A copy of PA HB 1205 can be found by following this link - HB 1205
Based on a review of this house bill - I like the following items:
1. Increasing the baseline radius to 2000 feet - but this does not address the issue of the horizontal leg of the well and does not really address local geology. It is important to note that it is my professional opinion that the fracing process or horizontal leg of the well is not the point or portion of the drilling that is a primary area of concern. The primary area of concern is the area around the well and drilling pad and the vertical wellbore construction and prevent of surface leaks and spills. A company needs to have a Spill Prevention and Action Plan.
2. Increasing the time line - I am not sure 2-years is the best number, but it is better than 6 months.
3. The issue of prior contamination and timing in the law- the wording could be interpreted to mean that the baseline quality is solely based on an analysis that was collected 30 days prior to drilling. This is not appropriate - If this raises a question in my mind - this is a potential weakness in the wording of the law.
4. The notification time line is not appropriate -the private well owners should be notified within 48 hours if there is a problem with the water quality that may pose a health concern and receive a written report in 30 to 60 days - 10 days for written is creating paper work - they need to get a copy of the testing results and there should be some form of education to help them understand the results and take action if needed.
5. Follow up water testing as written is not appropriate - if the time line is two years. Then the gas company should test the water at least once a year for two years. The follow-up testing should include the parameters tested in the initial baseline, plus any parameters specific to the chemicals or processes used in developing the well (see comment 8).
6. The proposed law does not address the issue of a possible contaminant event or concern. The owner should have the right to have the Commonwealth Investigate water quality contamination events and the cost reimbursed by the Gas Company or a fund established by the Gas Company- if a gas company is found responsible. If some other agent is found responsible - the PADEP should act on behalf of the private citizen to correct this issue.
7. A fund should be established to help improve, fix, or abandon wells (Cement or grout them closed) that are identified as contaminated during the initial baseline assessment or found to be vulnerable pathways for future contamination. It is in the benefit of the Commonwealth to eliminate this route of contamination or potential impact to the community.
8. Frac chemicals - I believe the listing of chemicals and MSDS sheets a company may used in the process is listed in the permit application to the state. At a minimum, the Spill Prevention Plan should require the company to have MSDS sheets for these chemicals on-site, spill containment systems for these chemicals, and provide a summary of the chemicals and quantities used in the frac process or other processes.
Just my thoughts
Brian
Brian: I believe the baseline radius should extend 1,000 feet beyond the end of any lateral wellbore. Thoughts?
ReplyDeleteDon W. - Wilkes EnviSci '78
First all - I glad to see you are well.
ReplyDeleteRegarding your question, I think it is important to keep the following in mind:
1. The area most vulnerable to potential impact in a reasonible period of time would be the area surrounding the wellbore and drilling site. The wellbore should be installed and designed to minimize this potential. This could be done by using multiple strings or casings rather than 1 and extending the casing to seal off shallow gas deposits. In addition, the cement process should be inspected and adequate time given for the cement to cure.
2. Proposed regulations are currently increasing this radii to 2000 feet around the well. (if passed)
3. On the horizontal leg - this is less of a potential for impact and if there is a potential for impact it would likely be based on the horizontal extent of the fractures and openings that are generated by the process. This distance is not the same for each company. For some companies they are reporting fractures off the horizontal leg that extend only 100 feet; whereas, some suggest up to 400 feet.
4. Because of comment 3 - I find it difficult to create a fixed radius along horizontal leg. I have recommended companies consider monitoring within this area and base their monitoirng on the estimated horizontal extent of fractures (I do not think this should be put into a regulation because of the variability) and some companies initially decided to conduct baseline testing within 1 mile.
5.I have also suggested that the drilling companies install some shallow groundwater monitoring wells around the pad to check water quality and monitor what is going on during "drilling" and the frac process and possibly monitoring an exisitng well along the horizontal leg.
6. I am more concerned about the drilling and construction of the vertical portion of the wellbore than the frac in the horizontal leg. Personally- Because of the lack of construction standards for private wells - I would like to see Natural Gas Wells further away from private wells or we need to back a significant effort to identify and fix poorly constructed private wells.
Just my thoughts
Glad to see you are always learning.
Brian
During the fracturing process - the process may create temporary partings out 1000 to 1500 feet, but when the pressure is removed the partings past about 500 feet close. Therefore, a testing out of 500 to 1000 feet from the horizontal leg would be a good estimate. This monitoring should also include water level in one or more deep wells.
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