management, and incident termination
and business resumption.
a. Emergency Response Plan Planning
i. Plan goals and objectives: Any ERP must be underlain with goals and objectives consistent
with the plan purpose and scope. Goals should be constructed to insure continual
improvement in ERP quality by evaluating ERP effectiveness through drills and exercises,
as well as real time emergencies. Goals should be understood throughout the organization
and identify clear responsibilities and accountabilities. ERPs may include SMART goals
where the goals should be Specific, Measurable, Attainable, Realistic, and Time-bound.
ii. ERP design: Plan design combines strategies, tactics, vision, policies, goals, required
capabilities, detailed risk assessment, and business impact analysis. The planning process
must address potential events that could impact personnel, property, the public, or the
environment. Design must combine the needs of all stakeholders into a coordinated and
coherent plan. Through the use of well-defined procedures, the design can identify, respond
to, and manage any emergency. Designs should take into consideration how the quality of
emergency management will impact an organization’s reputation, ability to conduct business,
operations, and relationships with key stakeholders.
iii. Incident management system: Incident management systems (IMS) should be founda-
tional to every organization’s health, safety, regulatory, and environmental policies and
procedures. IMSs are used to manage resources during an incident. Resources include
facilities, personnel, equipment, communication systems, and pre-determined response
procedures. Every incident must be investigated to determine root causes. Incidents must
be properly documented, and the organization must measure response and recovery
against goals, objectives, and Key Performance Indicators to determine criteria for
improvement.

iv. Hazard identification: Hazard identification (refer to chapter 3 on Risk Management for
additional detail on identification and mitigation of potential threats and hazards) is
crucial to planning any ERP and key to continual improvement and update. Adequate
time, personnel, and resources must be devoted to analyze all operations for routine and
non-routine hazards. Once identified, all hazards need to be risk assessed and prioritized
with specific procedures developed to avoid, mitigate, and recover from incidents involving
such hazards. A hierarchy to deal effectively with a wide range of hazards may address
elimination or substitution of tasks or the engagement of additional engineering and
administrative controls. The very last barrier is always use of personal protective equipment
(PPE). Well-tested and standardized hazard identification systems are available from the
safety engineering industry.
b. Emergency Response Plan Implementation
ERPs address personnel and public safety, as well as protection of property and environment. ERPs shall
also document assumptions, functional roles and responsibilities, delegation and transfer of authority,
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external liaisons, and support required from logistics and supply chain. The implemented plan should
consist of a single, integrated plan, but may include sections specific to operations such as:
i. P&M standards: P&M should be based on hazard identification, risk assessment, business
impact, and cost-benefit analysis. Strategies should be built to either prevent specific
incidents or mitigate them to limit impact and consequences. Strategies are dynamic with
procedures to adjust to changing conditions. See Chapter 3 on Risk Management.
ii. Operational procedures and recordkeeping: Procedures must be clearly written and
designed to protect life, property, and the environment to the maximum extent possible.
Procedures need to allow for concurrent activities of response, mitigation, prevention,
business continuity, and recovery. Volumes of information, data, updates, exercise and
emergency documentation, and audit results must be maintained in a recordkeeping
system that protects the security and integrity of the ERP. Systems must provide for ease
of maintenance, information retrieval, and back-up. Information retention should be suffi-
ciently beyond facility life to accommodate the possible development of latent issues.
Quality records are also required to support needs for subsequent due diligence, training,
and possible litigation.
iii. Situational/damage assessment and incident management: During any emergency, the
organization must timely assess the incident so that appropriate response may continually
be executed. Complete instructions are to be included in the ERP about how to perform
situational/damage assessment of an emergency incident. Some items to be considered
are determination of the nature of the emergency, weather, location, and time; threats to
life, property and the environment; and appropriate corrective actions. An operations
center should be designed and will issue all appropriate directives to manage the incident.
iv. Incident termination and business resumption: Through effective incident management,
the emergency will cease to be a significant threat to life, property, and the environment.
Plans should include steps to communicate internally and externally as appropriate,
secure the incident area for necessary recovery and remediation activities, and begin
the transition from emergency to non-emergency conditions. Business recovery and
resumption plans should provide for the restoration of all processes, operations, and
communications. The recovery process must be documented. At a minimum, consider
issues such as final damage assessment, total operational recovery, supply chain needs,
communication protocols with regulators and the public, required additional financial
resources, and employee assistance.
c. Training and Education
A critical element of an ERP is a comprehensive, well-integrated, and robust training program. The
program should at a minimum include goals, specific training and testing. All involved staff must possess
the necessary skills and knowledge to implement, support, and maintain the ERP. An ERP without this
component is not complete, nor will it be effective. This component should at a minimum include:
i. Type and frequency of training: Basic training should be general, broadly covering all
topics generic to the operation. Other trainings should be specific to task, location, equipment,
roles, responsibilities, hazards, and procedures. All personnel should be thoroughly and
routinely trained on all aspects within their roles and responsibilities. Frequency of training
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should be driven by regulatory requirements which is typically annually but may vary up
to every 3 years, and demonstrating competency. To reach desired levels of competency,
more frequent training and exercise may be needed beyond that required by law. Keeping
detailed training records should be and often is required by regulation.
ii. Public education: All emergency responders and other impacted outside agencies need
to be thoroughly trained and briefed regarding the specific operations, equipment, hazards,
communications, organizations and any other important previous operational issues. The
public should be made aware of potential impacts from operational incidents, ERP proce-
dural information, and key communication and organizational structures.
d. Exercises, Program Maintenance, Improvement and Update
Effective execution of ERPs will not occur without frequent and meaningful exercises and drills. At a min-
imum, these activities should provide opportunities for staff to take action, solve problems, interact with
all stakeholders, and deepen their understanding of the ERP. No amount of classroom or tabletop
exercises can replace drills and exercises conducted as if a real emergency were taking place.
i. Frequency and types of exercises and drills: Exercise and drill frequency should be at
least annually. More frequent drills may be needed to ensure all stakeholders are well-
versed in the ERP and can perform their duties effectively. Types of drills can vary from
workshops and tabletops to specific functional drills or full-scale exercises. Plan drills and
exercises carefully to cover a variety of situations across the full breadth of operations.
Strong consideration should also be given to conducting no-notice exercises. Effective
exercises and drills require adequate resources (time, material, planning, and personnel)
and a full commitment from all stakeholders, particularly senior leadership. Proper practice
is definitely one of the most critical parts of ERP implementation.
ii. Exercise and drill design: Exercises must be well-designed and executed for maximum
value. They must evaluate ERP effectiveness, procedures, and strategy to deal with a
broad range of emergencies. All outside agencies should be integrated into the exercise.
Exercises should incorporate a standardized template designed to test the ERP perfor-
mance, post-exercise analysis, lessons learned, and interaction with all stakeholders.
iii. Total plan review and update: Effective ERPs are dynamic documents and should be
thoroughly reviewed and updated at least annually. Other opportunities for improvement,
review, and update include exercises and drills, internal and external audit results, changing
regulations, organizational modifications, policy and procedural changes, and performance
objective refinements. Updates should be timely, follow a sound management of change
process, and be immediately communicated internally and to appropriate outside agencies.
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Chapter 12
Introduction
The temporary abandonment, plugging, and restoration of wells associated with the underground
storage of gas and other hydrocarbon storage gas operations has been accomplished by the gas storage
industry for a many years. Temporary abandonment, well plugging, and restoration requirements can
vary extensively between the various state regulatory agencies. Additionally, because of the different
types of storage wells (wells in depleted oil and gas horizons, salt caverns, hardrock caverns, and aquifers)
consideration of the various methodologies utilized for temporary and permanent abandonment must be
evaluated.

