DEP%20Regulatory%20Requirements%20Chapter%2078%20Subchapter%20D

1
DEP Regulatory RequirementsChapter 78 Subchapter
D

• Dave English
• Division of Compliance and Data Management
• Bureau of Oil and Gas Management

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Focus

• Significant changes to Subchapter D.
• Relevant revisions to Subchapters A, C, and E

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Oil and Gas Wells and the Middle Devonian
Marcellus Formation
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Chapter 78 Subchapter D addresses

• New well drilling, casing, cementing, completion
  and operational practices

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Chapter 78 Subchapter D addresses

• Currently operating oil and gas wells

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Chapter 78 Subchapter D addresses

• Plugging abandoned wells

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Rationale for Proposed Rulemaking Needs
Assessment

• New drilling and completion practices used to
  develop Marcellus and other unconventional
  formations
• Stray gas migration incidents (Marcellus and
  shallow oil and gas wells)
• Well control incidents (e.g. EOG incident June 3,
  2010 in Clearfield County)
• Hydraulic fracturing additive disclosure
• Mandatory production reporting Act 15

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Final Rulemaking 25 Pa. Code Chapter 78
Background

• Initial draft presented to TAB September 17, 2009
• DEP met with TAB and subcommittee four additional
  times (10/28/09, 1/14/10, 1/21/10, 3/25/10)
• Advanced Notice of Proposed Rulemaking Public
  comment period January 30, 2010 March 2, 2010
• Notice of Final Rulemaking Public comment period
  July 10, 2010 August 9, 2010
• Approval by EQB, IRRC, Attorney Generals Office.
• Final Regulations approved on publication in the
  Pennsylvania Bulletin February 5, 2011

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Final Rulemaking 25 Pa. Code Chapter 78
Significant Revisions

• Well Control
• Well Construction (casing and cementing
  operations)
• Mechanical Integrity of Existing Wells
• Gas Migration Response
• Well Reporting

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Future Rulemaking Next Regulatory Package

• Revisions to Plugging regulations 78.91-78.98
• Revisions to Subchapter C Environmental
  Protection Performance Standards
• Other revisions and modifications, i.e.,
  tweaks to Subchapter D

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Chapter 78. Oil and Gas Wells

• Subchapter A General Provisions

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Chapter 78. Oil and Gas Wells

• Subchapter A General Provisions new
  definitions added
• Conductor pipe
• Intermediate casing
• L.E.L. (lower explosive limit)
• Unconventional formations

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Chapter 78. Oil and Gas Wells

• Subchapter C Environmental Protection
  Performance Standards

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78.55. Control and Disposal Plan

• Plan must include operators pressure barrier
  policy that identifies barriers to be used during
  specific operations
• Plan must be available at the well site for
  review during drilling and completion activities
• List of emergency contact phone numbers for the
  area in which the site is located must be
  prominently displayed at the well site during
  drilling, completion, and workover activities

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Chapter 78. Oil and Gas Wells

• Subchapter D Well Drilling, Operation and
  Plugging

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78.72 Use of Safety Devices BOP Equipment(New
language in italics)

• BOP equipment to be used
• When drilling well intended to produce natural
  gas from an unconventional formation
• When drilling out frac plugs
• Where pressures are anticipated at the well site
  that may result in a loss of well control
• Where operator is drilling in an area where there
  is no prior knowledge of pressure or natural open
  flow
• When drilling conservation wells
• When drilling within 200 feet of a building

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78.72 Use of Safety Devices BOP Equipment

• Controls for the blow-out preventer must be
  accessible to allow actuation of the equipment
• Additional controls for the BOP with a pressure
  rating of 3000 psi, not associated with the rig
  hydraulic system, must be located at least 50 ft.
  away from the drilling rig such that the BOP can
  be activated if control of the well is lost

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78.72 Use of Safety Devices BOP Equipment

• Remote Accumulator for BOP Actuation

• Close-up of BOP Controls

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78.72 (d) BOP Equipment Testing

