The following are my comments related to PA House Bill 2213 - the full text of the regulations can be found at the following website.
1.I like the provisions for inspections - but does the PADEP field staff have the training they need and do they have the tools and equipment to really inspect a cement seal that is 2000 feet down? Therefore, the bill should require certification by the driller and a third party inspection service- paid by the Gas Company.
2. Fees should cover the cost of inspections, additional water testing, responding to complaints, etc - the full cost of the program.
3. I am ok with the 2500 foot from the drilling pad, but there are no provisions for the horizontal leg of the well and the 6 month time frame is inadequate. Point groundwater moves slowing - less than 0.1 ft per year to 3 ft per day - I would recommend at least 1 year to 2 years may be better.
For the horizontal leg, the gas companies can create fractures out 100 to 400 feet from the horizontal leg. Therefore, the testing zone should be 2500 foot, plus at least 100 foot on either side of the horizontal leg of the well. This could be adjusted based on the final report for the well when the company reports the extent of the horizontal fracturing.
4. Section 4 - if the specific chemical composition can not be disclosed the trade name should be released, MSDS sheet, and volume of the chemical used. All this information should be disclosed in the permit application and in a well completion report that is submitted for each well in a timely manner.
This information should also be available at the municipality were the well is located- so the public has access.
5. Bonding requirements seem better. Also - I support that no blanket bonds be issued for the Marcellus Shale and each well not drilling pad should be considered as a well. Therefore, a drilling pad with 6 wells should be six bonds.
6. Local ordinances should be permitted to control or prevent installation of well, temporary structures, or permanant structures in floodplains. Plus local agency should control nuisance issues, road bonding, road use and access, and the accessory development that will likely occur, such as field offices, temporary septic permits, holding tanks, etc.
7. Regulations should apply to Marcellus Shale and other other formations where the development technique is depolyed.
Thanks Brian Oram, PG B.F. Environmental Consultants Inc. 15 Hillcrest Drive Dallas, PA 18612 Thanks for your leadership
Showing posts with label abandoned oil gas wells. Show all posts
Showing posts with label abandoned oil gas wells. Show all posts
Monday, April 5, 2010
Saturday, April 3, 2010
DEP to require companies to list chemicals used at each gas well
DEP to require companies to list chemicals used at each gas well
Direct Url - http://thetimes-tribune.com/news/dep-to-require-companies-to-list-chemicals-used-at-each-gas-well-1.711837
(Note this is not my work)
by laura legere (staff writer)
Published: April 2, 2010
CLARKS SUMMIT - Gas drilling companies operating in Pennsylvania will have to provide the names of chemicals used at each well site under regulations proposed by the state's environmental oversight agency.
The requirement, which was added last week to the most recent draft of proposed well construction regulations, was discussed by the head of the Department of Environmental Protection's Bureau of Oil and Gas Management at a meeting of the Abington Council of Governments Thursday night.
The new proposal would require each company to include a list of the names and the total volume of chemicals used to hydraulically fracture each well as part of a report the drillers submit once each well is completed.
The regulations, if approved, will give a well-by-well picture of the chemicals that are mixed with water and sand and injected underground to break apart gas-bearing rock formations including the Marcellus Shale.
Scott Perry, who was appointed director of the bureau in mid-January, said the requirement was just added now to the suite of regulations first proposed in September "because we heard what the concerns of the public were."
Although drillers provide the department with Material Safety Data Sheets that outline what chemicals the companies plan to use at a well site, Mr. Perry said that prior to the new completion report requirements "we didn't ask for what chemicals were used to frack a well.""It's important for transparency, for people to be able to see what's going on," he said. The list will not include the volumes of individual chemicals used at a well site, he said.
He also insisted that even though the department is proposing to strengthen its disclosure requirements, hydraulic fracturing is not a threat to water supplies.
"There has never been any evidence of fracking ever causing direct contamination of fresh groundwater in Pennsylvania or anywhere else," he said.
"If I honestly thought that fracking was causing a direct communication with groundwater resources, I wouldn't be talking about how we have a chemical list. That is the ultimate half-measure. I would be saying, 'This cannot occur.' "
The proposed regulations will be presented at a meeting of the Environmental Quality Board on May 19, Mr. Perry said.
Contact the writer: llegere@timesshamrock.com
*******
This was part of my comments to the proposed legistation - I still believe it does not require the release of proprietory data - but it is important to note the MSDS sheets and information have always been included as part of the permitting process. Also - this report will be generated after completion to document what was actually used.
Looking for environmental or water quality monitoring equipment for field work.
Direct Url - http://thetimes-tribune.com/news/dep-to-require-companies-to-list-chemicals-used-at-each-gas-well-1.711837
(Note this is not my work)
by laura legere (staff writer)
Published: April 2, 2010
CLARKS SUMMIT - Gas drilling companies operating in Pennsylvania will have to provide the names of chemicals used at each well site under regulations proposed by the state's environmental oversight agency.