Perhaps the most critical issue to be addressed is to ensure that by placing the gas storage well into
temporary abandonment status or final plugging and abandonment prevents any potential for pathways
of gas migration and completely isolates the storage field reservoir from any temporarily or permanently
abandoned well. Wells placed into temporary abandonment status still need to demonstrate well integrity,
be monitored, be appropriately remediated if necessary, and returned to service, or eventually be perma-
nently plugged and abandoned. While placement of all plugs in a well is important, placement of the first
or bottom plug is critical to ensuring that the storage reservoir itself is isolated.
Main Take-Aways
• Temporary abandonment and well closure can be accomplished in a manner that ensures
wellbore integrity and prevents those wellbores from serving as pathways for the migration
of storage gas.
• Proper well closure and abandonment ensures the integrity of the gas storage reservoir.

Temporary abandonment of gas storage wells may be considered, but with significant regulatory conditions
(including limits on wells remaining in temporary abandonment status) established to ensure that these
wells will not present an immediate risk of gas migration out of the gas storage reservoir. Well abandonment
designs must ensure that the gas storage cavern or reservoir is isolated long-term from all other porous
or hydrocarbon-bearing zones in order to prevent fluid flow or gas migration between the storage zone
and any other penetrated formations and the surface. (16) (10) Once the well is plugged and permanently
abandoned, the operator should ensure the surface is returned to as near-original condition as is practicable
and should follow all applicable regulations and prudent practices.
a. Safety Considerations
A number of safety issues must be considered during testing of temporarily abandoned and/ or permanent
plugging and abandonment of gas storage wells. During each phase of the plugging or restorations
operations, a job safety analysis should be undertaken prior to any work being conducted. Everyone onsite
104
has stop work authority. All required PPE should be worn at all times when on location and the appropriate
level of safety training should be conducted for anyone that will be on location.
b. Potential Considerations for Porosity Storage (Depleted and Aquifer Storage Reservoirs)
i. Wellhead control considerations and capabilities;
ii. Protection of USDWs or other protected groundwater;
iii. The many potential wellbore issues – corrosion zones, flow zones, lost circulation zones,
disposal zones, commercial hydrocarbon-bearing horizons, lost fish, casing patches, liners,
junk, etc.;
iv. Directionally drilled wells;
v. Preparation for working with pressures anticipated from an existing storage reservoir
and potential pressures and flows from uphole formations currently behind pipe that may
be exposed to the wellbore if pipe is pulled;
vi. Well integrity and other pressure testing; and
vii. Open-hole and cased hole geophysical logging considerations.
c. Temporary Abandonment Well Considerations for Porosity Storage
i. Develop a plan to prevent migration pathways and isolate the storage reservoir in compliance
with regulatory requirements;
ii. Time considerations and notifications;
iii. Well testing and monitoring during temporary abandonment;
iv. Well workovers and corrective action;
v. Temporary abandonment status vs. “idle” well status – identify the differences; and
vi. Reporting requirements.
d. Plugging and Abandonment Well Considerations for Porosity Storage
i. General requirements and considerations
1. Plugging permit, closure plan, or other authorization, if required; and