• Annular-type must test according to the
  manufacturers instructions, or by a professional
  engineer, before placing in service
• Equipment failing test must not be used until it
  is repaired/replaced and passes the test

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78.72(d) BOP Equipment Testing

• Ram-type must test for both pressure and ram
  operation before placing in service on the well
• Testing in accordance with API RP53
• If not in good working order, drilling must cease
  until BOP equipment is repaired/replaced and
  re-tested

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78.72 BOP Additional requirements

• All lines, valves and fittings between the
  closing unit and the BOP stack must be flame
  resistant and have a rated working pressure that
  meets or exceeds the requirements of the BOP
  system
• When BOP is installed or required, an individual
  must be present at the well site with a current
  certification from a well control course
  accredited by the International Association of
  Drilling Contractors or other organization
  approved by DEP
• Pressure barriers identified in drilling and
  completions operations requiring two mechanical
  barriers must be capable of being tested. This
  does not mean that all operations utilizing BOP
  equipment must employ two mechanical barriers
• A stripper barrier or stripper heads are not
  considered adequate barriers
• A coiled tubing rig or hydraulic workover unit
  with appropriate BOP equipment must be utilized
  during post-completion cleanout operations in
  unconventional formations penetrated by a
  horizontal wellbore
• DEP will be developing pressure barrier policy

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Chapter 78 Major Changes to Well Construction and
Cementing and Other Changes to Subchapter D

• Revised casing standards
• New requirement for casing and cementing plan
• New Section on lost circulation
• Revised cement standards
• New Section on mechanical integrity of existing
  wells

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78.73 General Provisions Revised language

• Operator must construct well in accordance with
  this Chapter and ensure that the integrity of the
  well is maintained and health, safety,
  environment and property are protected
• Operator must prevent gas, oil, brine, completion
  and servicing fluids, and any other fluids or
  materials from below the casing seat from
  entering fresh groundwater, and shall otherwise
  prevent pollution or diminution of fresh
  groundwater
• Reduced pressure at surface or coal protective
  casing seat may not exceed 80 of the hydrostatic
  pressure of the surrounding fresh groundwater
  (0.8 X 0.433) X casing length (ft)

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78.73 General Provisions New Language

• Excess gas encountered during drilling,
  completion or stimulation must be flared,
  captured or diverted from the drilling rig in a
  manner that does not create a hazard to public
  health or safety
• Wells must be equipped with a check valve to
  prevent backflow from pipelines into well (except
  gas storage wells)

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78.75a. New Section Area of Alternative Methods

• DEP may designate an area of alternative methods
  if it determines that well drilling and operating
  requirements beyond those provided in this
  Chapter are necessary
• Notice of proposed area of alternative methods
  will be published in PA Bulletin
• Wells drilled within this area must meet the
  requirements specified by the Department unless
  the operator obtains DEP approval to drill,
  operate or plug the well in a different manner
  that is at least as safe and protective of the
  environment as the requirements in the area of
  alternative methods

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78.76. Drilling within a Gas Storage Reservoir

• An operator proposing to drill in a gas storage
  area (or the surrounding reservoir protective
  area.normally 2000 ft) must send a copy of the
  location plat, the drilling/casing/cementing
  plan, and the anticipated date drilling will
  commence to the gas storage reservoir operator
• New language requires that information above also
  be sent to the Department along with proof of
  notification to the gas storage reservoir
  operator DEP must approve the proposal prior to
  drilling

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78.81-78.87. Casing and Cementing
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78.81 General Provisions

• Casing and cementing must
• Allow effective control of the well at all times
• Prevent the migration of gas and other fluids
  into fresh groundwater
• Prevent the pollution or diminution of fresh
  groundwater
• Prevent the migration of gas or other fluids into
  coal seams

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78.82. Use of Conductor Pipe

• New rulemaking additions
• Conductor pipe shall be installed in a manner
  that prevents the subsurface infiltration of
  surface water or fluids
• Conductor pipe shall be made of steel

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78.83. Surface and Coal Protective Casing and
Cementing Procedures New Language

