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WANTED: Water
  
Massive quantities needed.
  
All sources may apply!


Hoses used by tanker trucks to withdraw water from Chartiers Creek
Water hoses are used so often by tanker trucks
to siphon water from Chartiers Creek
that the hoses are left on the bank

 
 

LAWMAKER CHALLENGES PENNSYLVANIA DEP'S REPORTING OF GAS WELL WATER SAFETY

By Don Hopey
Pittsburgh Post-Gazette

November 2, 2012 - The Pennsylvania Department of Environmental Protection produces incomplete lab reports and uses them to dismiss complaints that Marcellus Shale gas development operations have contaminated residential water supplies and made people sick, according to court documents. In response, state Rep. Jesse White, D-Cecil, Thursday called on state and federal agencies to investigate the DEP for "alleged misconduct and fraud" revealed by sworn depositions in a civil case currently in Washington County Common Pleas Court."This is beyond outrageous," Mr. White said. "Anyone who relied on the DEP for the truth about whether their water has been impacted by drilling activities has apparently been intentionally deprived of critical health and safety information by their own government."

************

MORE:

The letter sent to Rep. White alerting him of these issues can be found at: http://www.scribd.com/doc/111821139

The deposition of TaruUpadhyay, technical director of PA DEP Laboratory can be found at: http://www.scribd.com/doc/111821978


FOR FARMS IN THE WEST,
OIL WELLS ARE THIRSTY RIVALS

September 5, 2012 - GREELEY, Colo. — A new race for water is rippling through the drought-scorched heartland, pitting farmers against oil and gas interests, driven by new drilling techniques that use powerful streams of water, sand and chemicals to crack the ground and release stores of oil and gas. A single such well can require five million gallons of water, and energy companies are flocking to water auctions, farm ponds, irrigation ditches and municipal fire hydrants to get what they need.

Story


MORE WATER PROTECTION FROM MARCELLUS SHALE SUGGESTED FOR PENNSYLVANIA

April 16, 2012 - A former top environmental official says Pennsylvania's successful efforts to keep Marcellus Shale wastewater away from drinking water supplies should be extended to other oil and gas drillers. "It's the same industry. It is the same contaminants. And the goal should be the same," said George Jugovic Jr., former southwest regional director of the Department of Environmental Protection and president of PennFuture, an environmental group.

An Associated Press analysis of state data found that in the second half of 2011, about 1.86 million barrels — or about 78 million gallons — of drilling wastewater from conventional oil and gas wells were still being sent to treatment plants that discharge into rivers.

Story


METHANE, BARIUM, METALS & SALTS

April 18, 2012 – The Pa. Department of Environmental Protection did not include any information in the cover letter to the test results - or any flags in the lab report - outlining the hazards detected in the water: methane at double the concentration when it begins to seep out of water into the air, creating an explosion risk, and barium at more than twice state and federal safe drinking water limits.

The water also contained elevated levels of aluminum, manganese, iron, turbidity, total dissolved solids and chloride - all of which have limits set for aesthetic, not health, reasons - but the department did not highlight those parameters in the lab report or outline them in the cover letter.

Story


UPDATE ON WATER WELLS

Here are some excerpts from Bryan Swistock of Penn State in a June 21, 2010 Press Release following the Clearfield County gas well blowout that spewed contaminated water for 15 hours:

June 21, 2010 - Bryan Swistock, senior extension associate in the School of Forest Resources, said the state Department of Environmental Protection will probably check local streams for contamination, but it may be prudent for water-well owners living near the spill to have an independent laboratory test their well water. He said the tests for various contaminants have a range of costs and implications.

"Things like methane, chloride, total dissolved solids and barium are very good indicators and are relatively inexpensive to test for -- most labs can do them," Swistock explained. "When you move down into the organic chemicals that might be used in fracturing, the cost to test for them goes way up."

"It's hard to document anything if you don't have any pre-existing data," he added. "It's important that homeowners have an unbiased expert from a state-certified lab conduct the tests, in case the sample results are needed for legal action."

Certainly, water supplies within 1,000 feet of the drilling are considered at higher risk. Beyond that, it's up to the homeowner to decide.


Webmaster's note: It is advisable for those with water wells close to proposed drilling (within 2,500 feet) to have "split sample testing" done by a certified water lab. In other words, pay to have a certified water lab obtain a water sample from your well at the same time the drilling company is drawing their "pre-drill" sample. One such water lab is Pocono Labs.
These results will be invaluable if you end up in court with a drilling company over water well contamination. Have the most complete water testing done that you can afford. Wa
ter tests including VOC's (volatile organic compounds) will be more expensive. Your water test HAS to be taken by a certified tech and the "chain of custody" needs documented to be of value in court. 
"Post-drill" well water testing needs to be done within 6 months of drilling in Pennsylvania to be valid under mid-2010 regulations.

WHAT SHOULD YOUR WATER TEST INCLUDE?

It can get expensive to test for a long list of contaminants, so here is a short list of things you should test your water for first:

  • TDS

  • Barium

  • Chloride (Potassium chloride)

  • Methane

Eight additional test items to consider:

  • Aluminum

  • Arsenic

  • Bromide

  • Iron

  • Manganese

  • Lead

  • Strontium

  • Sulfate

  

WATER WITHDRAWALS

May 12, 2009 through July 15, 2014 - These water management plans have been approved by the PA DEP. The plans include a water withdrawal plan for Cross Creek, Cross Creek Lake and Chartiers Run, in Washington County. There is also a plan for Whiteley Creek in Greene County, as well as four commercial hydrants through Pennsylvania American Water Company in Washington County.

Photos taken September 23, 2009

Water withdrawals and a "leaky gate" have
affected this dock at Cross Creek Lake
  


Rocky shoreline near picnic tables is exposed
  


Cross Creek Lake boat launch area has changed drastically
  

Range Resources Water Management Plan summary:
800,000 gallons per day from Cross Creek Lake
200,000 gallons per day from Cross Creek
200,000 gallons per day from Chartiers Run
200,000 gallons per day from Whiteley Creek
2,592,000 gallons from four PAWC hydrants
Total = 3,992,000 gallons of water per day from all sources

Almost 4-million gallons of water per day (3,992,000) can be withdrawn from the Ohio River Basin watershed in two counties by Range Resources through July 15, 2014.

NOTE: This amount only includes Range Resources water withdrawals and does not include de-watering of the Ohio River Basin by other drilling companies.

Example: Eastern American Energy Corp. also has an approved water plan for withdrawal of 200,000 gallons of water per day from Whiteley Creek.

Eastern American Energy Corporation Water Management Plan for Whiteley Creek
(PDF - 210KB)

Whiteley Creek, Whiteley Township, Greene County, Penna.

Water Management Plans for SW Pennsylvania Region
48.5 million gallons per day from 10 counties
of the Monongahela/Ohio River watershed!


 

  

PENNSYLVANIA ACT 220 - Signed March 26, 2009

NEW PLAN OUTLINES STATEWIDE, REGIONAL PRIORITIES TO BALANCE COMPETING DEMANDS FOR WATER

As demand grows for Pennsylvania’s water resources, the commonwealth is offering comprehensive recommendations to help policymakers balance the demands of competing interests while protecting the quality and supply of water for residents and businesses.

The following goals have been identified by the Ohio Regional Water Resources Committee due to specific concerns regarding water quality and quantity in the region. These issues should be factored into any decisions that are made that may impact water resources, as we plan for the protection and restoration of water resources in the region.

􀂄 Distinguish the Ohio River Basin as a region that is different from other basins in the state while conducting public education and outreach on the importance of our water sources

􀂄 Identify water resources needed to promote and facilitate economic development, and provide job opportunities, while maintaining watershed integrity and recreational benefits

􀂄 Reduce and avoid impacts that may lead to contamination of groundwater and surface water sources available for residential water use

􀂄 Develop plans for water resources during periods of drought or other water shortage emergencies

􀂄 Protect and restore water resources such as critical groundwater recharge areas, ecologically sensitive watersheds, aquifers, wellheads, lakes, wetlands and floodplains

􀂄 Develop and encourage the use of appropriate, applied technology to ensure clean and healthy water resources and encourage water conservation practices

(Full PDF document -Ohio Region Water Atlas)

  

Hydraulic fracturing of shale for gas has its own sets of issues in each region of the United States. Some regions are short on water but can easily get rid of wastewater. Other regions have lots of water but no good way to get rid of the brine or "produced water." The second scenario applies to Marcellus Shale gas drilling in Pennsylvania, and some early lessons are being learned about the negative effects on drinking water sources.
  