2. Regulatory review, requirements, and notifications.
ii. Wellhead design considerations
1. Blow-out protection and well control; and

2. Snubbing or swabbing valve on production casing.
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iii. Plugging methods, considerations and regulatory requirements
1. Removal of all downhole equipment;

2. Setting of initial bottomhole plug – cement vs. mechanical or both – consideration of
pressure testing to ensure isolation of gas storage reservoir;
3. Additional cement plug requirements – casing shoes, casing rips, lost circulation,
flow zones, commercial hydrocarbon-bearing zones, corrosion zones, other mineral
zones (coal and others), USDWs or other protected groundwater, and surface plugs;
4. Staging of cement vs. bullhead cement jobs;
5. Cement types, additives, quality, and quantity;
6. Wait-on-cement time, pressure testing, and tagging plugs;
7. Plug spacer considerations;
8. Casing recovery (when possible and not cemented to surface);
9. Geophysical logging considerations;
10. Groundwater monitoring considerations; and
11. Submittal of plugging and abandonment report.
e. Restoration of Site for Porosity Storage Wells
i. Removal of wellhead and wellhead equipment;
ii. Cut off casing below grade (below plow depth if required);
iii. Tack weld steel plate with API or other identification information/number;
iv. Restoration of the area around the well; and
v. Records retention considerations.
f. Potential Issues for Salt Cavern Storage Wells
i. Wellhead control capabilities;
ii. Protection of USDWs or other protected groundwater;
iii. Addressing the many wellbore issues – corrosion zones, flow zones, lost circulation zones,
disposal zones, commercial hydrocarbon-bearing horizons, lost fish, casing patches, liners,
junk, and others;
iv. Directionally drilled wells;
v. Preparation for working with pressures anticipated from the existing gas storage reservoir;
vi. Well integrity and other pressure testing; and
vii. Geophysical logging considerations.
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g. Temporary Abandonment Well Considerations for Salt Cavern Storage
i. Develop a plan for agency approval to prevent migration pathways and isolate the storage
cavern;
ii. Time considerations and notifications;
iii. Well testing and monitoring during temporary abandonment – maintain a minimum pressure
for stability, monitor pressure;
iv. Temporary abandonment status vs. “idle” well status – identify the differences;
v. Reporting requirements include appropriate monitoring data such as pressures. Report

significant activities in regards to the well. Determine an appropriate reporting frequency;
vi. Implement measures in regards to wellhead equipment to prevent inadvertent use of the
well for storage; and
vii. Submit plan for agency approval for returning well to service.

h. Plugging and Abandonment Well Considerations for Salt Cavern Storage
i. General requirements and considerations
1. Review well construction, operational, monitoring, testing and logging information.

2. Develop a closure plan submitted to the regulatory agency for review and consid-
eration of approval. Plugging permit, closure plan, or other authorization if required;
3. Regulatory review, requirements, and notifications;
4. Wellhead design considerations;

ii. Plugging methods and requirements
1. Blow-out protection and well control;