• Wells drilled, altered, reconditioned or
  recompleted after final regulations may not
  utilize surface casing, or any casing functioning
  as water protection casing, unless
• The well is an oil well where the operator does
  not produce any gas generated by the well and the
  annulus between the surface casing and the
  production pipe is left open
• The operator demonstrates that the pressure in
  the wellbore at the casing seat is no greater
  than the pressure allowed by (new) 78.73(c) (0.8
  X 0.433 psi/ft X casing length (ft). Operator
  must install a working pressure gauge that can be
  inspected by the Department
• Determination may be with a pressure test to 80
  of the calculated hydrostatic pressure at the
  surface casing seat

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78.83. Surface and Coal Protective Casing and
Cementing Procedures New Language

• Surface casing may not be set more than 200 feet
  below the deepest fresh groundwater except as
  necessary to set the casing in consolidated rock
• Surface casing hole must be drilled using air,
  freshwater, or freshwater-based drilling fluid
• Wellbore must be conditioned to ensure an
  adequate cement bond between the casing and
  formation prior to cementing
• Centralizers at least one within 50 ft. of the
  surface casing seat, then in intervals no greater
  than every 150 ft. above the first centralizer

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78.83. Surface and Coal Protective Casing and
Cementing Procedures New Language

• Operator must document the depth of the fresh
  groundwater zone in the well and record if
  additional fresh groundwater is encountered below
  the surface casing
• Coal protective string must have at least two
  centralizers, one within 50 ft. of the casing
  seat and the second within 100 ft. of the surface
• When cementing in lost circulation zones, using a
  pour string/tremie pipe to cement above the
  cement basket does not constitute permanently
  cementing the surface or coal protective casing
  pursuant to new Section 78.78b (relating to
  Casing and Cementing Lost Circulation)

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78.83a. Casing and Cementing Plan New Section

• Operator must prepare a casing and cementing plan
  showing how the well will be drilled and
  completed
• Plan must include
• Anticipated depth and thickness of any producing
  formation, expected pressures and anticipated
  fresh groundwater zones, and the method or
  information by which the depth of the deepest
  fresh groundwater was determined (discussed
  later)
• Diameter of the borehole
• Casing type, depth, diameter, wall thickness, and
  burst pressure rating
• Cement type, additives, and estimated amount
• Estimated location of centralizers
• Proposed borehole conditioning procedures
• Alternative methods or materials as required by
  DEP as a condition of the well permit
• Plan must be available at the well site for
  review, may be required by the Department for
  review and approval (for permit issuance), and
  any revisions to the plan made as a result of
  on-site modifications must be documented by the
  operator, initialed and dated, and available for
  DEP review

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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Regulatory definition of deepest fresh
  groundwater
• The deepest fresh groundwater bearing
  formation penetrated by the wellbore as
  determined from drillers logs from the well or
  from other wells in the area surrounding the
  well or from historical records of the normal
  surface casing seat depths in the area
  surrounding the well, whichever is deeper.

Buckwalter Moore (2006)
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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Standard groundwater quality classification
  schemes
• Fetter (1994)
• Fresh 0 to 1,000 mg/l TDS
• Brackish 1,000 to 10,000 mg/l TDS
• Saline 10,000 to 100,000 mg/l TDS
• Brine gt100,000 mg/l TDS
• Quiñones-Aponte Wexler (1995)
• Fresh lt1,000 mg/l TDS
• Slightly Saline (brackish) 1,000 to 3,000 mg/l
  TDS
• Moderately Saline (brackish) 3,000 to 10,000
  mg/l TDS
• Very Saline (saltwater) 10,000 to 35,000 mg/l
  TDS
• Brine gt35,000 mg/l TDS

Olsthoorn (2008)
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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Some numerical considerations in Pennsylvania
• Delaware River Basin Commission (DRBC)
• Freshwater is water containing less than 1,000
  mg/l of dissolved solids, most often salt.
• 40 CFR 144.3 United States EPA
• Underground source of drinking water (USDW)
  means an aquifer or its portion (a)(1) Which
  supplies any public water system or (2) Which
  contains a sufficient quantity of ground water to
  supply a public water system and (i) Currently
  supplies drinking water for human consumption or
  (ii) Contains fewer than 10,000 mg/l total
  dissolved solids and (b) Which is not an
  exempted aquifer.
• 10,000 mg/l is FAR TOO SALINE for drinking water
  supplies in this Commonwealth

