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.
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.