Railroad Commission of Texas. Chairman Elizabeth Ames Jones Commissioner David Porter Barry T. Smitherman

Transcription

1 Railroad Commission of Texas Chairman Elizabeth Ames Jones Commissioner David Porter Barry T. Smitherman 1

2 Crossing the Pecos River The Railroad Commission of Texas acquired jurisdiction over oil and gas in a 1917 Act designed to prevent monopolistic practices, unfair pricing and discrimination in oil and gas pipelines. In 1919, the Texas Legislature passed a law which established the core regulations governing oil and gas and gave the Railroad Commission authority to regulate oil and gas production to prevent waste. The Railroad Commission has regulatory authority over oil and gas, common carrier pipelines, whether oil or gas, and over natural gas pipelines (Natural Resources Code and the Texas Utilities Code).

3 Table of Contents Introduction Tarrant County Disposal Wells Commercial Disposal Wells Commission Inspection Process Mechanical Integrity Test Hydraulic Fracturing Questions and Answers

4 Objectives Protect surface and groundwater, public health and safety Prevent waste and promote conservation Protect correlative rights to develop mineral resources

5 Regulatory Background There are over 392,000 oil and gas industry wells in Texas The first injection well in Texas was permitted in 1936 There are have been over 100,000 wells permitted for injection Over 52,000 have current permits, approximately 32,000 are active

6 Statutory Authority (Oil and Gas Division) Chapter 27 of the Texas Water Code: Well is in the public interest No harm to oil, gas, or other mineral formation Both ground and surface water protected Financial responsibility Various Chapters of the Natural Resources Code:

7 Railroad Commission Rules Permitting 16 TAC 3.8 Water Protection (pits, discharges, waste haulers) 16 TAC 3.9 Oil and Gas Waste Disposal into Non-productive Formations (Chapter 27 of the Water Code) 12,000 permitted (approx active) 16 TAC 3.46 Fluid Injection into Productive Formations (Natural Resources Code) 39,000 permitted (approx. 25,000 active)

8 Disposal vs Treatment Over 12 million barrels of produced water has been recycled, compared to: 427 million barrels of produced water has been disposed since 2007

9 Permitting Requirements Generalized Base of Useable Quality Groundwater Notice and Hearing Opportunity Area of Review study by Austin Geologic Requirements Surface Casing Requirements Production Casing cementing requirements Tubing/Packer

10 Notice & Hearing Surface owner notification Adjacent landowners (Commercial Disposal) Operators within ½ mile City clerk if within city limits Published in newspaper Protest considered in public hearing

11 Area Of Review Applicant for a disposal well permit must provide the data of record for wells that penetrate the proposed injection zone within (at least) one quarter (1/4) mile expanded when appropriate. Confirm wells have been plugged (or cased and cemented) in a manner that will prevent the movement of fluids into strata other than the authorized injection or disposal zone. Tabulated data keyed to a corresponding map.

12 Geological Requirements 1. Verify that the proposed injection zone is adequately isolated by relatively impermeable strata to confine injected fluids to the proposed injection interval. 2. Proposed injection interval must be isolated from overlying usable quality water by a sufficient thickness of relatively impermeable strata (accumulative total of at least 250 feet of clay or shale).

13 Completion Requirements: Three Degrees of Separation Between Injection Stream and Groundwater 1st Degree Surface casing set through entire interval deemed to have useable quality groundwater and cemented to ground surface 2 nd Degree Long string casing with at least feet of cement above injection interval 3 rd Degree Tubing set on a mechanical packer within 100 feet of the top of the injection interval

14 Ellenburger SWD Wells Monitoring & Testing Drilling & Completion Casing Cementing Tubing Packer Testing Prior to Service Cement Bond Log Pressure Testing Operations Continuous Monitoring Annual Integrity Testing Reporting Prior to Placing in Service Monthly Injection Date Pressure Volume

15 TARRANT COUNTY DISPOSAL WELLS

16 CURRENTLY DRILLED OPERATOR DISPOSAL WELLS Commercial Non-Commercial TARRANT COUNTY LEASE # O/G WELL API# OPERATOR LEASE NAME O FINLEY RESOURCES, INC. WEST TARRANT CO. WATER DISPOSAL O NABORS WELL SERVICES CO. FW SWD O RADIUS OPERATING, LLC I-20 SWD G DEVON ENERGY PRODUCTION CO, L.P. NORTH TARRANT SWD G PROVEN RESERVES MANAGEMENT, INC. BAGBY G QUICKSILVER RESOURCES INC. ALLIANCE AA BREWER UNIT G CHESAPEAKE OPERATING, INC BRENTWOOD SWD G A 1DM CHESAPEAKE OPERATING, INC DFW NORTH G C 1DE CHESAPEAKE OPERATING, INC DFW

