The Railroad Commission of Texas (RRC) amended its oil and gas well construction requirements rule (Statewide Rule 13) to clarify requirements related to casing, cementing, drilling, well control and completions. The rules include innovations that put the state “back into a leadership position on regulation of oil and gas well construction,”
The changes take effect Jan. 1, 2014 and apply to any wells drilled on or after that date. Two environmental groups voiced strong support for the changes.
For wells undergoing hydraulic fracturing (fracking) treatments, operators are now required to pressure test well casings to the maximum pressure expected during the fracture treatment and to notify the RRC of a failed test. Also during fracking, operators are required to monitor the annular space between the well’s casings for pressure changes (which could indicate a leak in casing) and suspend fracking if the annuli monitoring indicates a potential down hole casing leak.
Operators must also now isolate (place cement behind casing) across and above all formations that have a permit for an injection or disposal well within one-quarter mile of a proposed well and must obtain RRC approval before setting surface casing to a depth exceeding 3,500 feet. The changes establish additional testing and monitoring requirements for “minimum separation wells” where the vertical distance between the base of usable quality water and the top of a formation to undergo fracking is less than 1,000 vertical feet. “This provision involves a limited number of vertical wells that are vertically hydraulically fractured in a handful of shallow fields, which are found in the Abilene, Midland, San Antonio and Wichita Falls areas and does not involve horizontally completed and hydraulically fractured wells in the major plays in the Barnett Shale, Eagle Ford Shale and Permian Basin,” the commission said.
Operators are required to use air, fresh water or fresh water-based drilling mud until surface casing is set and cemented in a well to protect usable quality groundwater and are required to pump sufficient cement to isolate and control annular gas migration and isolate potential flow zones and zones with corrosive formation fluids. References to cement quality, cementing, well equipment, well casing centralizers and well control have been updated, and standards of minimum cement sheath thickness of at least 0.75 inches around the surface casing and a minimum cement sheath thickness of 0.50 inches around subsequent casing strings have been established. Requirements for well control and blowout preventers have been consolidated and updated, and the requirements distinguish between the use of well control equipment on inland, bay and offshore wells.
The changes also implement Article 2 of HB 2694 to reflect the transfer of the Texas Commission on Environmental Quality’s surface casing section to the RRC, where it is now called the groundwater advisory unit. “As usable quality groundwater depth varies statewide, this unit establishes the depth of surface casing required for each well to protect groundwater,” RRC said.
“These new rule amendments will provide our oil and gas operators with consistent and clear regulations,” said RRC Commissioner Christi Craddick. “They also enhance the Railroad Commission’s ongoing effectiveness in overseeing the responsible development of our domestic energy resources, which has resulted in one of this nation’s greatest economic success stories.”
The Sierra Club Lone Star Chapter and Environmental Defense Fund (EDF) cheered the “biggest overhaul of oil and gas rules in over 30 years,” they said and called Texas a leader in “new, innovative” drilling technologies. “State regulators made significant progress with the Rule 13 revisions,” said Cyrus Reed, Sierra Club Texas conservation director. “The Texas oil and gas industry has changed rapidly, and this overhaul of Rule 13 is a good start to address some of the public health and environmental concerns associated with hydraulically fractured wells.”
The rule is among the first in the nation to pay attention to the geology that separates protected underground water from rock being hydraulically fractured, the groups said. “This is important to be sure that any risks of fractures extending into water supplies are avoided.”
Other key innovations in the rule include a more sophisticated approach to determining which rock layers in a well need to be sealed off in order to assure the well’s pipes and cement protect water supplies from pollution.
“Texas has moved back into a leadership position on regulation of oil and gas well construction,” said Scott Anderson, EDF senior policy adviser. “Agencies around the country, including the federal Bureau of Land Management, can learn a lot from studying these rules as well as similar rules adopted last year in Ohio.” The groups, however, said one particular provision in Rule 13 falls short of requiring industry to follow best practice: the annular space requirements. “The RRC set this space below the limit experts advise in order to protect the environment,” the groups said.
Also last week, Texas Gov. Rick Perry signed HB 2767, legislation intended to encourage wastewater recycling from drilling and fracking operations for reuse rather than injection of the waste into disposal wells. The legislation, which takes effect Sept. 1, aims to clear up legal ambiguities around responsibility for transferred drilling waste. It adds a chapter to the state’s Natural Resources Code stipulating that it is necessary to conserve water resources and reduce the amount of liquid waste from oil and natural gas drilling and well stimulation activities.
Under the legislation, the party in possession of the waste is responsible for it, and that responsibility is passed at the point of sale, when waste is handed off to a recycling facility operator, for instance. The bill was introduced by Republican state Rep. Phil King. Backers of the legislation have asserted that a lengthy permitting process for facilities to treat wastewater away from the drilling lease area, and legal ambiguity about the ownership and legal liability for transferred waste have been obstacles to more oil and gas waste recycling.
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