(1) All wells within the area of review and that are in the same or a deeper zone as the gas storage reservoir, including directionally drilled wells that intersect the area of review in the same or deeper zone, shall be evaluated for the potential to allow fluid to migrate outside of the approved zone of gas storage. The operator should identify, and the Division confirm, wells which may require integrity testing or well logging in order to provide the requisite assurances that such wells will not act as conduits for fluid migration.

(2) Plugged and abandoned wells within the area of review shall have cement across all perforations and extending at least 100 feet above the highest of the top of a landed liner, the uppermost perforations, the casing cementing point, the water shutoff holes, or the approved gas storage zone. The Division may select plugged and abandoned wells to be re-entered, examined, re-plugged and abandoned, or monitored to manage identified containment assurance issues.

(3) If a plugged and abandoned well within the area of review does not meet the cement specifications of subdivision (a)(2), the Division may approve an alternative demonstration that the well will not be a potential conduit for fluid migration outside the approved gas storage zone. The Division's approval of such an alternative demonstration shall be supported by written findings by the Division that identify each plugged and abandoned well in the area of review that does not meet the cement specifications of subdivision (a)(2), specify how the well does not meet the requirements of subdivision (a)(2), and identify the basis for the Division's approval of the alternative demonstration.