Pennsylvania is considered to have an abundant supply of water, especially around Pittsburgh. On the opposite end of the state, Philadelphia tends to have more frequent summer droughts. The Allegheny River and Monongahela River join at 'the Point' in Pittsburgh to form the Ohio River. Until the past couple of years, when the amount of hydraulic fracturing increased in Western Pennsylvania, water quantity was rarely an issue.

Watergate

Looking back

During the 20th century Pittsburgh rivers became polluted from all the heavy industry present, while Pittsburgh became the Steel City, and this water pollution included acid mine drainage due to a very active coal mining industry. During the 2005 Bassmaster fishing event on Pittsburgh rivers it was reported how much cleaner the rivers were than a decade or two ago. Anglers were favorably impressed. Increased fish populations reflected these improvements in the river water quality.

In early 2011, it was reported by a representative of the Pa. Fish & Boat Commission that while the number of species of fish in Pittsburgh rivers increased from 2005 to 2010, that the game fish population declined.
  

Acid mine drainage at Coal Run
Acid mine drainage has brightly colored this stream south of Pittsburgh
  
  

One frac over the line

Environmental gains with Pittsburgh rivers have now started to reverse themselves since Marcellus Shale drilling began. This change became evident in 2008 as the hydraulic fracturing of wells began to ramp up. The problem stems from two issues.
  
The first problem is the massive quantities of water needed to frac each gas well, somewhere between 2 million and 6 million gallons. This water can be taken from any stream, lake, river or watershed in western Pennsylvania, since there is minimal regulation regarding water usage. Pittsburgh sorely needs a river basin commission that is more than just a figurehead like ORSANCO. This heavy drawing-off of water has had a significant impact on water levels, even in a water rich environment. Major problems began during the dry summer and fall seasons that Pittsburgh experienced in 2008.
  

3 Residual Waste tankers pumping water from the stream in front of the Washington County Firefighter Academy for a frac job at the intersection of Lynn Portal Road and West Buffalo Road.
Residual Waste tank trucks
The water level in the stream they are pumping from is running low due a rainfall deficiency of over 3-inches in the Pittsburgh area. July 11, 2009 photo

  
The second problem is the continuing flow of acid mine drainage, wildcat sewers, and other sources of contamination flowing into Pittsburgh area waterways. Add to that all the gas drilling wastewater that has been getting trucked to any waste treatment plant that would accept it. The wastewater was then being processed with various degrees of wastewater treatment before getting dumped back in area waterways. All of these sources (gas drilling wastewater, acid mine drainage, wildcat sewage flow) contribute to a high TDS (total dissolved solids) level.
 
The bad marriage

When you lower river flow and increase TDS levels.... BINGO!  The serious problems begin. Gas drilling companies are contributing to the problem on two levels, and it has become the proverbial straw that broke the camel's back. Whatever fragile balance that existed with Pittsburgh river water in the past has now been skewed by the increased drilling and hydrofracing of horizontal wells.

In early 2011, new concerns were announced due to the radioactivity of Marcellus Shale wastewater from soluble radioactive elements in the shale layer, including Ra 226.
  

Then they drink that water?

Did we forget to mention how many people around Pittsburgh get their drinking water from the rivers? The Monongahela River ("Mon") provides most of the area's drinking water to a large population of residents. There were very few problems with water companies providing drinking water within safety standards from Pittsburgh rivers until Marcellus drilling increased.
  
Add to these concerns the frac chemicals pumped deep underground. The manmade chemical mix joins the naturally occurring contaminants in the shale (including high salt content) and this toxic cocktail is put back into the waterways. What this adds to drinking water sources doesn't even account for inevitable run-off from well sites, accidents and spills. Who's to say some of the wastewater isn't getting 'the midnight dump' on local roads or into local streams?
  

Mon River in Pittsburgh Pennsylvania
The Monongahela River in Pittsburgh is known as "The Mon"
  
  

Getting up to speed

As drinking water started to go bad around Pittsburgh, there were some quick knee-jerk reactions. Some waste treatment plants that didn't have the proper facilities to process this industrial grade wastewater (consisting of a salty high brine content, frac fluids and heavy metals, just to name a few) were told they could no longer accept any produced water. This news really hurt the bottom line of some waste plants going through tough financial times, since several plants were reaping the financial rewards of treating additional wastewater. (There are at least 20 new wastewater plants in the planning stage for Pennsylvania).
  
In early 2009, the Pennsylvania DEP announced the installation of a new network of river monitors that would alert them to high-TDS levels. If the DEP can't control it at its source, why not monitor it and write a report on it? We'll see what this new program actually ends up accomplishing. At least it will raise public awareness of the problem which may eventually lead to reforms in the existing bad practices.
  

As Yogi said, "it's Deja Vu all over again"

We've now seen our first case of gas drilling creating a problem with drinking water in 2009, and it's just the beginning of summer, when tap water demands increase. On June 19th, the Tri-County Joint Municipal Authority alerted their 3,300 water customers to high levels of TTHMs (total trihalomethanes) in their tap water. Below is a copy of that letter:
  

  
After seeing the water report above, one local water expert offered the following comments:

"Not good at all.  Trihalomethanes (THM) can cause cancer, and some research has also linked it to miscarriages.  Very unusual to see a public drinking water system have an annual violation for this.  It’s a result of contaminants in the water reacting with the chlorine they add at the drinking water treatment plant.
  
I know that DEP and the Allegheny County Health Department are both aware that this is a potential problem that can happen when the drilling wastewater gets chlorinated and used for drinking water.  ...I don’t think anyone has reported an actual THM violation previously.
  
On the 'what people should do right now level' – a Brita (carbon) filter will take out THM, I’m pretty sure.  But be aware that most of your exposure is from showering, not drinking the water.  The steam in your shower will cause the THM to gas off out of the water and into your lungs.  Important to make sure your bathroom is well ventilated."

  

 


Key items on the agenda of the
Pennsylvania Environmental Quality Board (EQB)
meeting for May 19, 2010

Executive Summary - 25 PA Code Chapter 95 - Wastewater Treatment Requirements

May 19, 2010 Pennsylvania EQB Meeting Agenda

This final rulemaking amends Chapter 95 (relating to wastewater treatment requirements). The final form rulemaking includes the elimination of a redundant provision, and the establishment of new treatment requirements for new and expanding mass loadings of Total Dissolved Solids (TDS).

The proposed rulemaking was published in the Pennsylvania Bulletin on November 7, 2009. See 39 Pa.B. 6467 (November 7, 2009). Public comments were accepted until February 12, 2010. In addition, four (4) public hearings were held: December 14, 2009 in Cranberry Township, Butler County; December 15, 2009 in Ebensburg, Cambria County; December 16 in Williamsport, Lycoming County; and December 18, 2009 in Allentown, Lehigh County.

Prior to recommending that the proposed regulation be provided to the Environmental Quality Board, the Water Resources Advisory Committee (WRAC) suggested that further examination be made during the comment period to address two critical areas. WRAC suggested the Department examine the costs of the proposed regulation on the sectors that would be impacted, and the technologies available to treat discharges high in TDS. WRAC created the TDS Stakeholders Subcommittee to work in cooperation with the Department on these issues.

The TDS Stakeholders Subcommittee was tasked with examining the issue of cost and technology, and was to make recommendations to WRAC for submission to the Department in the form of formal comments on the proposed regulation. The subcommittee was made up of members of the various industries impacted as well as members of interested environmental groups. The subcommittee met monthly from August 2009 thru March 2010. During that timeframe various sector groups presented their findings on the impact of the proposed regulations to their industry or sector. The Department worked closely with the TDS Subcommittee and has taken into account the information presented and its recommendations in developing the final rulemaking.

This final form rulemaking protects the Commonwealth’s water resources from new and expanded sources of TDS. Most importantly, the rulemaking guarantees that waters of the Commonwealth will not exceed a threshold of 500 mg/l. In doing so, the rulemaking protects drinking water intakes on streams throughout the Commonwealth and aquatic life resources, as well as maintains continued economic viability of the current water users.

This final form rulemaking differs from the proposed rulemaking in several important respects. The differences are direct reflections of concerns raised by industries that would be impacted by this rulemaking. The rulemaking is responsive to these concerns, resulting in an improved rule.

The changes to the final form rulemaking are protective of our water resources and are appropriately applied by industrial sector, based on the potential impact of the specific sectors to our receiving streams. While many existing industries throughout the Commonwealth are of concern, the lower concentration and total loading of most of those industries does not necessitate treatment below a 2,000 mg/l threshold. A higher standard of 500 mg/l is being applied specifically to the natural gas sector, based on several factors.

