III. Well Designs and Construction for Hydraulic Fracturing;
supplied by Dr. Tom Williams, oil and gas field specialist.
Hydraulic Fracturing –
Any well subject to hydraulic fracturing or other high pressure injection systems or activities ( high pressure is when working pressures, for any and all activities from start to finish, exceed calculated hydraulic head of 0.42-0.6psi/foot of water) shall have the following reporting, design, documentation, analytical, and construction elements:
- Post all applications/notices on line and request comments – 2 weeks on Fracture HomePage
- Notify all owners and residents within 2500ft of the well, from head to toe – 30 days in advance of any HF stimulation.
- Require documentation and submission within 30days of completion for:
a. Fully described with calculations and drawings/flow charts;
b. Included in all applications and notices of intent submitted to the Division;
c. Subject to review and approval before undertaking; and
d. Fully described in subsequent Well Histories and in reports of activities to be submitted within 30 days of completion and reported monthly if prolonged beyond 30 days from initiation of high pressure operations.
- Post all reports, submissions, tests, logs, and well histories within 30 days of their preparation within 5 working days of DOGGR submission/receipt.
- Require any well to have 100% logged/tested cementing of casings to borehole wall
a. All casings shall have 100% casing-cementing-borehole wall from surface to toe suitable for containing calculated maximum pressures expected during any phase of well construction/reconstruction including drilling, complete, development, stimulation or other related activities during the initial drilling and any subsequent activities through abandonment.
- Conduct, Provide, Confirm and Certify logs of all casings for casing-cementing-borehole bonding integrity suitable and adequate to demonstrate full containment of calculated maximum pressures expected during any phase of well construction including drilling, complete, development, stimulation or other related activities during the initial drilling and any subsequent activities through abandonment.
- Conduct and Provide all wells to pressure test and use BlowOutPreventers rated to 120% of expected highest pressures.
a. All casings shall have specifications suitable for containing calculated maximum pressures expected during any phase of well construction/reconstruction, including drilling, complete, development, stimulation or other related activities during the initial drilling and any subsequent activities through abandonment.
b. All wells which may be pressurized in any manner above the calculated hydraulic pressure gradient shall be pressure-tested as an entire unit to the same level of pressure as to be used plus 20% (e.g., 6000psi expected maximum pressure requires a casing pressure test rated for 6000psi+1200psi = 7200psi) for a period equal to plus 20% of that during operations when pressures exceed the hydraulic gradient of 0.42psi/foot (e.g., 3hr for fracking = 180min + 36min = 216min for testing). Any pressure loss of >5% throughout the test period shall be assumed to equal failure of tests and additional activities shall be required prior to any other high pressure efforts until such compliance for the full test period is achieved.
c. All drilling and any other pre-production activities shall be equipped with a blowout preventer installed, operational, and tested suitable for containing the calculated maximum pressures to be reached during any phase of well activities (e.g., if fracked at 8000-9000psi, a BOP rated at 10,000psi would be used during all phases of well construction or reconstruction).
- Conduct and Provide monitoring seismicity and water quality before, during, and after drilling, completing, stimulating, and up to initial production and 60 days thereafter.
- Conduct and Provide full logs any/all water, gas, or petroleum composition and shall establish for each well activity. Actual depth to useful water (<30,000mg/L total dissolved salts) and for gas or oil contents (>50mg/L TPH).
- Conduct and Provide cross-hole geophysical logging for all wells within 500ft of subject wells for any and all water, gas, or petroleum composition
shall be undertaken and shall establish for each well activity. Actual depth to useful water (100mg/l TPH) within 500ft of subject well.
- Conduct and Provide geophysical surveys of all areas with 4 or more wells to ascertain the depths and contours of the bases of “fresh” and useful water and the expected depths of any member, horizon, play, or zone with hydrocarbon contents >100mg/L TPH.
- Conduct and Provide AERIAL GASES BUDGET of all area with more than four (4) wells per square mile (640acres) with an annual estimate of all air emissions (e.g., Area/Unit/Field Emissions or emissions bubble) from any exploration, drilling, completion, and production activities and facilities for the area.
- Conduct and Provide emissions controls for all GHG and air toxics to reduce emissions to those estimated for the year 1990 within a five (5) year period.
- Conduct and Provide WATER BUDGET – an annual estimate of all water use, importation, storage, use, treatment, and disposal/discharge/disposition (e.g., Area emissions or emissions bubble) from any exploration, drilling, completion, and production activities and facilities for the area. Including Water Supply and Consumption, Surface Water and Spill Management Control Wastewater and Solid Waste Management, Groundwater Contamination water Flow Chart Produced Water, Industrial Process Water and Comingled Waters >51%Produced = produced, Produced Water.
- Conduct and Provide CHEMICAL BUDGET, including an annual estimate of all chemicals used for any exploration, drilling, completion, and production activities and facilities for the Area/Unit/Field/Lease and their composition after use and before any transport from the well pad.
- Conduct and Provide NATURAL RESOURCES BUDGET, including changes in Formation Permeability, Porosity, and Connectivity, Natural Fractures, Joints, and Faults, Waters, Hydrocarbon Liquids, and Hydrocarbon Gases.
- Conduct and Provide current pre-well activities OPERATIONAL PRESSURE, including actual pressures, less than estimated pressure, more than or longer than estimated duration.
- Develop, Implement, and Provide WELL CONTINGENCY PROGRAMS for all emergency conditions which would be expected, based on past 20+ years of oil field activities (e.g., blowout, spills/releases, etc.)
- Develop, Implement, and Provide PERIODIC RE-LOGGING, RESURVEY AND RE-TESTING of wells, pressure tests, water/oil/gas logs.
- Develop, Implement, and Provide LIABILITIES AND DO-NO-HARM CLAUSES for gas-oil related complaints, Prove No Harm.
- Develop, Implement, Conduct and Provide WELL ABANDONMENT PROGRAM to a.) review all historic sources and confirm locations and conditions of every know, expected, and suspected well within 2500ft of any well from head to toe; b.) locate wells and conduct tests and monitor gases and pressures within the well; c.) conduct risk management for each well in relationship to the field and individual operating wells;
- Require all operators to establish funds for the Division’s FULL COSTS RECOVERY for implementing above measures based on the actual use of hydraulic fracturing.
- Re-abandon any well within 2500ft of an operating well with 100% cementation (0% mud) of well annular and internal casing space.
Additionally we would like to see Fracking operations and regulations to reflect these precepts:
- Prove Do NO Harm (No Risk) and have inferred liability (similar to how FDA has a New Drug Approach) – “All drugs” have implied liability even when tested and certified by FDA. Similarly all frack jobs have implied liability to the community.
- Support the democratic process and an Informed Public. All information/elements on the table and hold town hall or like community meetings until all concerns/issues are resolved or satisfactorily addressed.
- Require informed consent by the surrounding community and those at Risk.