2. Snubbing or swabbing valve on production casing;
3. Removal of all downhole equipment;
4. Prior to abandonment, removal of all gas to the extent possible through displacement
of brine; (11)
5. The cavern must be filled with saturated brine to assist in maintaining cavern
stability.
6. Conduct geophysical logging/ cavern surveys. Considerations include - gamma
ray, cement bond, temperature, casing inspection logs, and sonar survey;
7. Set initial bottomhole plug – must be a mechanical bridge plug set at the deepest
location within the production casing to both properly isolate the cavern and not
damage the casing – performance of pressure testing to ensure isolation of gas
storage reservoir and then place cement plug on top of the mechanical plug.;
8. Additional cement plug requirements – casing shoes, casing rips, loss circulation
zones, flow zones, commercial hydrocarbon-bearing zones, corrosion zones, other
mineral zones (coal and others), USDWs or other protected groundwater, and
surface plugs;
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9. Staging of cement;
10. Cement types, additives, quality, and quantity considerations;
11. Wait-on-cement time, pressure testing, and tagging plugs;
12. If there is a fall back of cement inside the production casing at the surface, the casing
must be topped off to the surface with cement.
13. Plug spacer considerations – if allowed. It is recommended that if feasible the well
casing be filled with cement from bottom to surface;
14. Casing recovery (when possible and not cemented to surface);
15. Consideration for well and cavern to be at state of static equilibrium prior to plugging
and abandonment ;
16. Submittal of plugging and abandonment report; and
i. Restoration of Salt Cavern Storage Wells
i. Remove wellhead equipment;
ii. Tack weld steel plate with API, or other identification information/ number;
iii. Leave casing top accessible and incorporate into monument grid for subsidence monitoring;
iv. Continue groundwater monitoring; and
v. Records retention must meet agency requirements, must be maintained for a period of time
until satisfied there are no problems with the well/cavern.
j. Potential Considerations for Hard Rock Cavern Storage Wells
i. Typically, hard rock caverns are normally relatively shallow;
ii. Wellhead control considerations and capabilities;
iii. Operating pressures in the cavern system are intended to keep the stored product in a liquid
phase. Depending on the cavern depth and the stored product, these pressures are typically in
the range of 20 to 125 psi. A loss of this operating pressure can result in a rapid transformation
of liquid into gas;
iv. Protection of USDWs or other protected groundwater is accomplished during the initial
installation of operational and venting wells installed to perform mining operations. Not only
is the USDW or other protected groundwater protected but the casing program prevents
groundwater invasion into the mine;
v. Addressing any wellbore issues – corrosion zones, flow zones, lost circulation zones, lost fish,
liners, and junk, etc.;
vi. Well integrity and other pressure testing;
vii. Geophysical logging considerations; and
viii. Favorable conditions for adequate hydraulic containment.
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k. Temporary Abandonment Well Considerations for Hard Rock Cavern Storage
i. Develop a plan for prevention of migration pathways and isolation of the storage reservoir.
Prior to temporarily abandoning a mined cavern, the stored liquid must be removed and the
cavern filled with an inert gas or liquid. To ensure the cavern has been rendered completely
inert, the operator may conduct and submit chemical analyses of the storage fluids to
the regulatory agency for review. The inert gas can also assist with recovery of both the liquid
and gas phases in the cavern. The inert gas is used to maintain positive pressure (100 plus
psi depending on depth or the minimum pressure determined by a rock mechanical properties
assessment) (53) on the cavern to support the pillars and prevent collapse of the cavern.
The inert gas pressure can be monitored at the surface as a possible indicator of migration
from either the cavern itself or from one (or more) of the access points.
ii. Time considerations and notifications

The length of time necessary to render inert any cavern will depend on the product volume
and market. For example, an operator may have difficulty making a propane cavern inert in
July due to market demand. The regulatory agency (federal or state) with responsibility for
mined cavern operations is notified when a cavern or caverns are taken out of service.
iii. Well testing and monitoring

When a cavern is temporarily abandoned, the pressure in the access wells is monitored
continuously with any significant change in pressure reported within 48 hours. The pres
sure is used to support the cavern roof and pillars and the loss of pressure could result in
catastrophic failure of the cavern. Integrity testing of the access wells (and other conveyances)
may be confirmed before beginning large scale product evacuations and again once the
cavern is confirmed to be inert.
iv. Temporary abandonment status vs. “idle” well status – identifying the differences
v. Reporting requirements: The owner/operator of the cavern reports pressure measurements

on a quarterly basis for any and all access wells.
l. Plugging and Abandonment Well Considerations for Hard Rock Cavern Storage
Prior to abandoning a hard rock cavern, the cavern should be evacuated, to the extent practicable, of all
hydrocarbons. The plugging and abandoning of a mined cavern storage operation requires that the aban-
donment of the cavern be considered as well as the abandonment of any and all wells that provide access
to the cavern. Caverns can be abandoned by filling with an appropriate inert gas or potentially other
fluid. The depth of the cavern and any potential communication with the local USDWs or other protected
groundwater will dictate the appropriate material. Typically, one or more large diameter boring(s) (60
inches or greater) provides the initial entry to begin mining operations. A single casing string is installed
in this boring to the roof of the proposed mine and is either grouted or cemented in place. This casing
string provides future access to the mine as well as providing protection of the USDW or other protected
groundwater. Subsequent to the completion of the mining operation, additional smaller diameter wells
are drilled and cased to provide additional points to place or remove the stored hydrocarbons.
A permit to mine the cavern may have been issued by the federal or state agency with authority over
underground mining. The permit to drill the access wells may have been issued by the federal or state
agency with authority over drilling. The abandonment of any well permitted to drill should obtain a permit
to plug.
109
The regulatory agency – federal or state – with the authority to permit the mining portion of the oper-
ation may require application and review of any plan to abandon the mine and notification when the
activity is scheduled to occur. The regulatory agency – federal or state – with the authority to permit any
drilling, casing or cementing associated with cavern operation will review any proposal to abandon a
permitted operation. The agency may require appropriate prior notification to allow for site inspection and or
witnessing.
An operator should develop a plugging and abandonment plan that includes:
i. Demonstration of the stability of all caverns being abandoned with geomechanical analysis
and pressure build-up;
ii. Removal of all downhole equipment and uncemented casing strings, unless circumstances
prohibit their removal;
iii. Complete isolation from all other porous and permeable zones or hydrocarbon-bearing
formations.
iv. Wellhead design considerations