The most significant rationale for this industry standard is the fact that wastewaters resulting from the extraction of natural gas are of much higher concentration and represent higher overall loadings when compared to other industries. In other words, the effluent standard does not dictate the treatment technology. Instead, selection of the treatment technology is driven by the raw extraordinarily high wastewater TDS concentration. Second, treatment technologies are currently available and are being employed in Pennsylvania and other states for the treatment of these wastewaters, in contrast to other industries. Regulatory certainty provided with this final rule will drive investment in and development of new technologies. Third, few other states allow the discharge of these treated wastewaters to their surface waters at all, dispelling any argument that Pennsylvania is creating an economic disadvantage for this industry. Fourth, the expansion of the industry into the Marcellus Shale is new to the Commonwealth, and without TDS controls it could impact existing industries, placing them at an economic disadvantage. The potential for growth for Marcellus gas drilling within this sector is enormous and should that growth be realized, the potential impacts are just as enormous. Finally, this industry has shown an ability to respond appropriately in addressing potential impacts to our natural resources. Options currently exist for other disposal pathways, including non-discharge options, and the creativity of the industry only assures that additional disposal and treatment options will flourish and allow for the continued expansion.

While the intent of both the proposed and final rules is to address new, larger sources of TDS, the proposed rulemaking focused upon controlling new sources of “high-TDS” wastewater through defining these sources in terms of those that were to be regulated (exempting by default those that were not). In order to provide greater clarity to the scope of the regulation, the final rulemaking takes the approach of specifically exempting certain classes of TDS discharges from the application of this rule. This approach is designed to clearly exclude from the scope of this regulation all existing loadings of TDS authorized by the Department prior to the effective date of this regulation, as well as new and expanding TDS sources, which the Department has determined are insignificant from a loading perspective.

In addition, based on Stakeholder comments received during a comprehensive public participation process, the final rulemaking adopts a combination of recommended approaches for addressing these larger loadings of TDS. This combination of approaches includes an industrial sector-based regulation along with a watershed-based analysis. The sector-based piece focuses on the Oil and Gas Industry, promoting the reuse of natural gas well flow back and the treatment of wastewater. Treatment for wastewater that is not recycled or disposed in an approved underground injection well must be performed at a Centralized Wastewater Treatment facility (CWT) to the standards contained in the proposed regulation. This approach sets treatment requirements for natural gas well wastewaters based on available, proven treatment technologies for this industry and takes cost into consideration. These requirements will assure that any threat of water pollution from this rapidly growing industry is prevented in accordance with the mandate of the Clean Streams Law.

The Department has reviewed all of the comments received and has determined that a sector-by-sector approach to controlling TDS is appropriate. High-TDS wastewaters from different industries present different treatment challenges. Based on the need for regulation of a rapidly expanding industry which generates wastewaters with extraordinarily high levels of TDS and chlorides, the readily available proven treatment technologies for this wastewater, the low costs associated with treatment, and the overwhelming public comment in favor of a standard for this industry, the proposed regulation has refined its original focus on treatment for oil and gas wastewaters. The final regulation now contains more specific treatment requirements for wastewater generated from all natural gas drilling activities.

The final regulation continues to prohibit any discharge of wastewater from natural gas well activities into waters of the Commonwealth except as authorized by § 95.10(b), and requires that such wastewater be treated at Centralized Waste Treatment facilities (CWTs). The final rule retains the CWT discharge limits for TDS, sulfates, chlorides, barium and strontium contained in the proposed rule. In response to comments, the final regulation adds a provision regarding reuse of flowback or production fluids from natural gas wells, and specifies that deep well injection of wastewater from natural gas wells must comply with 25 Pa. Code § 78.18.

The Department agrees with the comments that were received by various industries pointing out that the proposed rule is a one-size-fits-all approach that may not be appropriate. The final rulemaking addresses this issue by establishing an effluent standard for sectors (other than natural gas well operations) at 2,000 mg/l, and allows a variance from this standard under certain conditions specific to the watershed in which the discharge is located. This approach is consistent with the federal regulatory approach that separates technology-based, end-of-pipe requirements by industry sectors. This approach further accounts for economic impacts by distinguishing between new and existing sources of pollution, recognizing that new sources can plan their operations factoring in the regulatory requirements for wastewater treatment.

In summary, the final rulemaking establishes a watershed based approach that allows for use of assimilative capacity where available. Further, it provides watershed monitoring of the TDS loadings in watersheds statewide, and only imposes effluent limits on dischargers when the loading within the water body is nearing the limit of assimilative capacity. The final rulemaking establishes sector-based effluent standards for the natural gas industry, and requires recycle and reuse of fluids captured in the initial stages of well development. Wastewater that cannot be reused must be transported to treatment facilities that provide treatment to appropriate standards.

This final rulemaking was presented to the WRAC on April 14, 2010. During this discussion, WRAC members sought further clarification on the watershed approach, the impact on conventional gas drillers and the mandatory recycling provision within the proposed regulation. Clarification was provided by the Department, summarizing the intent of the watershed based approach. This included an explanation of what was deemed an existing discharge and further clarification that only the additional load above baseline would be subject to the rule should the total loading be more than the 5,000 pounds in mass loading the Department has determined to be de minimis.

Discussion on the impacts to the oil and gas industry, particularly the conventional well drillers was also significant. The Department clarified its intent that existing centralized wastewater treatment facilities, in particular those that treat conventional drilling wastewater, are considered as existing facilities and as such, can continue to accept oil and gas wastewater at levels currently approved. Finally, discussion focused on the provision within the regulation that would require the recycling or reuse of oil and gas wastewater that contained concentrations of less than 30,000 mg/l TDS. WRAC members noted that this will negatively impact both conventional and Marcellus drillers and should be revised or removed from the regulation. Specifically, the implementation date of the regulation and the subsequent impact that would have on the industry should the recycling provision remain was noted.

The Department agreed to continue working to address the concerns of WRAC members and the stakeholders they represent, including further examination of the implementation date. With the expected continued efforts of the department noted, WRAC concurred unanimously to move the revised regulation forward to the EQB. The motion that carried was:

“WRAC appreciates all of the Department's efforts to respond to our comments and improve the regulation. WRAC believes that the current draft of the regulation is substantially improved over the draft we reviewed in July of 2009, and we understand that additional improvements will be made based on our comments today. Although some of the individual WRAC members continue to have significant concerns about the regulation and whether it should proceed without an advance notice of final rulemaking, in light of the progress and efforts made to date and in light of the department's desire to proceed with the regulation, the consensus of the Committee is that the regulation should proceed for final consideration by the EQB.”
  

Executive Summary - PA Oil and Gas Well Casing and Cementing - Amendments to Chapter 78

May 19, 2010 Pennsylvania EQB Meeting Agenda

The proposed rulemaking would update existing requirements regarding the drilling, casing, cementing, testing, monitoring and plugging of oil and gas wells, and the protection of water supplies. The new and amended sections are §§78.1, .51, .52, .71-.73, .81-.85, .88, .89, .91-.96, .121 and .122. The proposed modifications include updated material specifications and performance testing and revised design, construction, operational, monitoring, plugging, water supply replacement, and gas migration reporting requirements. The additional requirements will minimize gas migration and will provide an increased degree of protection for both public and private water supplies.

With the development of the oil and gas industry in Pennsylvania, the potential exists for natural gas to migrate from the wellbore (via either improperly constructed or old, deteriorated wells). This stray gas may adversely affect water supplies, as well as accumulate within or adjacent to structures such as residences and businesses. If a well is not properly constructed and operated there could be potential threat of a fire or explosion. These situations represent a threat to public safety, health and welfare.

Properly cementing and casing a well is critical to preventing gas migration. The updated casing and cementing requirements will provide an increased degree of protection for homeowners and water supplies. The proposed construction standards will align Pennsylvania’s regulations with other states’ rules as well as current industry standards. Casing pressure tests will detect deficiencies before a well could create a potential safety or environmental problem. Minimizing annular pressure will reduce the potential for gas migration. The new quarterly inspections and annual reporting will result in early detection of possible well integrity problems before impacts to the environment or public safety occur. The proposed regulations also outline the procedures the operator and the Department will utilize if there is a reported gas migration event.