The requirement, which was added last week to the most recent draft of proposed well construction regulations, was discussed by the head of the Department of Environmental Protection's Bureau of Oil and Gas Management at a meeting of the Abington Council of Governments Thursday night.
The new proposal would require each company to include a list of the names and the total volume of chemicals used to hydraulically fracture each well as part of a report the drillers submit once each well is completed.
The regulations, if approved, will give a well-by-well picture of the chemicals that are mixed with water and sand and injected underground to break apart gas-bearing rock formations including the Marcellus Shale.
Scott Perry, who was appointed director of the bureau in mid-January, said the requirement was just added now to the suite of regulations first proposed in September "because we heard what the concerns of the public were."
Although drillers provide the department with Material Safety Data Sheets that outline what chemicals the companies plan to use at a well site, Mr. Perry said that prior to the new completion report requirements "we didn't ask for what chemicals were used to frack a well.""It's important for transparency, for people to be able to see what's going on," he said. The list will not include the volumes of individual chemicals used at a well site, he said.
He also insisted that even though the department is proposing to strengthen its disclosure requirements, hydraulic fracturing is not a threat to water supplies.
"There has never been any evidence of fracking ever causing direct contamination of fresh groundwater in Pennsylvania or anywhere else," he said.
"If I honestly thought that fracking was causing a direct communication with groundwater resources, I wouldn't be talking about how we have a chemical list. That is the ultimate half-measure. I would be saying, 'This cannot occur.' "
The proposed regulations will be presented at a meeting of the Environmental Quality Board on May 19, Mr. Perry said.
Contact the writer: llegere@timesshamrock.com
*******
This was part of my comments to the proposed legistation - I still believe it does not require the release of proprietory data - but it is important to note the MSDS sheets and information have always been included as part of the permitting process. Also - this report will be generated after completion to document what was actually used.
Looking for environmental or water quality monitoring equipment for field work.
Tuesday, March 9, 2010
25 PA Code 78 Oil and Gas Wells - Comments on New Regulations
Comments from
Mr. Brian Oram,
Our comments are as follows:
B.F. Environmental Consultants Inc. is in support of the proposed changes to 25 PA Code 78 Oil and Gas Wells as outlined in the draft regulations. The changes provide a significant improvement over existing regulations and help to protect local citizens and the environment. Based on a review of the draft regulations, the primary concerns were identified:
a. copies of permit applications be available for review at a local PADEP office;
b. it would be preferable to have a minimum annular space of at least 2 inch and not 1-inch around the casing;
c. placement of the casements should be based on a field measurement of conductivity to ensure that the well is protecting both the freshwater zone and the water bearing zone with a total dissolved solids of < 10,000 mg/l. This is an EPA requirement, i.e., USDW- Determination of Underground Sources of Water;
d. in all cases, a multiple casing or string approach should be used to separate the shallow and deep groundwater flow system- because of the fractured nature of the local bedrock it is not appropriate to use a single string to seal off a freshwater, saline, or brackish water zones;
e. Copies of frac chemicals and other chemicals used at developing or maintaining these wells with copies of MSDS sheets should be available at a location when each community or municipality; and
f. If possible, the third party inspectors should be individuals that carry a license or certification by Pennsylvania and have specific training and experience to provide this service.
Just my comments - related to proposed regulations.
Mr. Brian Oram
Mr. Brian Oram,
Our comments are as follows:
B.F. Environmental Consultants Inc. is in support of the proposed changes to 25 PA Code 78 Oil and Gas Wells as outlined in the draft regulations. The changes provide a significant improvement over existing regulations and help to protect local citizens and the environment. Based on a review of the draft regulations, the primary concerns were identified:
a. copies of permit applications be available for review at a local PADEP office;
b. it would be preferable to have a minimum annular space of at least 2 inch and not 1-inch around the casing;
c. placement of the casements should be based on a field measurement of conductivity to ensure that the well is protecting both the freshwater zone and the water bearing zone with a total dissolved solids of < 10,000 mg/l. This is an EPA requirement, i.e., USDW- Determination of Underground Sources of Water;
d. in all cases, a multiple casing or string approach should be used to separate the shallow and deep groundwater flow system- because of the fractured nature of the local bedrock it is not appropriate to use a single string to seal off a freshwater, saline, or brackish water zones;
e. Copies of frac chemicals and other chemicals used at developing or maintaining these wells with copies of MSDS sheets should be available at a location when each community or municipality; and
f. If possible, the third party inspectors should be individuals that carry a license or certification by Pennsylvania and have specific training and experience to provide this service.
Just my comments - related to proposed regulations.
Mr. Brian Oram
Friday, February 19, 2010
DEP revising oil and gas well regs
This is a reposting of an article- I think it is critical for citizens, professionals, and organizations to review and comment.