v. Plugging and abandonment procedures;
vi. Blow-out protection and well control;
vii. Snubbing or swabbing valve on production casing;
viii. Setting of initial bottomhole plug, which must include a mechanical plug and then
consideration of pressure testing of the mechanical plug to ensure isolation of gas storage
reservoir;
ix. Mechanical bridge plugs can be set inside the smaller diameter access wells near the base
of the casing where good cement bond exists between the casing and the formation. Once
the bridge plug is set, 100 feet of cement is usually placed on the plug with tubing and
allowed to cure long enough to reach a prescribed compressive strength. A cement bong
log should be run on access wells to ensure that the cement sheath provides adequate
hydraulic isolation of the casing/formation annulus;
x. Cement should be spotted with tubing or work string and stage cemented to surface;
xi. Cement types, additives, quality, and quantity considerations;
xii. Wait-on-cement, pressure testing, and tagging plugs;
xiii. A written closure or plugging report summarizing the plugging activities may be submitted
to the permitting authority. The report identifies the plugging method, materials, equipment
and results. Supporting documentation in the form of contractor reports, invoices and/or
job summaries may also accompany the plugging report; and
xiv. Potential groundwater monitoring considerations.
110
m. Restoration of Hard Rock Cavern Wells
i. Remove wellhead equipment; (57)
ii. Tack weld of steel plate with API or other identification information/ number;
iii. Leave casing top accessible and incorporate into monument grid for subsidence
monitoring; and
iv. Records retention requirements.
111
Appendix A
List of References
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4. Clark, James A. The Chronological History of the Petroleum and Natural Gas Industries. Houston : Clark
Book Co., 1963.
5. Natural Gas Supply Association. Storage of Natural Gas. [Online] January 28, 2013. http://naturalgas.
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6. British Geological Survey. An Appraisal of Underground Gas Storage Technologies and Incidents for the
Development of Risk Assessment Methodology, RR^)%. s.l. : Health and Safety Executive, 2008.
7. Lord, Anna S. Overview of Geologic Storage of Natural Gas with an Emphasis on Assessing the Feasilibility
of Storing Hydrogen. s.l. : Sandia National Laboratories, SAND200-5878, 2009.
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Level Storage Data (Annual) -2005 and 2015. [Online] 2016. [Cited: June 2016, 2016.] http://www.
eia.gov/cfapps/ngqs/ngqs .cfm?f_report=RP7&f_sortby=ACI&f_items=&f_year_start=2005&f_year_
end=2015&f_show_compid=Name.
10. API. RP 1171 Functional integrity of natural gas storage in depleted and aquifer reservoirs, API RP 1171,
First Edition. s.l. : API, September 2015.
11. IOGCC, Energy Resources Committee. Natural gas storage in salt caverns: A guide for State regulators.
1998. p. 45.
12. Preliminary SED Staff Whitepaper on As Low As Reasonably Practicable (ALARP) Risk-informed Decision
Framework Applied to Public Utility Safety. Haine, Stephen. 2015.
13. API. RP 1114 Recommended Practice for the Design of Solution-mined Underground Storage Facilities,
First Edition. 1220 L St. NW, Washington D.C. : API Publishing Services, 1994.
14. NYDEC. Generic Environmental Impact Statement on the Oil, Gas and Solution Mining Regulatory Pro-
gram. New York Department of Environmental Conservation. [Online] [Cited: February 2, 2017.] http://
www.dec.ny.gov/energy/45912.html.
112
15. Kansas, State of. K.A.R. 82-3-311.
16. CSA. Storage of hydrocarbons in underground formations, 2341 Series- 14, 138 P. s.l. : Canadian Standards
Association, August, 2014.
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RP 1170, First Edition. s.l. : API, July 2015.
18. —. RP 6A Specification for wellhead and Christmas tree equipment, 20th edition. s.l. : API, October 2011.
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Version 1.18. September 2015.
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Petroleum Technology 37, no. 7, pp. 1285-1294.
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York : Society of Petroleum Engineers, 1990.
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N. D. and Maline, D. H. 2015, World Journal of Environmental Engineering 3, pp. 121-125.
113
33. Evans, D. J. A review of underground fuel storage events and putting risk into perspective with other areas
of the energy supply chain, In Underground gas storage: Worldwide experiences and future development in the
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34. United Nations Economic Commission for Europe. Study on underground gas storage in Europe and
Central Asia. Geneva, Switzerland : United Nations, 2013.
35. Analysis of major risks associated with hydrocarbon storage caverns in bedded salt rock. Yang, C., et al.
2013, Reliability Engineering and System Safety 113, pp. 94-111.
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M.B. Houston : s.n., 2016. 50th US Rock Mechanics/ Geomechanics Symposium. pp. 669-678.
37. Ghassemi, A. A review of some rock mechanics issues in geothermal reservoir development. Geotechnical
and Geological Engineering 30. 2012. pp. 647-664.
38. Estimating fault stability and sustainable fluid pressures for underground storage of CO2 in porous rock.
Streit, J. E. and Hillis, R. R. Energy 29, pp. 1445-1456.
39. The geomechanics of CO2 storage in deep sedimentary formations. Rutqvist, J. 2012, Journal of Geotech-
nical and Geological Engineering 30, pp. 525-551.
40. Earthquake triggering and large-scale geologic storage of carbon dioxide. Zoback, M. D. and Gorelick,
S. M. 2012. Proceedings of the U.S. National Academy of Science 109. pp. 10,164-10,168.
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42. Thesis—keeping the management system ‘live’ and reaching the workforce Paper SPE 36034. Primrose,
M. J., Bentley, P. D. and Van der Graff, G. C. New Orleans, LA : s.n., 1996, Journal of Petroleum Technology,
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43. Ten golden rules for developing robust bowties. Ramsden, M., et al. London, UK : s.n., April, 2013. SPE