Prior to drilling a well, operators will now be required to develop a casing and cementing plan that shows how the well will be drilled and completed. Use of centralizers (which keep the casing centered in the well bore) must be used at prescribed locations to ensure that cement is evenly distributed between the casing and the well bore. Cement meeting ASTM criteria for oil and gas wells must be used. Used or welded casing must be pressure tested as well as casing strings attached to heavy duty blow-out preventers. Documentation of the cement quality and cementing practices used at the well must be available for Department inspection.

Operators must inspect all of their wells quarterly and report the findings of the inspections to the Department annually. If defective casing, evidence of leaks, or if excessive pressure within the well bore is discovered, the operator must immediately notify the Department and take corrective action.

The Oil and Gas Act requires any operator who contaminates or diminishes a water supply to restore or replace the supply with one that is adequate in quantity and quality for the purposes served. Case law on these requirements has defined when an operator must provide compensation for increased operation and maintenance costs and for what duration. The regulations codify these and other relevant holdings to clearly describe the operator’s responsibility. The regulations also limit the operator’s duty to restore the quality of the supply to Safe Drinking Water Act standards.

The new regulations impose a duty on operators to immediately investigate a gas migration complaint and to notify the Department if they receive such a complaint. If natural gas is found at elevated levels the operator must immediately notify emergency responders and initiate mitigation measures.

The regulations revise well plugging standards to require operators to plug wells through the producing formation rather than setting the cement plug immediately above the formation. This practice will better ensure that any residual gas or oil does not somehow channel through the plug as the cement is setting.

The proposed rulemaking was presented to the Oil and Gas Technical Advisory Board (TAB) for their consideration on September 17, 2009. Because of the scope of the changes, TAB requested additional time to review and provide comment. As part of their review, TAB formed a technical committee with representatives from various companies, trade groups and consultants. Since the initial meeting in September, the Department has met with TAB and their subcommittee on October 28, 2009, January 14, 2010, January 21, 2010 and March 25, 2010.

In addition to TAB’s input, the Department received input from industry representatives, consultants and environmental groups. On January 30, 2010 the Department published an Advanced Notice of Proposed Rulemaking for a 30 day comment period. The Department received comments from 87 individuals representing industry, consultants and environmental groups. The current proposal is based on the comments received during the public comment period and comments submitted by TAB members. At its March 25, 2010, meeting, TAB voted unanimously to recommend that the EQB offer these regulations as a proposed rulemaking.

The rulemaking will become effective upon publication in the Pennsylvania Bulletin, which is anticipated to occur in Fall 2010. The Department recommends a 30-day public comment period for the proposed rulemaking. No public meetings are planned.
 

Annex A - Title 25. Environmental Protection

Part I. Department of Environmental Protection

Subpart C. Protection of Natural Resources - Article I. Land Resources - CHAPTER 78. OIL AND GAS WELLS

Subchapter A. GENERAL PROVISIONS

§ 78.1. Definitions.

(a) The words and terms defined in section 103 of the act (58 P. S. § 601.103), section 2 of the Coal and Gas Resource Coordination Act (58 P. S. § 502), section 2 of the Oil and Gas Conservation Law (58 P. S. § 402), section 103 of the Solid Waste Management Act (35 P. S. § 6018.103) and section 1 of The Clean Stream Law (35 P. S. § 691.1), have the meanings set forth in those statutes when the terms are used in this chapter.

(b) The following words and terms, when used in this chapter, have the following meanings, unless the context clearly indicates otherwise:

* * * * *

Casing seat—The depth to which the surface casing or coal protection casing [is run] or intermediate casing is set. In wells without surface casing, the surface casing seat shall be considered to be equal to 50 feet below the deepest fresh groundwater [the depth of casing which is normal for wells in the area].

* * * * *

Cement—A mixture of materials for bonding or sealing that attains a 7-day maximum permeability of 0.01 millidarcies and a 24-hour compressive strength of at least 500 psi in accordance with applicable [API] standards and specifications.

Cement job log – a written record that documents the actual procedures and specifications of the cementing operation. The record must include the type of cement with additives, the volume, yield and density in pounds per gallon of the cement and the amount of cement returned to the surface, if any. Cementing procedural information must include a description of the pumping rates in bbls per minute, pressures in psi, time in minutes and sequence of events during the cementing operation.


 

1

* * * * *

Conductor pipe – a short string of large-diameter casing used to stabilize the top of the wellbore in shallow unconsolidated formations.

* * * * *

Intermediate casing – a string of casing other than production casing that is used in the wellbore to isolate, stabilize or provide well control to a greater depth than that provided by the surface casing or coal protection casing.

* * * * *

[Retrievable—When used in conjunction with surface casing, coal protective casing or production casing, the casing that can be removed after exerting a prudent effort to pull the casing while applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% of the casing weight, whichever is greater.]

* * * * *

Surface Casing—[A string of pipe which extends from the surface and that segregates and protects fresh groundwater and stabilizes the hole]. Casing used to isolate the wellbore from fresh groundwater and to prevent the escape or migration of gas, oil and other fluids from the well bore into fresh groundwater. The surface casing is also commonly referred to as the water string or water casing.

* * * * *

Subchapter C. ENVIRONMENTAL PROTECTION

PERFORMANCE STANDARDS

§ 78.51. Protection of water supplies.

(a) A well operator who affects a public or private water supply by pollution or diminution shall restore or replace the affected supply with an alternate source of water adequate in quantity and quality for the purposes served by the supply as determined by the Department.

* * * * *

(d) [The operator shall affirmatively demonstrate to the Department’s satisfaction that the quality of the restored or replaced water supply to be used for human consumption is at least equal to the quality of the water supply before it was affected by the operator. If the quality of the water supply before it was affected by the


 

2

operator cannot be affirmatively established, the operator shall demonstrate that the concentrations of substances in the restored or replaced water supply do not exceed the primary and secondary maximum contaminant levels established under § 109.202 (relating to State MCLs and treatment technique requirements).] A restored or replaced water supply shall include any well, spring, public water system or other supply approved by the Department, which meets the criteria for adequacy as follows:

(1) Reliability, cost, maintenance and control. A restored or replaced water supply, at a minimum, must:

(i) Be as reliable as the previous water supply.

(ii) Be as permanent as the previous water supply.

(iii) Not require excessive maintenance.

(iv) Provide the owner and the user with as much control and accessibility as exercised over the previous water supply.

(v) Not result in increased costs to operate and maintain. If the operating and maintenance costs of the restored or replaced water supply are increased, the operator shall provide for permanent payment of the increased operating and maintenance costs of the restored or replaced water supply.

(2) Quality. The quality of a restored or replaced water supply will be deemed

adequate if it meets the standards established pursuant to the Pennsylvania Safe Drinking Water Act (35 P. S. § § 721.1—721.17), or is comparable to the unaffected water supply if that water supply did not meet these standards.

(3) Adequate quantity. A restored or replaced water supply will be deemed adequate in quantity if it meets one of the following as determined by the Department:

(i) It delivers the amount of water necessary to satisfy the water user’s needs and the demands of any reasonably foreseeable uses.

(ii) It is established through a connection to a public water supply system which is capable of delivering the amount of water necessary to satisfy the water user’s needs and the demands of any reasonably foreseeable uses.

(iii) For purposes of this paragraph and with respect to agricultural water supplies, the term reasonably foreseeable uses includes the reasonable expansion of use where the water supply available prior to drilling exceeded the actual use.


 

3

(4) Water source serviceability. Replacement of a water supply includes providing plumbing, conveyance, pumping or auxiliary equipment and facilities necessary for the surface landowner or water purveyor to utilize the water supply.

(e) If the water supply is for uses other than human consumption, the operator shall demonstrate to the Department’s satisfaction that the restored or replaced water supply is adequate for the purposes served by the supply.

(f) [The oil or gas well operator’s duty to replace or restore a water supply includes providing plumbing, conveyance, pumping or auxiliary equipment and facilities necessary for the surface landowner or water purveyor to utilize the water supply.]

[(g)] Tank trucks or bottled water are acceptable only as temporary water replacement for a period approved by the Department and do not relieve the operator of the obligation to provide a restored or replaced water supply.

[(h)] (g) If the well operator and the landowner, water purveyor or affected person are unable to reach agreement on the means for restoring or replacing the water supply, the Department or either party may request a conference under section 501 of the act (58 P. S. § 601.501).

(h) A well operator who receives notice from a landowner, water purveyor or affected person that a water supply has been affected by pollution or diminution, shall report receipt of such notice to the Department within 10 calendar days of receiving the notice.

§ 78.52. Predrilling or prealteration survey.