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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Numerical considerations elsewhere
• Texas 3000 mg/l TDS
• Oklahoma 10,000 mg/l TDS
• Illinois 10,000 mg/l TDS
• New York 1,000 mg/l TDS
• Alberta 4,000 mg/l TDS to a depth not to exceed
  600 meters

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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Numerical considerations (31 states surveyed)

GWPC (2009)
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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Numerical considerations (15 states with
  quantitative definition)

GWPC (2009)
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Section 78.83a.(a)(1) Methodology for
Determining Deepest Fresh Groundwater

• Techniques for defining base of deepest fresh
  groundwater aquifer
• Estimating fracture zone yield and measuring
  specific conductance using a calibrated meter
  during drilling
• Standard water well geophysical logging of
  tophole specific conductance critical, but
  other logs may help corroborate water-bearing
  zones
• More sophisticated geophysical logging of
  tophole per EPA UIC recommendations (SP log or
  resistivity/porosity log)
• Installation of monitoring wells at well pad and
  groundwater testing
• Information from offset wells including water
  well testing, geophysical log data, and surface
  casing set depths considering water well
  offsets alone will typically not be enough

Williams (2010)
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78.83b. Casing and Cementing Lost Circulation
New Section

• If cement used to permanently cement the surface
  or coal protective casing cannot be circulated to
  the surface due to lost circulation, the operator
  shall determine the top of cement, notify the
  Department and meet one of the following
• Run additional string 50 deeper than where
  circulation was lost, cement back to lost
  circulation string casing seat, vent the annulus,
  meet pressure requirements of 78.73(c)
• Run production casing and set on packer, vent the
  annulus
• Run production casing to formation being
  produced, cement to surface
• Run intermediate and production casing and cement
  both strings to surface
• May also emplace supplemental cement in addition
  to the above

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78.83b. Casing and Cementing Lost Circulation
New Section- continued

• Policy cement returns to surface followed by
  cement drop may be considered to be permanently
  cemented if the DEP inspector determines an
  adequate amount of surface casing cement was
  placed above the seat.
• Top of cement determination must be made and
  notification given to the DEP inspector for
  evaluation of casing cement adequacy and
  subsequent approval for remedial casing options.
  Must be done prior to continuation of drilling
  (e.g. no TOC determination after well
  drilled/completed to TD).
• In addition to remedial casing options, the
  minimum amount of surface casing cement above
  seat and corresponding maximum amount of
  uncemented surface casing will be made on a
  case-by-case basis by DEP. In certain cases, the
  well may need to be plugged and abandoned if only
  a minimal amount of cement exists above the
  surface casing seat (a catastrophic loss of
  cement).
• DEP may require remedial cementing from surface
  and/or pressure-testing of the casing string to
  determine integrity of the well and ensure
  protection of the surface casing seat.

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78.83c. Intermediate and Production Casing New
Section

• Prior to cementing intermediate and production
  casing, the borehole, mud, and cement must be
  conditioned to ensure an adequate cement bond
  between the casing and the formation
• If a well is to be equipped with intermediate
  casing, centralizers must be used and the casing
  must be cemented to the surface by the
  displacement method gas may be produced off the
  intermediate casing if a shoe test demonstrates
  that all gas will be contained within the well
  and a relief valve is installed at the surface
  that is set at less than the shoe test pressure
  (this pressure must be recorded in the completion
  report)
• Except as provided by 78.83, each well must be
  equipped with production casing centralizers
  must be used the production string may be set on
  a packer or cemented in place annular space must
  be cemented to a point at least 500 ft. above the
  TVD or at least 200 ft. above the uppermost
  perforations, whichever is greater.