European Health, Safety, Environment, and Social Responsibility in Oil and Gas Exploration Conference
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44. Cavern storage of liquified natural gas. Paper WPC-12534. Khan, A. R., Anderson, P. J. and Eakin, B.
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45. Civil reuses of underground mine openings: A summary of international experience. Peila, D. and Pelizza,
S. 1995, Tunneling and Underground Space Technology 10, pp. 179-191.
46. Ohio seeks US guidance on storage caverns. Cromwell, L. March 6, 2013, CantonRep.com.
47. PB-KBB, Inc. Advanced underground gas storage concepts: Refrigerated-mined cavern storage. Final
Report to USDOE, contract number DE-AC26-97FT34349. 1998.
114
48. Underground gas storage in the Leyden lignite mine. Meddles, R. M. 1978. 1978 Symposium on Energy
Resources of the Denveer Basin, Rocky Mountain Association of Geologists. pp. 51-59.
49. The water curtain: A successful means of preventing gas leakage from high-pressure, unlined rock caverns.
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50. Folga, S., et al. U.S. natural gas storage risk-based ranking methodology and results. s.l. : Argonne Na-
tional Laboratory Technical Report ANL-16/19, 2016.
51. Safety of salt caverns used for underground storage. Berest, P. and Brouard. s.l. : Oil & Gas Science and
Technology, 2003, Vol. Rev. IFP 58.
52. Bruno, M. S., et al. Development of improved caprock integrity analysis and risk assessment techniques.
Energy Procedia 63: 4708-4744. 2014.
53. Nemec, R. California’s second -largest gas storage field closed for leak repair. NGI’s Daily Gas Price
Index. 2016.
54. Safe storage of CO2: Experience from the natural gas storage industry. Papanikolau, N., et al. Trondheim,
Norway : N.A. Rokke et al., Editors, 2006. 8th International Conference on Greenhouse Gas Control Tech-
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s.l. : Exploration and Production: Oil and Gas Review, Vols. Paper LBNL-2989E.
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57. ISO. 55000 Asset management- Overview, principles and terminology, 1st Edition. s.l. : International
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ates-its-natural-gas-storage-facilities.
59. API. RP 1114 Recommended Practice for the Design of Solution-mined Underground Storage Facilities,
Second Edition. 1220 L. St., NW, Washington D.C. : API Publishing Services, 2013.
60. —. RP 1115 Recommended Practice for Operation of Solution-Mined Underground Storage Facilities, First
Edition. s.l. : API Publishing Services, 1220 L. St. NW, Washington D.C., 1994.
61. Subsurface containment assurance program—Key element overview and best practice examples, Paper
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62. Geomechanical technology for seal integrity analysis- The three-step approach Paper IPTC 17057. Davidson,
J.M., et al. Beijing : s.n., 2013. International Petroleum Technology Conference.
63. Monitoring and induced seismicity from underground gas storage: First steps in Italy, Paper EGU 2013-
12375. Mucciarelli and Priolo. Vienna, Austria : s.n., 2013. EGU General Assembly.
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64. Jaeger, J.C., Cook, N.G.W. and Zimmerman, R.W. Fundamentals of Rock Mechanics, Fourth Edition.
s.l. : Blackwell Publishing, 2007.
65. Use of natural gas compositional tracers to investigate gas migration from a gas storage field. Saba, T.
and Boehm, P.D. s.l. : Environmental Geosciences 19(2): 1-12, 2012.
66. Eminence Dome- Natural-Gas Storage In Salt Comes of Age, SPE 3433-PA. Medley, A.H. s.l. : Journal of
Petroleum Technology Vo. 24 No. 11, 1975.
67. Hilbert, L.B. and Saraf, V.K. Salt mechanics and casing deformation in solution-mined gas storage operations,
Paper ARMA 08-383. San Francisco, CA : 42nd U.S. Rock Mechanics Symposium and 2nd U.S.-Canada Rock
Mechanics Symposium, 2008.
68. Geomechanical response to season gas storage in depleted reservoirs: A case study in the Po River basin,
Italy. Teatini, et al. F02002, doi: 10.1029/2010JF001793, s.l. : Journal of Geophysical Research, 2011, Vol.
116.
69. API. RP 100-1 Hydraulic Fracturing-Well Integrity and Fracture Containment, 1st Edition. s.l. :API,
October 1, 2015.
70. —. RP 14B Design, Installation, Operation, Test, and Redress of Subsurface Safety Valve Systems, 6th Edition.
s.l. : API, September 1, 2015.
71. ISO. 22301 Societal security- Business continuity management systems- Requirements, 1st Edition. s.l. :
International Standards Organization, May 15, 2012.
72. CSA. Z731-03 Emergency Preparedness and Response. s.l. : Canadian Standards Association, 2014.
73. NFPA. 1600: Standard on Disaster/ Emergency Management and Business Continuity/ Continuity of Operations
Programs. s.l. : National Fire Prevention Association, 2016.
74. IOGCC, Energy Resources Committee. Natural Gas Storage in Salt Caverns: A Guide for State Regulators.
p. 16.
75. Comment on ‘Methane Emissions from Process Equipment at Natural Gas Production Sites in the U.S.:
Pneumatic Controllers. Howard, Touche. 2015, Environmental Science & Technology 49 (6), pp. 3981-
3982.
76. The status quo and technical development direction of underground gas storages in China. Ding, G., et al.
2015, Natural Gas Industry B2, pp. 535-541.
77. Benson, Robert, et al. Standoff Passive Optical Leak Detection of Volatile Organic Compounds Using a
Cooled InSb Based Infrared Imager. In. Vo. Paper 06-A-131. New Oreleans, LA : s.n., 2006.
78. USDOT, PHMSA [Docket No. PHMSA-2016-0016] . Pipeline Safety: Safe Operations of Underground
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U.S. Federal Register, February 2016. pp. 6334-6336.
116
79. Induced seismicity from underground gas storage: First steps in Italy. Vienna : s.n., 2005. EGU2013-
12375 presented at EGU General Assembly, 7-12 April 2013. pp. 37-38.
80. Bacharach, Inc. Bacharach Hi-Flow Sampler, Instruction 0055-9017, Operation and Maintenance. s.l. :
Bacharach, Inc., 2015.
81. Asset Management Standards. [Online] http://www.assetmanagementstandards.com/iso-55000-