(a) A well operator who wishes to preserve its defense under section 208(d)(1) of the act (58 P. S. § 601.208(d)(1)) that the pollution of a water supply existed prior to the drilling or alteration of the well shall [cause] conduct a predrilling or prealteration survey [to be conducted] in accordance with this section.

* * * * *

(d) An operator electing to preserve its defenses under section 208(d)(1) of the act shall provide a copy of the results of the survey to the Department and the landowner or water purveyor within 10-calendar days of receipt [being notified by the Department to submit a copy] of the results.

* * * * *


 

4

Subchapter D. WELL DRILLING, OPERATION AND PLUGGING

GENERAL

Sec.

78.71. Use of safety devices—well casing. 78.72. Use of safety devices—blow-out prevention equipment. 78.73. General provision for well construction and operation. 78.74. Venting of gas. 78.75. Alternative methods.

78.75a. Area of alternative methods. 78.76. Drilling within a gas storage reservoir area.

78.77. Wells in a hydrogen sulfide area. 78.78 Pillar permit applications.

CASING AND CEMENTING

78.81. General provisions. 78.82. Use of conductor pipe. 78.83. Surface and coal protective casing and cementing procedures. 78.83a. Casing and cementing plan. 78.83b. Casing and cementing – lost circulation. 78.83c. Intermediate and production casing. 78.84. Casing standards. 78.85. Cement standards. 78.86. Defective casing or cementing. 78.87. Gas storage reservoir protective casing and cementing procedures.

OPERATING WELLS

78.88. Mechanical integrity of operating wells. 78.89. Gas migration response. .

* * * * *


 

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Subchapter D. WELL DRILLING, OPERATION AND PLUGGING

GENERAL

§ 78.71. Use of safety devices—well casing.

(a) The operator shall equip the well with one or more strings of casing of sufficient cemented length and strength to attach blow-out prevention equipment and prevent blowouts, explosions, fires and casing failures during installation, completion and operation.

* * * * *

§ 78.72. Use of safety devices—blow-out prevention equipment.

(a) The operator shall use blow-out prevention equipment [when well head pressures or natural open flows are anticipated at the well site that may result in a blow-out or when the operator is drilling in an area where there is no prior knowledge of the pressures or natural open flows to be encountered.] in the following circumstances:

(1) When drilling a well that is intended to produce natural gas from the Marcellus Shale formation;

(2) When well head pressures or natural open flows are anticipated at the well site that may result in a loss of well control;

(3) When the operator is drilling in an area where there is no prior knowledge of the pressures or natural open flows to be encountered;

(4) On wells regulated by the Oil and Gas Conservation Law (58 P.S. §§ 401 – 409);

(5) When drilling within 200 feet of a building.

(b) Blow-out prevention equipment used shall be in good working condition at all times.

(c) Controls for the blow-out preventer shall be accessible to allow actuation of the equipment. Additional controls for a blow-out preventer with a pressure rating of greater than 3,000 psi not associated with the rig hydraulic system shall be located away from the drilling rig such that the blow-out preventer can be actuated if control of the well is lost.

[(c)] (d) * * * * *


 

6

[(d)] (e) The operator shall conduct a complete test of the ram type blow-out preventer and related equipment for both pressure and ram operation before placing it in service on the well. The operator shall test the annular type blow-out preventer in accordance with the manufacturer’s published instructions, or the instructions of a professional engineer, prior to the device being placed in service. Blow-out prevention equipment that fails the test shall not be used until it is repaired and passes the test.

[(e)] (f) When the equipment is in service, the operator shall visually inspect blow-out prevention equipment during each tour of drilling operation and during actual drilling operations test the pipe rams for closure daily and the blind rams for closure on each round trip. When more than one round trip is made in a day, one daily closure test for blind rams is sufficient. Testing shall be conducted in accordance with American Petroleum Institute publication API RP53, ‘‘API Recommended Practice for Blowout Prevention Equipment Systems for Drilling Wells.’’ The operator shall record the results of the inspection and closure test in the drillers log before the end of the tour. Blow-out prevention equipment that is not in good working order shall be repaired or replaced immediately and re-tested prior to the resumption of drilling.

(g) All lines, valves and fittings between the closing unit and the blow-out preventer stack shall be flame resistant and have a rated working pressure that meets or exceeds the requirements of the blow-out preventer system.

[(f)] (h) During drilling when conditions are such that the use of a blowout preventer can be anticipated, there shall be present on the [rig floor a certified] well site an individual [responsible to] who the operator has determined is trained and competent in the use of the blow-out prevention equipment. Satisfactory completion of [a United States Geologic Survey (U.S.G.S.)] a[n approved] well control course by the [American Petroleum Institute,] Independent Association of Drilling Contractors or equivalent study shall be deemed adequate [certification] for purposes of this subsection.

[(g)] (i) * * * * *

[(h)] (j) * * * * *

§ 78.73. General provision for well construction and operation.

(a) The operator shall construct and operate the well in accordance with this chapter and ensure that the integrity of the well is maintained and health, safety, environment and property are protected.

[(a)] (b) The operator shall prevent gas [and other fluids from lower formations from entering fresh groundwater.], oil, brine, completion and servicing fluids, and any


 

7

other fluids from below the casing seat from entering fresh groundwater and prevent pollution or diminution of fresh groundwater.

[(b)] (c) After a well has been completed, recompleted, reconditioned or altered the operator shall prevent shut-in pressure [or] and producing back pressure at the surface casing seat, [or] coal protective casing seat or intermediate casing seat when the intermediate casing is used in conjunction with the surface casing to isolate fresh groundwater from exceeding 80 percent (80%) of the hydrostatic pressure of the surrounding fresh groundwater system in accordance with the following formula. The maximum allowable shut-in pressure [or] and producing back pressure to be exerted at the [surface casing seat, or coal protective] casing seat may not exceed the [hydrostatic] pressure calculated as follows: Maximum pressure = (0.8 x 0.433 psi/foot) multiplied by (casing length in feet).

[(c)] (d) After a well has been completed, recompleted, reconditioned or altered, if the shut-in pressure or producing back pressure exceeds the [hydrostatic] pressure at the surface casing seat, coal protective casing as calculated in subsection [(b)] (c), the operator shall take action to prevent the migration of gas and other fluids from lower formations into fresh groundwater. To meet this standard the operator may cement or install on a packer sufficient intermediate or production casing or take other actions approved by the Department. This section does not apply during testing for mechanical integrity in accordance with State or Federal requirements.

(e) Excess gas encountered during drilling, completion or stimulation shall be flared, captured or diverted away from the drilling rig in a manner that does not create a hazard to the public health or safety.

(f) Except for gas storage wells, the well must be equipped with a check valve to prevent backflow from the pipelines into the well.

* * * * *

§ 78.75a. Area of alternative methods.

(a) The Department may designate an area of alternative methods if the Department determines that well drilling requirements beyond those provided in this chapter are necessary to drill, operate or plug a well in a safe and environmentally protective manner.

(b) To establish an area of alternative methods, the Department shall publish a notice in the Pennsylvania Bulletin of the proposed area of alternative methods and provide the public with an opportunity to comment on the proposal. After reviewing any comments received on the proposal, the Department shall publish a final designation of the area and required alternative methods in the Pennsylvania Bulletin.


 

8

(c) Wells drilled within an area of alternative methods established pursuant to subsection (b) must meet the requirements specified by the Department unless the operator obtains approval from the Department 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 of the area of alternative methods.

§ 78.76. Drilling within a gas storage reservoir area.

(a) An operator proposing to drill a well within a gas storage reservoir area or a reservoir protective area to produce gas or oil shall forward by certified mail a copy of the well location plat, the drilling, casing and cementing plan and the anticipated date drilling will commence to the gas storage reservoir operator and to the Department for approval by the Department and shall submit proof of notification to the Department with the well permit application.

* * * * *

CASING AND CEMENTING

* * * * *

[(c) Casing and cementing standards in § § 78.83—78.85 (relating to surface and coal protective casing and cementing procedures; casing standards; and cement standards) apply to surface casing and coal protective casing but do not apply to production casing.]

§ 78.82 Use of conductor pipe.

If the operator installs conductor pipe in the well, the [operator may not remove the pipe] following provisions shall apply:

                        (i)

The operator may not remove the pipe;

(ii)

Conductor pipe shall be installed in a manner that prevents infiltration of surface water or fluids from the operation into groundwater;

(iii)

Conductor pipe must be made of steel unless a different material is approved for use by the Department.

 

§ 78.83. Surface and coal protective casing and cementing procedures.