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78.84. Casing Standards Original Language

• Casing must withstand the effects of tension, and
  prevent burst and collapse during its
  installation, cementing, and subsequent drilling
  and producing operations
• Casing must be equipped with appropriate
  equipment to center the casing through the hole
  in fresh groundwater zones
• Coal protective casing must have a minimum wall
  thickness of 0.23 inches

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78.84. Casing Standards New Language

• All casing must be a string of new pipe with a
  pressure rating at least 20 greater than the
  anticipated maximum pressure
• Used casing may be approved but must be pressure
  tested after cementing and before continuation of
  drilling a passing pressure test is holding the
  maximum anticipated pressure for 30 minutes with
  no more than a 10 change in pressure. Pressure
  testing should be done before significant gel
  strength has developed in the cement. API RP65
  Part 2
• New or used plain end casing that is welded must
  be pressure tested and hold the maximum
  anticipated pressure for 30 minutes with no more
  than a 10 change in pressure

• Welded casing must be welded using at least three
  passes with the joint cleaned between each pass
• Welder must be trained and certified in the
  applicable API, ASME, AWS or equivalent standard
  for welding casing and pipe or an equivalent
  training and certification program a person with
  10 or more years of experience welding casing
  does not need to be certified Note that the
  certification requirements do not kick in until
  August 5, 2011

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78.85. Cement Standards Original Requirements

• Cement must resist degradation by chemical and
  physical conditions in the well
• Minimum compressive strength of 350 psi in
  accordance with API spec 10 cement must set for
  a minimum period of eight (8) hours prior to the
  resumption of actual drilling
• Operator may request approval from DEP to reduce
  the cement setting time when special cement or
  additives are used

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Chapter 78.85 New Cement Standards

• Revised cement standards
• Cement must protect casing from corrosion and
  geochemical, lithologic and physical conditions
  of the surrounding wellbore
• Gas-block additives and low fluid-loss slurries
  in areas of known shallow gas-producing zones are
  required
• Zone of critical cement around surface casing
  seat
• True eight-hour WOC (wait on cement) before
  casing may be disturbed
• One-day notification to DEP prior to cementing of
  surface casing
• Cement job log must be prepared and available at
  the well site during drilling operations and
  maintained for at least five years

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Chapter 78.85 New Cement Standards

• Zone of Critical Cement
• Applies to bottom 300 ft. of surface casing
  cement, or entire cemented string if the surface
  casing string is less than 300 ft
• Cement must achieve a 72-hour compressive
  strength of 1200 psi
• Cement must achieve a free-water separation of no
  more than 6 milliliters of water per 250
  milliliters of cement

49
Chapter 78.85 New Cement Standards

• Eight-hour WOC (wait on cement) casing may be
  not be disturbed by
• Releasing pressure on the cement head if check
  valves on float shoe are secure, the pressure may
  be released at a continuous, gradual rate after
  four hours
• Nippling up on or in conjunction to the casing
• Slacking off by the rig supporting the casing in
  the cement sheath
• Running drill pipe or other mechanical devices
  into or out of the wellbore with the exception of
  a wireline used to determine the top of cement

50
Chapter 78.85 New Cement Standards

• Cement job log required components
• Mix water temperature and pH
• Type of cement with listing and quantity of
  additives
• Volume, yield, and density in ppg of the cement
• Amount of cement returned to the surface
• Cementing procedural information including a
  description of the pumping rates in bbl/min,
  pressure in psi, time in min, and the sequence of
  events during the cementing operations
• Logs must be available for all cement jobs done
  after 2/5/2011.