Public comment sought by March 2
By SANDY LONG
PENNSYLVANIA — In efforts to provide better protection to Pennsylvania’s water resources, the state’s Department of Environmental Protection (DEP) is revising its existing rules for the construction of oil and gas wells and soliciting comments on the proposed revisions by March 2.
The proposed rulemaking would incorporate and update existing requirements, with modifications, regarding the drilling, casing, cementing, testing, monitoring and plugging of oil and gas wells.
The effects of unregulated drilling are still being addressed today. Last year, the DEP plugged 259 abandoned oil and gas wells located in the western and north-central regions of the state in nine counties. Many of the wells were leaking oil, acid mine drainage or natural gas.
The department has documented more than 8,600 wells throughout the state that were abandoned prior to the passage of modern oil and gas drilling regulations.
“Abandoned wells create passageways for pollution to enter and contaminate drinking water,” said DEP secretary John Hanger. “They also can allow natural gas to enter water supplies or build up in a home, which can create a dangerous enclosed space. Modern regulations require that wells be cased properly during use and sealed once they are taken out of service but, unfortunately, there are thousands of wells that were simply abandoned before people understood the dangers.”
The costs to plug a well vary with its age, depth and the terrain in which it is found. Typically, DEP crews clear a site and clean or remove the old well. After casings are removed and the well bore is clear, the well is filled with grout or cement and other materials.
Funding for the state’s Abandoned and Orphan Well Plugging Program comes from surcharges on well-drilling permits and from the Growing Greener program.
According to the DEP, Pennsylvania has the highest number of abandoned wells in the Appalachian region and is one of the top five states nationally. Since the first commercial oil well was drilled in Pennsylvania in 1859, DEP estimates as many as 350,000 oil and gas wells have been drilled in the state, with many of those wells having been abandoned without proper plugging.
Locally, the Wayne Conservation District has begun investigating the locations of such wells in the county. To report an abandoned well, call 570/253-0930.
View the proposed changes to the gas and oil well regulations at
http://www.dep.state.pa.us/dep/deputate/minres/oilgas/Oil%20&%20Gas%20Documents/CHAPTER%2078%20Revisions%20January%2027%202010.pdf
Written comments on the draft proposed rulemaking should be sent to the DEP, Bureau of Oil and Gas Management, P.O. Box 8765, Harrisburg, PA 17105-8765. Comments may also be submitted electronically to the department at ra-epoilandgas@state.pa.us.
Public comment sought by March 2
By SANDY LONG
PENNSYLVANIA — In efforts to provide better protection to Pennsylvania’s water resources, the state’s Department of Environmental Protection (DEP) is revising its existing rules for the construction of oil and gas wells and soliciting comments on the proposed revisions by March 2.
The proposed rulemaking would incorporate and update existing requirements, with modifications, regarding the drilling, casing, cementing, testing, monitoring and plugging of oil and gas wells.
The effects of unregulated drilling are still being addressed today. Last year, the DEP plugged 259 abandoned oil and gas wells located in the western and north-central regions of the state in nine counties. Many of the wells were leaking oil, acid mine drainage or natural gas.
The department has documented more than 8,600 wells throughout the state that were abandoned prior to the passage of modern oil and gas drilling regulations.
“Abandoned wells create passageways for pollution to enter and contaminate drinking water,” said DEP secretary John Hanger. “They also can allow natural gas to enter water supplies or build up in a home, which can create a dangerous enclosed space. Modern regulations require that wells be cased properly during use and sealed once they are taken out of service but, unfortunately, there are thousands of wells that were simply abandoned before people understood the dangers.”
The costs to plug a well vary with its age, depth and the terrain in which it is found. Typically, DEP crews clear a site and clean or remove the old well. After casings are removed and the well bore is clear, the well is filled with grout or cement and other materials.
Funding for the state’s Abandoned and Orphan Well Plugging Program comes from surcharges on well-drilling permits and from the Growing Greener program.
According to the DEP, Pennsylvania has the highest number of abandoned wells in the Appalachian region and is one of the top five states nationally. Since the first commercial oil well was drilled in Pennsylvania in 1859, DEP estimates as many as 350,000 oil and gas wells have been drilled in the state, with many of those wells having been abandoned without proper plugging.
Locally, the Wayne Conservation District has begun investigating the locations of such wells in the county. To report an abandoned well, call 570/253-0930.
View the proposed changes to the gas and oil well regulations at
http://www.dep.state.pa.us/dep/deputate/minres/oilgas/Oil%20&%20Gas%20Documents/CHAPTER%2078%20Revisions%20January%2027%202010.pdf
Written comments on the draft proposed rulemaking should be sent to the DEP, Bureau of Oil and Gas Management, P.O. Box 8765, Harrisburg, PA 17105-8765. Comments may also be submitted electronically to the department at ra-epoilandgas@state.pa.us.
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