(a) For wells drilled, altered, reconditioned or recompleted after [effective date], surface casing or any casing functioning as a water protection casing must not be utilized as production casing unless one of the following applies:


 

9

                        (1)

In oil wells 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;

 

                        (2)

The operator demonstrates that the pressure in the well bore at the casing seat is no greater than the pressure permitted by § 78.73(c) and demonstrates through a pressure test or other method approved by the Department that all gas and fluids will be contained within the well.

 

[(a)] (b) If the well is to be equipped with threaded and coupled casing, the operator shall drill a hole so that the diameter is at least 1 inch greater than the outside diameter of the casing collar to be installed. If the well is to be equipped with plain-end welded casing, the operator shall drill a hole so that the diameter is at least 1 inch greater than the outside diameter of the [casing tube] centralizer band.

[(b)] (c) [Except as provided in subsection (c) , t]The operator shall drill to approximately 50 feet below the deepest fresh groundwater or at least 50 feet into consolidated rock, whichever is deeper, and immediately set and permanently cement a string of surface casing to that depth. The surface hole shall be drilled using air, freshwater, or freshwater based drilling fluid. The surface casing seat shall be set in consolidated rock. When drilling a new well or redrilling an existing well, the operator shall install at least one centralizer within 50 feet of the casing seat and then install a centralizer in intervals no greater than every 150 feet above the first centralizer.

[(c) If no fresh groundwater is being utilized as a source of drinking water within a 1,000-foot radius of the well, the operator may set and permanently cement a single string of surface casing through all water zones, including fresh, brackish and salt water zones. Prior to penetrating zones known to contain, or likely containing, oil or gas, the operator shall install and permanently cement the string of casing in a manner that segregates the various waters.]

* * * * *

(f) If additional fresh groundwater is encountered in drilling below the permanently cemented surface casing, the operator shall protect the additional fresh groundwater by installing and cementing a subsequent string of casing or other procedures approved by the Department to completely isolate and protect fresh groundwater. The string of casing may also penetrate zones bearing salty or brackish water with cement in the annular space being used to segregate the various zones. Sufficient cement shall be used to cement the casing at least 20 feet into the permanently cemented surface casing.

(g) The operator shall set and cement a coal protective string of casing through workable coal seams. The base of the coal protective casing shall be at least 30 feet below the lowest workable coal seam. The operator shall install at least two centralizers. One


 

10

centralizer shall be within 50 feet of the casing seat and the second centralizer shall be within 100 feet of the surface.

(h) Unless an alternative method has been approved by the Department in accordance with § 78.75 (relating to Alternative methods), [W]when a well is drilled through a coal seam at a location where the coal has been removed or when a well is drilled through a coal pillar, the operator shall drill to a depth of at least 30 feet but no more than 50 feet deeper than the bottom of the coal seam. The operator shall set and cement a coal protection string of casing to this depth. The operator shall equip the casing with a cement basket or other similar device above and as close to the top of the coal seam as practical. The bottom of the casing shall be equipped with an appropriate device designed to prevent deformation of the bottom of the casing. The interval from the bottom of the casing to the bottom of the coal seam shall be filled with cement either by the balance method or by the displacement method. Cement shall be placed on top of the basket between the wall of the hole and the outside of the casing by pumping from the surface. If the operator penetrates more than one coal seam from which the coal has been removed, the operator shall protect each seam with a separate string of casing that is set and cemented or with a single string of casing which is stage cemented so that each coal seam is protected as described in this subsection. The operator shall cement the well to isolate workable coal seams from each other.

* * * * *

(j) If it is anticipated that cement used to permanently cement the surface casing can not be circulated to the surface a cement basket may be installed immediately above the depth of the anticipated [last] lost circulation zone. The casing shall be permanently cemented by the displacement method. Additional cement may be added above the cement basket, if necessary, by pumping through a pour string from the surface to fill the annular space.

§ 78.83a. Casing and cementing plan.

(a) The operator shall prepare and maintain a casing and cementing plan showing how the well will be drilled and completed. The plan must demonstrate compliance with this subchapter and include the following information:

(1) The anticipated depth and thickness of any producing formation, expected pressures, and anticipated fresh groundwater zones;

(2) Diameter of the well bore;

(3) Casing type, whether the casing is new or used, depth, diameter, wall thickness and burst pressure rating;

(4) Cement type, yield, additives, and estimated amount;


 

11

(5) Estimated location of centralizers;

(6) Alternative methods or materials as required by the Department as a condition of the well permit.

(b) The plan must be available at the well site for review by the Department.

(c) Upon request, the operator shall provide a copy of the well specific casing and cementing plan to the Department for review and approval.

(d) Any revisions to the plan made as a result of on-site modification shall be documented in the plan by the operator and be available for review by the Department.

§ 78.83b. Casing and cementing – lost circulation.

(a) If cement used to permanently cement the surface or coal protective casing is not circulated to the surface despite pumping a volume of cement equal to or greater than 120% of the calculated annular space, the operator shall notify the Department and meet one of the following requirements:

                        (1)

Run an additional string of casing at least 50 feet deeper than the surface casing and cement the second string of casing back to the seat of the surface or coal protective casing and vent the annulus of the additional casing string to the atmosphere at all times unless closed for well testing or maintenance. Shut-in pressure on the casing seat of the second string of casing must not exceed the requirements of section 78.73(c).

 

                        (2)

If the additional string of casing is the production casing, the operator shall set the production casing on a packer in a competent formation below the surface casing seat, and vent the annulus of the production casing to the atmosphere at all times unless closed for well testing or maintenance.

 

                        (3)

Run production casing at least to the top of the formation that is being produced and cement the production casing to the surface.

 

                        (4)

Produce oil but not gas and leave the annulus between the surface casing and the production pipe open.

 


 

12

(b) If cement used to permanently cement the surface or coal protective casing is not circulated to the surface, the Department may require the operator to determine the amount of casing that was cemented by logging or other suitable method.

§ 78.83c. Intermediate and production casing.

(a) Except as provided in § 78.72 (relating to Use of safety devices – blow-out prevention equipment), intermediate and production casing must be cemented according to this section.

(b) If the well is to be equipped with an intermediate casing, the casing must be cemented from the casing seat to a point at least 500 feet above the seat. If any producing horizon is open to the well bore above the casing seat, the casing must be cemented from the casing seat up to a point at least 500 feet above the top of the shallowest productive horizon, or to a point at least 200 feet above the shoe of the next shallower casing string that was set and cemented in the well. The intermediate casing may be perforated to produce gas or oil if a shoe test demonstrates a pressure gradient greater than 0.465 psi/ft multiplied by casing length in feet.

(c) Except as provided for in § 78.83 (relating to surface and coal protective casing and cementing procedures), each well must be equipped with production casing. The production string may be set on a packer or cemented in place. If the production casing is cemented in place, cement must be placed by the displacement method with sufficient cement to fill the annular space to the surface or to a point at least 500 feet above the production casing seat.

§ 78.84. Casing standards.

                        (a)

The operator shall install casing that can withstand the effects of tension, and prevent leaks, burst and collapse during its installation, cementing and subsequent drilling and producing operations.

 

(b) Surface casing must be a string of new pipe with a pressure rating that is at least 20 percent greater than the anticipated maximum pressure to which the surface casing will be exposed.

(c) Used casing may be approved for use as surface, intermediate or production casing but must be pressure tested after cementing and before continuation of drilling. A passing pressure test is holding the anticipated maximum pressure to which it will be exposed for 30 minutes with not more than a 10 percent decrease in pressure.

(d) New or used plain end casing, except when being used as drive pipe, conductor, or as a casing string prior to setting and cementing surface casing, that is welded together for use must meet the following requirements:


 

13

(1) It must pass a pressure test by holding the anticipated maximum pressure to which the casing will be exposed for 30 minutes with not more than a 10 percent decrease in pressure. The operator shall notify the Department at least 24 hours before conducting the test. The test results shall be entered on the drilling log.

(2) It shall be welded using at least three passes with the joint cleaned between each pass.

(3) It shall be welded by a person trained and certified in the applicable American Petroleum Institute’s standard for welding casing and pipe or an equivalent training and certification program as approved by the Department. A person with 10 or more years of experience welding casing as of [effective date] who registers with the Department within nine months of the effective date of this subsection is deemed to be certified.

[(b) The operator shall equip the casing string with appropriate equipment to center the casing through the hole in fresh groundwater zones. This equipment is not required when existing hole conditions such as caving or crookedness might cause loss of the well or result in a defective cement job.]