17 COMMERCIAL DISPOSAL PERMIT

18 COMMERCIAL DISPOSAL with Conditions & Requirements Disposal wells must be equipped with surface casing set at least as deep as the deepest useable quality groundwater and cemented from TD to the ground surface. Long-string casing must be set at least to the top of the injection interval and cemented with sufficient cement to provide a minimum of 600 feet above the top of the shallowest productive horizon or the top of the permitted injection interval, whichever is greatest. Injection tubing must be set on a packer to within 100 feet of the top of the permitted injection interval. There must be at least 250 feet of impermeable shale between the top of the injection interval and the base of the useable quality groundwater. All wells within the area of review (1/4 mile for Ellenburger below NEBS, determined by pressure influence calculations above NEBS) must be adequately cased, cemented, or plugged such that they cannot become a conduit for non-confinement of fluid to the permitted injection interval. All storage vessels must have overfill detection equipment to prevent spills and secondary containment sufficient to hold total volume in the event of tank failure. All fabricated waste storage and pretreatment facilities (tanks, separators, or flow lines) shall be constructed of steel, concrete, fiberglass, or other materials approved by the Assistant Director of Technical Permitting. These facilities must be maintained so as to prevent discharges of oil and gas waste. There must be catch basin(s) constructed of concrete, steel, or fiberglass must be installed to catch oil and gas waste which may spill as a result of connecting and disconnecting hoses or other apparatus while transferring oil and gas waste from tank trucks to the disposal facility. The facility shall have security to prevent unauthorized access. A 24-hour attendant, a fence and locked gate when unattended, or a key-controlled access system shall secure access. For a facility without a 24-hour attendant, fencing shall be required unless terrain or vegetation prevents truck access except through entrances with lockable gates.

19 Commercial Disposal Facility Disposal Well Pressure Observation Valves Surface Casing Production Casing Tubing String Facility Safety Requirements 24 Hour Security Guard Shack Containment Ring - Dike Catch Basin Visual Alarm Storage Tanks Disposal Pumps Offloading Area Staging Area Concrete Apro

20 Commercial Disposal Facility & Guard

21 24 Hour Security Guard Shack Spill Containment Ring - Dike Visual Alarm Overfill Prevention Catch Basin Load Line Commercial Disposal Facility Safety Requirements

22 Disposal Well Tubing - Pressure Observation Valve & Gauge Production Casing - Observation Valve & Gauge Surface Casing - Observation Valve & Gauge Commercial Disposal Facility Disposal Well

23 COMMERCIAL DISPOSAL FACILITY INSPECTION

24 "Petrolmen" - dispatched by Governor Ross S. Sterling to enforce orderly conduct in the East Texas Field. 1933

25 Inspection Report - (Form D-O)

26 Inspection Sheet Detail page - (Form D-A)

27 DISPOSAL WELL TEST INSPECTION

28 Disposal Well Test Operator Pressure Test Report Form H-5 (Failed Test)

29 Disposal Well Test Commission Inspection Report Form D-O (Failed Test)

30 Disposal Well Test Operator Pressure Test Chart (Failed Test)

31 HYDRAULIC FRACTURING FLUID REGULATION

32 House Bill No AN ACT relating to the disclosure of the composition of hydraulic fracturing fluids used in hydraulic fracturing treatments. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS: SECTION 1. Chapter 91, Natural Resources Code, is amended by adding Subchapter S to read as follows: SUBCHAPTER S. DISCLOSURE OF COMPOSITION OF HYDRAULIC FRACTURING FLUIDS Sec DISCLOSURE OF COMPOSITION OF HYDRAULIC FRACTURING FLUIDS. (a) The commission by rule shall: (1) require an operator of a well on which a hydraulic fracturing treatment is performed to: (A) complete the form posted on the hydraulic fracturing chemical registry Internet website of the Ground Water Protection Council and the Interstate Oil and Gas Compact Commission with regard to the well; (B) include in the form completed under Paragraph (A): (i) the total volume of water used in the hydraulic fracturing treatment; and (ii) each chemical ingredient that is subject to the requirements of 29 C.F.R. Section (g)(2), as provided by a service company or chemical supplier or by the operator, if the operator provides its own chemical ingredients; (C) post the completed form described by Paragraph (A) on the website described by that paragraph or, if the website is discontinued or permanently inoperable, post the completed form on another publicly accessible Internet website specified by the commission; (D) submit the completed form described by Paragraph (A) to the commission with the well completion report for the well; and (E) in addition to the completed form specified in Paragraph (D), provide to the commission a list, to be made available on a publicly accessible website, of all other chemical ingredients not listed on the completed form that were intentionally included and used for the purpose of creating a hydraulic fracturing treatment for the well. The commission rule shall ensure that an operator, service company, or supplier is not responsible for disclosing ingredients that: (i) were not purposely added to the hydraulic fracturing treatment; (ii) occur incidentally or are otherwise unintentionally present in the treatment; or (iii) in the case of the operator, are not disclosed to the operator by a service company or supplier. The commission rule shall not require that the ingredients be identified based on the additive in which they are found or that the concentration of such ingredients be provided; HB 3328