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Section 78.88 Mechanical Integrity of Operating
Wells

• Quarterly monitoring program will begin first
  quarter after the Department develops a standard
  form for collecting mechanical integrity data
• Key monitoring/testing provisions
• Pressure monitoring associated with production
  casing
• Pressure monitoring in annular space associated
  with production casing
• Pressure monitoring at relevant casing seat
• Checking well fluid level in production casing
• Corrosion and equipment deterioration survey
• Monitoring for leaking gas
• Clear methodology for addressing over-pressured
  wells
• Flexibility for Department to require additional
  testing
• Report detailing results of quarterly inspections
  must be submitted to Department annually by
  January 31 of year following inspections

52
Operating Wells 78.88 Mechanical Integrity of
Operating Wells

• For wells not in compliance, the operator must
  immediately notify DEP and take corrective action
  to mitigate the excess pressure on the surface
  casing seat, coal protective casing seat, or
  intermediate casing seat when the intermediate
  casing seat is used in conjunction with the
  surface casing seat to isolate fresh groundwater
• Corrective action occurs in the following
  hierarchy
• Operator must reduce the shut-in or producing
  back pressure to achieve compliance with 78.73(c)
• Operator must retrofit the well by installing
  production casing to reduce pressure on the
  casing seat to achieve compliance with 78.73(c)
  the annular space surrounding the production
  casing must be open to the atmosphere production
  casing must either be cemented in place or
  installed on a permanent packer
• Operator must notify DEP 7 days prior to
  initiating corrective action

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Section 78.88 Mechanical Integrity of Operating
Wells

• Potential well problems

54
Section 78.88 Mechanical Integrity of Operating
Wells

• Potential well problems overpressuring

Harrison (1985)
55
Section 78.88 Mechanical Integrity of Operating
Wells

• Potential well problems overpressuring
  (continued)

Harrison (1985)
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Section 78.88 Mechanical Integrity of Operating
Wells

• Potential well problems overpressuring
  (continued)

Harrison (1985)
57
Section 78.88 Mechanical Integrity of Operating
Wells

• Potential well problems cement failures and
  inadequate casing/tubing

58
Section 78.88 Mechanical Integrity of Operating
Wells

• Some notable items
• Operators will not be required to retrofit older
  wells for pressure monitoring
• Overpressured conditions or problems noted
  during well corrosion/equipment deterioration
  survey must be reported immediately
• 7-day notification for wells that will be
  retrofitted with production casing

59
Section 78.88 Mechanical Integrity of Operating
Wells

• Some notable items (continued)
• Water protection depth will apply in older wells
  where fluid levels can be determined
• Pressure monitoring locations will vary as a
  function of well construction

60
Section 78.88 Mechanical Integrity of Operating
Wells

• Department projects underway or being considered
  to assist the industry
• Development of comprehensive technical
  guidance/instructions to accompany form to ensure
  consistency and ease of implementation
• Development of tracking system for problems
  noted to help identify what well maintenance
  procedures are critical during various points
  throughout operational history

M.I.C.S.(2011)
61
78.89. Stray Gas Mitigation Response

• Establishes protocol for operator, DEP, and local
  emergency response agencies to determine the
  nature of a gas migration incident, assess the
  potential for hazards to public health and
  safety, and mitigate any hazard posed by the
  release of natural gas
• Operator, in conjunction with the Department and
  local emergency response agencies, must take
  measures necessary to ensure public health and
  safety

62
Section 78.89 Gas Migration Response

• Stray gas migration incidents continue to
  represent one of the most significant problems
  associated with oil and gas development in the
  Commonwealth
• Previous discussion on well integrity highlighted
  some problems that result in stray gas migration
  incidents
• Other contributing factor in Pennsylvania is the
  number of legacy/abandoned wells that were never
  properly plugged and whose locations remain
  unknown
• Stray gas migration associated with Marcellus
  Shale development has been geographically
  isolated

63
Section 78.89 Gas Migration Response

• Physical properties of methane
• The simplest of all paraffin hydrocarbon gas
• Flammable, colorless, and odorless
• Specific gravity 0.555
• Explosive range 5-15
• Maximum solubility in water 26-32 mg/l at
  standard temperature and pressure, but higher at
  depth due to pressure regime

Baldassare (2009)
64
Section 78.89 Gas Migration Response

• Factors influencing stray gas migration
• Changes in barometric pressure
• Soil and bedrock porosity/permeability
• Pore water
• Temperature contrasts
• Other meteorological conditions including
  precipitation (rain vs. snow) and ground cover
  (layer of snow or frozen ground)