[(c)] (e) When casing through a workable coal seam, the operator shall install coal protective casing that has a minimum wall thickness of 0.23 inches.

(f) Casing which is attached to a blow-out preventer with a pressure rating of greater than 3,000 psi shall be pressure tested. A passing pressure test must be holding 120 percent of the highest expected working pressure of the casing string being tested, for 30 minutes with not more than a 10 percent decrease. Certification of the pressure test shall be confirmed by entry and signature of the person performing the test on the driller’s log.

§ 78.85. Cement standards.

(a) When cementing surface casing, coal protective casing and intermediate casing when the intermediate casing is used in conjunction with the surface casing to isolate fresh groundwater, [T]the operator shall use cement that [will resist degradation by chemical and physical conditions in the well.] meets or exceeds the ASTM International C 150, Type I, II or III Standard or API Specification 10. The cement must also:

(1) Secure the casing in the well bore;

(2) Isolate the well bore from fresh groundwater;

(3) Contain any pressure from drilling, completion and production;


 

14

(4) Protect the casing from corrosion;

(5) Resist degradation by the chemical and physical conditions in the well;

(6) Prevent gas flow in the annulus.

(b) [The operator shall permit the cement to set to a minimum compressive strength of 350 pounds per square inch (psi) in accordance with the American Petroleum Institute’s API Specification 10. The operator shall permit the cement to set for a minimum period of 8 hours prior to the resumption of actual drilling.] After the casing cement is placed behind surface casing and intermediate casing when the intermediate casing is used in conjunction with the surface casing to isolate fresh groundwater, the operator shall permit the cement to set to a minimum designed compressive strength of 350 pounds per square inch (psi) at the casing seat.

(c) After the casing cement is placed and cementing operations are complete, the casing may not be disturbed for a minimum of eight (8) hours by:

(1) Releasing pressure on the cement head, if float equipment check valves did not hold or float equipment was not equipped with check valves;

(2) Nippling up on or in conjunction to the casing;

(3) Slacking off by the rig supporting the casing in the cement sheath; or

(4) Running drill pipe, wireline, or other mechanical devices into or out of the wellbore.

[(c)] (d) Where special cement or additives are used, the operator may request approval from the Department to reduce the cement setting time specified in subsection [(b)] (d).

(e) The operator shall notify the Department a minimum of one day before cementing of the surface casing begins, unless the cementing operation begins within 72 hours of commencement of drilling.

(f) A copy of the cement job log must be available at the well site for inspection by the Department during drilling operations. The cement job log shall be maintained by the operator after drilling operations for at least five years and be made available to the Department upon request.

* * * * *


 

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OPERATING WELLS

§ 78.88. Mechanical integrity of operating wells.

(a) Except for wells regulated under Subchapter H (relating to Underground gas storage), the operator shall inspect each operating well at least quarterly to ensure it is in compliance with the well construction and operating requirements of this chapter and the Act. The results of the inspections shall be recorded and retained by the operator for at least five years and shall be available for review by the Department and the coal owner or operator.

(b) At a minimum, inspections must determine:

(1) The well-head pressure or water level measurement;

(2) The open flow on the annulus of the production casing or the annulus pressure if the annulus is shut in;

(3) If there is evidence of gas escaping from the well and the amount escaping, using measurement or best estimate of quantity;

(4) If there is evidence of progressive corrosion, rusting or other signs of equipment deterioration.

(c) For structurally sound wells in compliance with §78.73(c), the operator shall follow the reporting schedule outlined in subsection (e).

(d) For wells exhibiting progressive corrosion, rusting or other signs of equipment deterioration that compromise the integrity of the well, or the well is not in compliance with §78.73(c), the operator shall immediately notify the Department and take corrective actions to repair or replace defective equipment or casing or mitigate the excess pressure on the surface casing seat, coal protective casing seat or intermediate casing seat when the intermediate casing is used in conjunction with the surface casing to isolate fresh groundwater according to the following hierarchy:

                        (1)

The operator shall reduce the shut-in or producing back pressure on the casing seat to achieve compliance with § 78.73(c).

 

                        (2)

The operator shall retrofit the well by installing production casing to reduce the 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. The production casing shall be either cemented to the surface or installed on a permanent packer. The operator shall notify the Department at least seven days prior to initiating the corrective measure.

 


 

16

                        (3)

Additional mechanical integrity tests, including but not limited to pressure tests, may be required by the Department to demonstrate the integrity of the well.

 

(e) The operator shall submit an annual report to the Department identifying the compliance status of each well with the mechanical integrity requirements of this section. The report shall be submitted on forms prescribed by, and available from, the Department or in a similar manner approved by the Department.

§ 78.89. Gas migration response.

(a) When an operator or owner is notified of or otherwise made aware of a natural gas migration incident, the operator shall immediately notify the Department and, if so directed by the Department, conduct an investigation of the incident. The purpose of the investigation is to determine the nature of the incident, assess the potential for hazards to public health and safety, and mitigate any hazard posed by the levels of natural gas. The operator, in conjunction with the Department and local emergency response agencies, shall take measures necessary to ensure public health and safety.

(b) The investigation undertaken pursuant to subsection (a) shall include, but not be limited to:

(1) An interview with the complainant to obtain information about the complaint and to assess the reported problem.

(2) A field survey to assess the presence and concentrations of natural gas and aerial extent of the stray natural gas.

(3) Establishment of monitoring locations at potential sources, in potentially impacted structures, and the subsurface.

(c) If the level of natural gas is greater than 10 percent of the lower explosive limit of natural gas, the operator shall:

(1) Immediately notify the local emergency response agency, police and fire departments and the Department;

(2) Conduct an immediate field survey of the operator’s adjacent oil or gas wells to assess the wells for mechanical integrity, defective casing or cementing, and excess pressures within any part of the well. The initial area of assessment shall include wells within 2,500 feet and expanded to a greater distance if necessary as determined by the Department;

(3) Initiate mitigation controls, which may include remedial measures, access control, advisories, evacuation, signs and other actions;


 

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(d) The operator shall take action to correct any defect in the oil and gas wells to mitigate the stray gas incident.

(e) The operator and owner shall report to the Department by phone within 12 hours after the interview with the complainant and field survey of the natural gas levels. A follow-up report shall be filed in writing with the Department within three days of the complaint. This follow-up report must include the results of the investigation, monitoring results and measures taken by the operator to repair any defects at any of the adjacent oil and gas wells.

PLUGGING

§ 78.92. Wells in coal areas—surface or coal protective casing is cemented.

(a) In a well underlain by a workable coal seam, where the surface casing or coal protective casing is cemented and the production casing is not cemented or the production casing is not present, the owner or operator shall plug the well as follows:

(1) The retrievable production casing shall be removed by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater. [and the] The well shall be filled with nonporous material from the total depth or attainable bottom of the well, to a point 50 feet below [20 feet above the top of] the lowest stratum bearing or having borne oil, gas or water. At this point there shall be placed a plug of cement, which shall extend for at least 50 feet above this stratum [that point]. Each overlying formation bearing or having borne oil, gas or water shall be plugged with cement a minimum of 50 feet below this formation to a point 50 feet above this formation. The zone between cement plugs shall be filled with nonporous material. [Between this sealing plug and a point 20 feet above the next higher stratum bearing or having borne oil, gas or water, the hole shall be filled with nonporous material and at that point there shall be placed another 50-foot plug of cement which] The cement plugs shall be placed in a manner that will completely seal the hole. [In like manner, the hole shall be filled and plugged, with reference to each of the strata bearing or having borne oil, gas or water.] The operator may treat multiple strata as one stratum and plug as described in this subsection with a single column of cement or other materials approved by the Department. Where the production casing is not retrievable, the operator shall plug that portion of the well under § 78.91(d) (relating to general provisions).

* * * * *

(b) The owner or operator shall plug a well, where the surface casing, coal protective casing and production casing are cemented, as follows:


 

18

* * * * *

(3) Following the plugging of the cemented portion of the production casing, the uncemented portion of the production casing shall be separated from the cemented portion and retrieved by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater . The maximum distance the stub of the uncemented portion of the production casing may extend is 100 feet below the surface or coal protective casing whichever is lower. In no case may the uncemented portion of the casing left in the well extend through a formation bearing or having borne oil, gas or water. Other stratum above the cemented portion of the production casing bearing or having borne oil, gas or water shall be plugged by filling the hole with nonporous material to 20 feet above the stratum and setting a 50-foot plug of cement. The operator may treat multiple strata as one stratum and plug as described in this subsection with a single column of cement or other material as approved by the Department. When the uncemented portion of the production casing is not retrievable, the operator shall plug that portion of the well under § 78.91(d).

