The Texas Railroad Commission has updated Statewide Rule 13.
Since this rule has had no major updates in the last 30 years–way before the 2002 wedding of horizontal drilling and fracking in my backyard–these are much needed improvements, they are a good start but more needs to be done (like converting to clean energy ASAP).
I haven’t tallied up all the improvements yet but there are way over 20 and they cover drilling, casing, cementing, well control and blow-out preventers and fracking.
I don’t like giving grades but it is important to give credit when due. If pressed, I might give the RRC a “B” on this update.
I have 5 points to make:
First, some of these improvements require additional monitoring, which presents the two following problems:
- Monitoring is not prevention. To confirm that ask any woman who just learned from her mammogram that she has breast cancer.
- Industry gets the monitoring job. Scouts’ honor hasn’t worked well with this industry. See page 8, FLOWBACK: How the Texas Natural Gas Boom Affects Health and Safety: As result of the lawsuit, which did not go to trial until 1996, the Railroad Commission investigated and found that more than 100 wells in the county “didn’t have enough surface casing to protect groundwater and that records about the surface casing had been falsified.”
Second, remember a rule is only good if it’s enforced and the RRC and 5 other state regulatory agencies received an “F” for enforcement.
Third, as I said before: Size matters especially when you are considering the annular space because that’s where the cement goes. The new RRC rule starts out with a .75 inch annular space requirement, which seems inadequate to me but is what experts recommend. But in the deeper part of the well, they peter out to a wimpy .5 inch.
Fourth, the RRC receives a tremendous amount of pressure from industry. They receive much less pressure from regular citizens and environmental groups. I think comments from regular citizens need to be weighted.
Fifth, the RRC has more rule updates planned and this process can’t be fun for anyone. If we want better rules we will need to weigh in and give the Commission some cover.
I’m still wading through the the comments and the RRC’s response.
Page 13, Line 8 starts an interesting discussion about fracture height.
The discussion on the “cement sheath thickness” starts on Page 17, Line 13.
On Page 23, Line 10 there is a mention of a Schlumberger article on casing failures. I think this is the article. It’s from 2003 (the year after the 2002 wedding of horizontal drilling and fracking in my backyard). The RRC dismissed it saying the examples of failures are offshore wells or those in “extreme environments” and the data is old. They also said “…failure would be detected, generally by an increase in bradenhead pressure which the Commission’s rules require operators to monitor and address as necessary.” See “First” above. Later, I will have more to say about “extreme environments” and about my experience of how industry monitors bradenhead pressure. I would love to see current data on casing failures–the known casing failures?
Page 28, Line 12 to Page 31 is worth reading.
The amendments start on Page 34.
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Ha, Ha, Ha. I can’t wait to read this ammendment. I’ll bet there have been changes—–BUT, if the changes are relevant to better well integrity, then there will always be EXEMPTIONS or AMMENDMENTS to get around the NEW requirements—-Ha, Ha, I can’t wait to read it.
PS: for instant the .5 inch annular space is meaningless when there are no requirements for centralizing of casing, or for 100% annulus cement bond logs to be reported for public viewing, etc., etc., etc.
The Honest Truth says
I would really like to know how we are going to convert to clean energy ASAP.
The honest truth is that oil and gas does not have to fuel our country and there is ample evidence to prove that we have enough wind and solar to provide our energy needs. But I don’t expect someone who thinks “The Honest Truth” is that you can’t smell H2S gas to have the motivation to seek out that information.
The Honest Truth says
Please tell me more on how solar and wind can completely replace oil and gas? And in a feasible manner? You’re talking about completely redoing every power plant that supplies electricity to the country, every car, the makeup you use, other toiletries, your hot water, your heat, airplanes, roads, and I could go on. I don’t see how someone with a level head could think that we can replace all of that with wind and solar. You should also think about how windmills and solar panels are manufactured and the fuel needed to manufacture them. On top of that, as a whole, windmills and solar energy in that large of a scale is way more expensive to produce and maintain than oil and gas. If they worked so efficiently and cost effectively then why did people stop using them when it was discovered that oil and gas can provide better benefits at way lower costs.
Much of the costs of oil and gas have always been externalized to the taxpayers and citizens- polluted water, polluted air, cancer, disease, tax breaks and subsidies for the oil and gas industry, a massive expensive global military presence, trillion dollar wars (Iraq), millions of lives maimed and lost, Global Warming. “Privatize the profits, socialize the costs” is the name of the game in the fossil fuel industries.
If all the true costs of oil and gas were actually factored in, the fossil fuels would be MUCH more expensive than they currently seem to be.
Despite all the help the fossil fuel industries get in this country, renewables are already starting to compete at an equal price level or even cheaper in some cases. The technology keeps improving, efficiency of solar panels keeps improving (check out SunPower’s C7 technology due to be deployed soon), and just about everybody who has a house has a place to put some decentralized power generating capability. Maybe the future isn’t in big centralized power plants, but in each house producing some (or all) of its own power. Then you don’t need as much transmission infrastructure.
Sure, it won’t happen overnight and there are still limitations. But we could do this if we really got behind it. What’s really sad is that if a Big Oil company put just 10% of its yearly profits into switching to renewables, we’d probably be able to make the switch in no time. But the short-sighted short-term profit mentality doesn’t do too well with long-term concerns.
Oil and Gas fuels our country says
I can’t tell if you are joking or not Tom. I’m guessing you’ve watched a lot of videos like Gaslands, the movie that was made for that guy to make money. It’s fallacies have been exposed so you might want to read up on that. You do realize that oil and gas companies are getting taxed more than they used to be, and that partially fuels (no pun intended) higher prices of the products made using oil and gas that you use in your everyday life. And with Barack Obama as president, even more taxes on O&G companies are waiting to be voted on. If those taxes get approved, it will drive up your cost of living. And if you think oil and gas will be done away with in your lifetime, you are clearly mistaken. If you think the wars are all about oil and gas, you are completely wrong. I have a feeling you might be very anti-war, but I don’t want to rush to judgement, but from my experiences talking to lots of veterans (who come home to find there are plenty of jobs supporting our failing economy), they really take pride in fighting to keep our freedom here and to keep people from trying to attack America. Also, profits are not privatized in public companies, it’s the same throughout the whole US. And this global warming you talk about – you do realize there were record lows all across the US this year in March and April, along with record snow fall? With the amount of solar energy I’ve seen used around the world, well, it’s pretty safe to say that even though the technology has been there for a long time, it’s still barely used. I don’t think you have read annual financial reports of many oil and gas companies or else you would know that they are putting profits in renewable energy research, and have been for many years. As far as making the switch in no time…. well, I have no idea what you are talking about since making that switch will cost a lot more than producing the proven oil and gas reserves that can last us at least another 200 years. I say proven because new fields are being discovered every month or so and new technologies are allowing older fields to recover more and more of what they weren’t able to recover before. I don’t know what long-term means to you, but 200 years is long term enough for me, and that’s a cautious estimate.
It’s hard to get a man to understand something when his paycheck depends on him not understanding. Upton Sinclair
The O&G companies are a BIG part of our military industrial complex. I know it well!