standards-for-asset-management/.
82. International Association of Oil and Gas Producers. Asset integrity: the key to managing major incident
risks. 2008.
83. Gas Processors Association Midstream Association. [Online] https://www.gpaglobal.org/knowl-

edge-center/midstream-operations.
84. Allen, David T., Sullivan, David W. and Harrison, Matt. Response to Comment on Methane Emissions
from Process Equipment at Natural Gas production Sites in the U.S.: Pneumatic Controllers. s.l. : Environ-
mental Science & Technology 49(6): 3983-84. doi:10.1021/acs.est.5b00941.
85. Overview on underground storage of natural gas. Katz, D. L. and Tek, M. R. 1981, Journal of Petroleum
Technology 33, pp. 943-951.
117
Appendix B
List of Acronyms
118
119
Appendix C
List of Terms

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Acknowledgements
The States First Initiative would like to acknowledge the following individuals for their contributions to
this guide. (Listed alphabetically by group)
Development Leadership Team

Tim Baker, Director, Oil and Gas Division, Oklahoma Corporation Commission
Diana Burn, Eastern Engineering Supervisor, Colorado Oil and Gas Conservation Commission
Hal Fitch, Chief, Office of Oil, Gas, and Minerals, Michigan Department of Environmental Quality (Co-chair)
Ryan Hoffman, Director of Oil and Gas, Kansas Corporation Commission
Virginia Hullinger, Technical Services Manager - Oil and Gas Division, Oklahoma Corporation Commission
Rick Simmers, Chief, Division of Oil and Gas Resources, Ohio Department of Natural Resources (Co-chair)
Michael Sims, Engineer, Technical Permitting, Oil and Gas Division, Railroad Commission of Texas
Alan Walker, Supervising Oil and Gas Engineer , Division of Oil, Gas and Geothermal Resources, California
Department of Conservation
Contributing Authors
Andrew Adgate, UIC Manager, Division of Oil and Gas Resources, Ohio Department of Natural Resources
Jacob Isaac K. Abraham, Storage Reservoir Engineer, Dominion Energy
Andrew Adgate, UIC Manager, Division of Oil and Gas, Ohio Dept. of Natural Resources
Tom Alexander, Consulting Engineer, Environmental Defense Fund
Scott Anderson, Senior Policy Director, U.S. Climate and Energy Program, Environmental Defense Fund
Dan Arthur, President, ALL Consulting
James Bolander, President, JLB Engineering, L.L.C.
Alan Brannon, Consulting Engineer, Dominion Transmission
Vivian Chou, Division of Oil, Gas and Geothermal Resources, California Department of Conservation
Mike Cochran, Chief, Geology and Well Technology Section, Kansas Department of Health and Environment
Dan Collins, Senior Principal Geologist, GeostockSandia, LLC
Jessica Crossman, Chief, Underground Hydrocarbon Storage Unit, Kansas Department of Health and
Environment, Bureau of Water/ Geology and Well Technology Section
Phil Gibicar, Associate Oil and Gas Engineer, California Department of Conservation
L. Brun Hilbert, Jr., Ph.D., Principal Engineer, Exponent Failure Analysis Associates
John Kearney, Environmental Resource Analyst - Office of Oil and Gas, West Virginia Department of
Environmental Protection
Jeff Kennedy, Senior Geologist, ALL Consulting
Kurt Looff, Senior Principal Geologist, GeostockSandia, LLC
Berne Mosley, BSCE, Energy Projects Consulting, LLC
Gregg Parsons, Director of Functional Safety Technology, United Electric Controls
Adam Peltz, Senior Attorney, U.S. Climate and Energy, Environmental Defense Fund
Bob Pilko, Strategic Director, Blade Energy Partners
Avideh Razavi, Southern California Gas Company, Storage Risk Management
Teresa Rougon, Geologist DCL, Louisiana Office of Conservation
Richard A. Schultz, Ph.D., Senior Research Scientist- Overburden 7 Reservoir Geomechanics, University
of Texas at Austin, Center for Petroleum and Geosystems Engineering
122
Gene Smith, Assistant Chief - Permitting, Office of Oil and Gas, West Virginia Department of Environmental
Protection
Tom Tomastik, Senior Geologist and Regulatory Specialist, ALL Consulting
Robert F. Van Voorhees, Executive Director, Underground Injection Technology Council
Tom Williams, Senior Advisor, Environmentally Friendly Drilling
Robert Worstall, Deputy Chief, Division of Oil and Gas Resources, Ohio Department of Natural Resources
Daniel Wynne, Associate Oil and Gas Engineer, Division of Oil, Gas and Geothermal Resources, California
Department of Conservation
Independent Review Team