§ 78.93. Wells in coal areas—surface or coal protective casing anchored with a packer or cement.

(a) In a well where the surface casing or coal protective casing and production casing are anchored with a packer or cement, the owner or operator shall plug the well as follows:

(1) The retrievable production casing shall be removed by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater.

[and the] The well shall be filled with nonporous material from the total depth or attainable bottom of the well, to a point 50 feet below [20 feet above the top of] the lowest stratum bearing or having borne oil, gas or water. At this point there shall be placed a plug of cement, which shall extend for at least 50 feet above this stratum [that point]. Each overlying formation bearing or having borne oil, gas or water shall be plugged with cement a minimum of 50 feet below this formation to a point 50 feet above this formation. The zone between cement plugs shall be filled with nonporous material. [Between this sealing plug and a point 20 feet above the next higher stratum bearing or having borne oil, gas or water, the hole shall be filled with nonporous material and at that point there shall be placed another 50-foot plug of cement which] The cement plugs shall be placed in a manner that will completely


 

19

seal the hole. [In this manner, the hole shall be filled and plugged, with reference to each of the strata bearing or having borne oil, gas or water.] The operator may treat multiple strata as one stratum and plug as described in this subsection with a single column of cement or other material as approved by the Department. When the production casing is not retrievable, the operator shall plug this portion of the well under § 78.91(d) (relating to general provisions).

(2) The well shall then be filled with nonporous material to a point approximately 200 feet below the lowest workable coal seam, or surface or coal protective casing seat, whichever is deeper. Beginning at this point a 100-foot plug of cement shall be installed.

(3) After it has been established that the surface casing or coal protective casing is free and can be retrieved, the surface or coal protective casing shall be retrieved by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater. [and a] A string of casing with an outside diameter of not less than 4 1/2 inches for gas wells, or not less than 2 inches for oil wells, shall be run to the top of the 100-foot plug described in paragraph (2) and cemented to the surface.

* * * * *

§ 78.94. Wells in noncoal areas—surface casing is not cemented or not present.

(a) The owner or operator shall plug a noncoal well, where the surface casing and production casing are not cemented, or is not present as follows:

(1) The retrievable production casing shall be removed by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater. The well shall be filled with nonporous material from the total depth or attainable bottom of the well, to a point 50 feet below [20 feet above the top of] the lowest stratum bearing or having borne oil, gas or water. At this point there shall be placed a plug of cement, which shall extend for at least 50 feet above this stratum [that point]. Each overlying formation bearing or having borne oil, gas or water shall be plugged with cement a minimum of 50 feet below this formation to a point 50 feet above this formation. The zone between cement plugs shall be filled with nonporous material. [Between this sealing plug and a point 20 feet above the next higher stratum bearing or having borne oil, gas or water, the hole shall be filled with nonporous material and at that point there shall be placed another 50-foot plug of cement which] The cement plugs shall be placed in a manner that will completely seal the hole. [The hole shall be filled


 

20

and plugged, with reference to each of the strata bearing or having borne oil, gas or water.] The operator may treat multiple strata as one stratum and plug as described in this paragraph with a single column of cement or other materials as approved by the Department. When the production casing is not retrievable, the operator shall plug this portion of the well under § 78.91(d) (relating to general provisions).

(2) After plugging strata bearing or having borne oil, gas or water, the well shall be filled with nonporous material to approximately 100 feet below the surface casing seat and there shall be placed another plug of cement or other equally nonporous material approved by the Department extending at least 50 feet above that point.

(3) After setting the uppermost 50-foot plug, the retrievable surface casing shall be removed by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater. [and the] The hole shall be filled from the top of the 50-foot plug to the surface with nonporous material other than gel. If the surface casing is not retrievable, the hole shall be filled from the top of the 50-foot plug to the surface with a noncementing material.

* * * * *

§ 78.95. Wells in noncoal areas—surface casing is cemented.

(a) The owner or operator shall plug a well, where the surface casing is cemented and the production casing is not cemented or not present, as follows:

(1) The retrievable production casing shall be removed by applying a pulling force at least equal to the casing weight plus 5000 pounds or 120% whichever is greater. If this fails, an attempt shall be made to separate the casing by cutting, ripping, shooting or other method approved by the Department, and making a second attempt to remove the casing by exerting a pulling force equal to the casing weight plus 5,000 pounds or 120 percent of the casing weight, whichever is greater. [and] T[t]he well shall be filled with nonporous material from the total depth or attainable bottom of the well, to a point 50 feet below [20 feet above the top of] the lowest stratum bearing or having borne oil, gas or water. At this point there shall be placed a plug of cement, which shall extend for at least 50 feet above this stratum [that point]. Each overlying formation bearing or having borne oil, gas or water shall be plugged with cement a minimum of 50 feet below this formation to a point 50 feet above this formation. The zone between cement plugs shall be filled with nonporous material. [Between this sealing plug and a point 20 feet above the next higher stratum bearing or having borne oil, gas or water, the hole shall be filled with nonporous material and at that point there shall be placed another 50-foot plug of cement] The cement plugs shall be placed in a manner that will completely seal the hole. [The hole shall be filled and plugged, with reference to each of the strata bearing or having borne


 

21

oil, gas or water.] The operator may treat multiple strata as one stratum and plug as described in this subsection with a single column of cement or other materials as approved by the Department. When the production casing is not retrievable, the operator shall plug this portion of the well under § 78.91(d) (relating to general provisions).

* * * * *

§ 78.96. Marking the location of a plugged well.

(a) Upon the completion of plugging or replugging a well, the operator shall erect over the plugged well a permanent marker of concrete, metal, plastic or equally durable material [or metal and concrete]. The marker shall extend at least 4 feet above the ground surface and enough below the surface to make the marker permanent. Cement may be used to hold the marker in place provided the cement does not prevent inspection of the adequacy of the well plugging. The permit or registration number shall be stamped or cast or otherwise permanently affixed to the marker. In lieu of placing the marker above the ground surface, the marker may be buried below plow depth and shall contain enough metal to be detected at the surface by conventional metal detectors

* * * **

SUBCHAPTER E. WELL REPORTING

78.121. [Annual] P[p]roduction reporting. 78.122. Well record and completion report. 78.123. Logs and additional data. 78.124. Certificate of plugging. 78.125. Disposal and enhanced recovery well reports.

§ 78.121. [Annual] P[p]roduction reporting.

(a) The well operator shall submit an annual production and status report for each well on an individual basis, on or before [March 31] February 15 of each year. The operator of a well which produces gas from the Marcellus shale formation shall submit a production and status report for each well on an individual basis, on or before February 15 and August 15 of each year. Production shall be reported for the preceding calendar year or in the case of a Marcellus shale well, for the preceding six months. When the production data is not available to the operator on a well basis, the operator shall report production on the most well-specific basis available. The annual production report shall include information on the amount and type of waste produced


 

22

and the method of waste disposal or reuse. Waste information submitted to the Department in accordance with this subsection shall satisfy the residual waste biennial reporting requirements of § 287.52 (relating to biennial report).

(b) The [annual] production report shall be submitted ELECTRONICALLY TO THE DEPARMENT THROUGH ITS WEBSITE.[on forms prescribed by, and available from, the Department or in a similar manner approved by the Department.]

§ 78.122. Well record and completion report.

(a) For each well that is drilled or altered, the operator shall keep a detailed drillers log at the well site available for inspection until drilling is completed. Within 30 calendar days of cessation of drilling or altering a well, the well operator shall submit a well record to the Department on a form provided by the Department that includes the following information:

* * * * *

                        (9)

A certification by the operator that the well has been constructed in accordance with this chapter and any permit conditions imposed by the Department.

 

[(10)] 11 Other information required by the Department.

(b) Within 30 calendar days after completion of the well, the well operator shall submit a completion report to the Department on a form provided by the Department that includes the following information:

(1) Name, address and telephone number of the permittee.

(2) Name, address and telephone number of the service companies.

(3) Permit number and farm name and number.

(4) Township and county.

(5) Perforation record.

(6) Stimulation record, including pump rates, pressure, total volume and list of hydraulic fracturing chemicals used, the volume of water used and identification of water sources used pursuant to an approved water management plan.

(7) Actual open flow production and [rock] reservoir pressure.


 

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LINKS

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Pennsylvania's Act 220

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