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Saturday, February 23, 2013

Rome Wasn’t Built in a Regulator’s Day!

Or Could It Have Been?
By Laurie Barr
February 24, 2013

For many Pennsylvania citizens living in the Marcellus Shale development zone, their land, water and livelihoods are on the line while the Technical Advisory Board and PADEP officials slowly mull over revisions to Pennsylvania's oil and gas rules.
In the future, operators in Pennsylvania may be required to ask for assistance from nearby landowners to track down old, abandoned wells, but status quo allows operators to situate new wells and the fracture zones of their lateral bores in legacy fields with the option of crossing their fingers in hopes nothing pops or blows up.
During a 1942 scrap metal drive to help support the war effort, wellheads, their casings, and gathering lines were dismantled; leaving little evidence behind of their existence. The scrap drive came after an extensive drilling campaign which began in the early 1930’s with the discovery of large volumes of gas in the deep formations in Pennsylvania.
It wasn’t until the mid 1980’s (state) regulations required operators to record and report the locations and depths of their wells. Up until then, an unknown number of wells had been drilled and abandoned.
In 2010 the abandoned well issue was raised by the State Review of Oil and Natural Gas Environmental Regulations (STRONGER) board, which reviews regulations associated with drilling and hydraulic fracturing, develops guidelines, and makes recommendations for states regulatory programs.
After completing their review (of Pennsylvania’s regulations), the STRONGER board recommended; “…DEP should require operators to identify and eliminate these potential pathways for fluid movement into groundwater before conducting hydraulic fracturing operations.”
According to the (latest) proposals, locating and identifying well locations may be a task left for landowners because the (current) proposals, if approved, would require operators to ask landowners to identify well locations.
For those who lie in wait for Pennsylvania’s regulators to get this right; the (proposed) revisions are a long way off in more ways than one.

Landowners Cross Your Fingers Too!

The ‘closing of the barn doors after the horses escape’ plan may be instituted. Operators may be required to monitor nearby unplugged wells during drilling and hydraulic fracturing and may be required to plug those that have been affected by the procedures. By then communication between the wells would have likely caused contamination to the surrounding environment. Prevention doesn’t seem to be an entrée regulators are interested in serving to the operators and landowners. The decision to plug nearby abandoned well(s )prior to drilling and hydraulic fracturing may be left to the discretion of the operators and some may not electively plug.

Location is Everything

 Locating abandoned wells has proven to be no easy feat. During the construction of a well pad located in North Beaver Twp., Lawrence County, Shell hired a contractor to locate legacy wells on a nearby farm.
 The well locations are documented and identified on a USGS map. Their wellheads and related infrastructure were removed long ago. After the (contractor) team’s extensive efforts, many man hours, using equipment including; magnetometers and excavating equipment, they failed to locate the wells.
Most landowners don’t own the equipment used to locate abandoned wells so if you have difficulty locating legacy wells on your land; shopping for affordable geophysical/ ground-penetrating survey equipment may be something to add to your ‘to do’ list .