Grant Bromhal, Ph.D., U.S. Dept. of Energy, HQ, Office of Fossil Energy
Candace Cady, Utah Division of Water Quality, Underground Injection Control (UIC) Program
Joe Carmer, Phillips 66, Cavern Engineer
Catherine Foerster, Commissioner, Alaska Oil and Gas Conservation Commission
Mathieu Fournier, Vice President, Engineering & Operations, Niska Gas Storage
Doug Johnson, Senior Director, Economics/FTI Platt Sparks
Noah Matthews, USDOT, PHMSA, SW Region, Engineer (Inspector)
John McLennan, Ph.D., Department of Chemical Engineering, University of Utah
Berne Mosley, President, Energy Projects Consulting
Andy Theodos, Consultant, INGAA
Staff Support
Gerry Baker, Associate Executive Director, Interstate Oil and Gas Compact Commission
Carol Booth, Communications Manager, Interstate Oil and Gas Compact Commission
Amy Childers, Federal Projects Manager, Interstate Oil and Gas Compact Commission
Mike Nickolaus, Special Projects Director, Ground Water Protection Council
123

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Underground Gas Storage

Chapter 1: Introduction to Underground Gas Storage.......................................................................7

Chapter 2: Regulatory Framework of Underground Gas Storage (Federal and State)....................10

Chapter 3: Risk Management..............................................................................................................13

Chapter 4: State Permitting of Underground Gas Storage............................................................... 17

Chapter 6: Well Integrity Testing........................................................................................................ 41

Chapter 7: Reservoir Integrity............................................................................................................. 53

Chapter 9: Monitoring and Observation Wells.................................................................................. 78

Chapter 10: Wellhead and Surface Facilities.................................................................................... 82

Chapter 11: Emergency Response Planning..................................................................................... 98

Chapter 12: Temporary Abandonment, Well Closure, and Restoration............................................ 104

Appendix A: List of References........................................................................................................... 112

Appendix B: List of Acronyms.............................................................................................................. 118

Regulatory Framework of Underground Gas Storage (Federal and State)

State Permitting of Underground Gas Storage

Well Drilling, Construction and Conversion

Well Integrity Testing

Injection and Withdrawal Well Operations and Maintenance

Monitoring and Observation Wells

Wellhead and Surface Facilities

Emergency Response Planning

Temporary Abandonment, Well Closure, and Restoration

Figure 1-1 Underground Gas Storage Timeline

• Black- or brown-outs during unexpectedly warm summers, resulting in a lack of electric

The four area classifications are defined as follows:

• Class 1 Location with 10 or fewer buildings intended for human occupancy;

Major Issues and Concerns

i. Well work such as drilling, completion, workover, and conversion;

ii. Geological characterization of the storage reservoir or salt body;

iii. Well and reservoir integrity monitoring;

iv. Critical above-ground systems; and

v. Monitoring and observation wells.

b. Identification of Potential Threats and Hazards

c. Preventive and Mitigative Responses to Threats and Hazards

d. Approval and Certification Requirements

Major Issues and Concerns

State Permitting of Underground Gas Storage by Reservoir Type

i. Geologic Site Characterization for Porous Media

1. Reservoir characteristics – lithology, porosity, permeability, capillary pressure,

compartmentalization, current and historical fluid contacts, geomechanical

iii. Siting and spacing considerations:

1. Geologic reservoir features

iv. Operational requirements near sensitive areas:

v. Geologic Site Characterization for Solution Mined Salt Cavern Storage

vi. Geologic Site Characterization for Mined Cavern Storage

Potential geologic risks can include:

i. Engineering Considerations for Porous Media

1. Engineering analyses including: (10)

ii. Engineering Considerations for Solution Mined Caverns

1. The placement of the cavern from the edge of the salt

iii. Engineering Considerations for Mined Caverns

c. Area of Review (AOR)

d) Potential sensitive surface features;

iii. Elements of an AOR

iv. Corrective Action Strategies

d. Siting and Spacing Considerations

i. Physical Features Advantageous for Storage

1. A geologic structure with suitable capacity and flow potential to be commercially