Figure courtesy of John Harper, PA Topographic
and Geologic Survey
65
Section 78.89 Gas Migration Response

• Types of gas and isotopic signatures (Baldassare,
  2009)
• Subsurface microbial gas (deep- sea sediments
  and drift gas)
• Near-surface microbial gas (marsh gas and
  landfill gas)
• Thermogenic gas (natural gas and coalbed gas)

Baldassare (2009)
66
Section 78.89 Gas Migration Response

• Locations total number of stray gas cases since
  1987 compared to all permitted drilling activity

67
Section 78.89 Gas Migration Response

• Location of Marcellus Shale stray gas cases
  since 2008 compared to Marcellus Shale drilling
  activity between 2008 and 2010

68
Section 78.89 Gas Migration Response

• Recent trends in stray gas incidents Marcellus
  Shale versus non-Marcellus Shale wells

69
Section 78.89 Gas Migration Response

• Key components of stray gas regulations
• Operators notified about a potential stray gas
  migration incident must immediately conduct an
  investigation to determine nature of incident,
  assess potential hazards, and mitigate hazards
  as needed
• Response actions are tiered based on the
  severity of the incident
• Investigation closure dependent upon Department
  approval

70
Section 78.89 Gas Migration Response

• A three-tiered approach
• Category 1 (Immediate Threat) detectable
  concentrations equal to or greater than 10 of
  the lower explosive limit (LEL) or combustible
  gas in a building or structure(s), or otherwise
  deemed Category 1 by the Department.
• Category 2 (Potential Threat) detectable
  concentrations less than 10 of the LEL of
  combustible gas in a building or structure(s),
  and/or combustible gas greater than 50 of the
  LEL in the headspace of a water well, and/or
  visual or audible evidence of stray gas bubbling
  through a water well column or surface body,
  and/or detectable concentrations of stray gas in
  the soils, and/or concentrations of dissolved
  methane in water at or above 25 of the lower
  solubility limit for methane (7 mg/l).
• Category 3 (No Apparent Threat) none of the
  above conditions were met. If conditions
  indicate methane in groundwater at concentrations
  above 0.5 mg/l, but below 7 mg/l, continued
  monitoring is necessary to ensure that
  concentrations do not trend to a Category 2
  potential threat.

71
Section 78.89 Gas Migration Response

• Department projects underway or being considered
  to assist the industry
• Development of stray gas migration technical
  guidance document to compliment new regulations
• NCRO Stray Gas Prevention Program
• Series of joint technical guidance and public
  outreach documents with Emergency Response staff

72
Plugging 78.91 78.98

• Second attempt to remove production casing after
  cutting, ripping, shooting or other method
  approved by the Department.
• Cement plug now to be placed across oil or
  gas-bearing strata (rather than gel).
• Next regulatory package will significantly revise
  plugging regulations.

73
Chapter 78. Oil and Gas Wells

• Subchapter E Well Reporting

74
Chapter 78. Oil and Gas Wells

• Subchapter E Well Reporting Revisions
• 78.121. Production reporting Incorporates the
  requirements of Act 15 of 2010 which mandates
  semi-annual reporting of production of Marcellus
  Shale wells (8/15 2/15) Non-Marcellus wells
  report annually (2/15) Information is posted on
  DEPs website
• 78.122. Well record and completion report
  Completion report to include descriptive list of
  chemical additives used in the stimulation fluid
  the percent by volume of those additives a list
  of hazardous chemicals used in the stimulation
  fluid (MSDS/CAS ) the percent by volume of
  those hazardous chemicals the total volume of
  water used a list of water sources used pursuant
  to an approved water management plan the total
  volume of recycled water used and the pump rate
  and pressure used in completing the well
• Operator must designate separate sheet as
  confidential or a trade secret DEP will prevent
  disclosure of confidential information to the
  extent provided by the Right-To-Know Law
• Well record adds certification by operator that
  well has been constructed in accordance with this
  Subchapter and any permit conditions imposed by
  DEP

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Thank youdaenglish_at_state.pa.us(717) 772-2199