33 (2) require a service company that performs a hydraulic fracturing treatment on a well or a supplier of an additive used in a hydraulic fracturing treatment on a well to provide the operator of the well with the information necessary for the operator to comply with Subdivision (1); (3) prescribe a process by which an entity required to comply with Subdivision (1) or (2) may withhold and declare certain information as a trade secret for purposes of Section , Government Code, including the identity and amount of the chemical ingredient used in a hydraulic fracturing treatment; (4) require a person who desires to challenge a claim of entitlement to trade secret protection under Subdivision (3) to file the challenge not later than the second anniversary of the date the relevant well completion report is filed with the commission; (5) limit the persons who may challenge a claim of entitlement to trade secret protection under Subdivision (3) to: (A) the landowner on whose property the relevant well is located; (B) a landowner who owns property adjacent to property described by Paragraph (A); or (C) a department or agency of this state with jurisdiction over a matter to which the claimed trade secret is relevant; (6) require, in the event of a trade secret challenge, that the commission promptly notify the service company performing the hydraulic fracturing treatment on the relevant well, the supplier of the additive or chemical ingredient for which the trade secret claim is made, or any other owner of the trade secret being challenged and provide the owner an opportunity to substantiate its trade secret claim; and (7) prescribe a process, consistent with 29 C.F.R. Section , for an entity described by Subdivision (1) or (2) to provide information, including information that is a trade secret as defined by Appendix D to 29 C.F.R. Section , to a health professional or emergency responder who needs the information in accordance with Subsection (i) of that section. (b) The protection and challenge of trade secrets under this section is governed by Chapter 552, Government Code. SECTION 2. Subchapter S, Chapter 91, Natural Resources Code, as added by this Act, applies only to a hydraulic fracturing treatment performed on a well for which an initial drilling permit is issued on or after the date the initial rules adopted by the Railroad Commission of Texas under that subchapter take effect. A hydraulic fracturing treatment performed on a well for which an initial drilling permit is issued before the date the initial rules take effect is governed by the law as it existed immediately before the effective date of this Act, and that law is continued in effect for that purpose. SECTION 3. The Railroad Commission of Texas shall adopt rules under Subchapter S, Chapter 91, Natural Resources Code, as added by this Act, not later than July 1, 2012, with the exception of those rules under Paragraph (E), which are to be adopted not later than July 1, SECTION 4. This Act takes effect September 1, HB 3328

34 QUESTIONS AND ANSWERS

35 Q. What Environmental protection measures are required for a saltwater disposal well construction? A. All drilling in Texas is controlled and permitted by the Railroad Commission of Texas. The RRC requires drillers to set steel pipe (surface casing) through the fresh water table and to cement the steel casing in place in order to prevent any contamination of the fresh water table. If you have any concerns about a drilling operation and your water well, you should contact the nearest regional office of the RRC to express your concerns. You can find contact information at the Railroad Commission web site at: Questions and Answers

36 Q. What Environmental protection measures are required for a saltwater disposal well construction? A. All drilling in Texas is controlled and permitted by the Railroad Commission of Texas. The RRC requires drillers to set steel pipe (surface casing) through the fresh water table and to cement the steel casing in place in order to prevent any contamination of the fresh water table. If you have any concerns about a drilling operation and your water well, you should contact the nearest regional office of the RRC to express your concerns. You can find contact information at the Railroad Commission web site at: Questions and Answers

37 Q. What is done with the waste water and fracing fluid? Is something done to clean it up for other uses or to be reused for the same? A. Some recycling of produced water is taking place within the Barnett Shale but those instances are still considered to be pilot projects. The reason is that the technology to recycle produced water still only yields a low percentage of usable water. Most produced water is taken to deep disposal wells and injected into those wells. An explanation of the recycling process that Devon Energy uses is here: iatives-waterrecycling.aspx Questions and Answers

38 Q. Why don t trucks that carry produced water or water that has been used in drilling have "TOXIC" signs on them to warn people if there is an accident? A. The water that gets transported from the drilling site is essentially salt water not clean enough for drinking or gardening. RRC requires waste haulers to be licensed and not to leak and to document where the waste comes from and its destination. Questions and Answers

39 Q. How does the RRC monitor SWD wells? A. The RRC inspects SWD wells periodically. The frequency of a routine well/lease inspection is based on many factors including the type of well/operation, the location of the well with regard to public areas or sensitive environments, and the compliance record of the operator. Other actions that may trigger an inspection include a third-party complaint, notice to the RRC of a reportable incident, such as spill, fire, or blowout. Under normal conditions District 09 will inspect these commercial SWD wells on a quarterly (4 times/yr) basis.overall, in 2010, the RRC conducted 121,667 well or lease inspections statewide. Questions and Answers

40 THE END