“Frack-out” is also a term used for “communication” incidents.
Since 2016, DEP has required shale gas operators to submit an Area of Review analysis as part of the permitting process for unconventional wells to help identify abandoned wells, water wells and conflicts with other shale gas wells and laterals before they happen.
Operators have submitted 5,414 Area of Review submissions to DEP.
A total of 14,412 shale gas wells have been drilled in Pennsylvania and a total of 23,720 wells were issued permits, starting in 2003.
Joel Keller, an Environmental Group Manager in the Office of Oil and Gas Management, gave the Board a broad overview of the lessons learned in implementing the Area of Review process in permitting unconventional shale gas wells.
Area Of Review Process
“[Area of Review] regulations require an operator of unconventional wells to identify wells within a specific area, execute monitoring at a subset of those wells having certain penetration depths, and submit a report and accompanying plat 30 days prior to drilling the well, or at the time the permit application is submitted, if drilling is planned less than 30 days after permit issuance,” said Keller.
Locating Wells
“Operators have to locate wells, they have to locate offset wells within 1,000 feet in all directions around the wellbore path and the well itself,” explained Keller. “This is accomplished by reviewing reference materials such as DEP databases, historical sources, and also field surveys.”
The “wellbore path” includes both the vertical and horizontal-lateral portion of the unconventional well.
Landowner Survey
“The regulations also require an operator to submit what's called a landowner questionnaire by certified mail to landowners whose property falls within the area of review survey,” said Keller.
He pointed out “the landowner is not required to complete this form,” but at the same time he said it could contain important information.
Zone Of Fracturing Influence
“After these offset wells are identified, the operator determines what wells penetrate what's called the zone of hydraulic fracturing influence. This is a vertical buffer distance, 1,500 feet vertically, upward, and downward from the wellbore path,” said Keller.
The operator is also required to coordinate with adjacent shale gas operators to notify them if their wells penetrate the zone of fracturing influence.
[See drawing accompanying this article.]
Risk Based Approach
“This is a risk-based approach to monitoring based on the well type, age, condition, construction status,” said Keller. “Certainly risk levels for a Marcellus well that falls within the zone of hydraulic fracturing influence is of less concern than an abandoned well that penetrates the zone of hydraulic fracturing influence or a well that's unknown.”
5,414 Plans Submitted
Keller said DEP has received 5,414 Area Of Review submissions since 2016-- 2,181 in the Southwest District, 610 in the Northwest and 2,623 in the Eastern District.
There is no requirement for DEP to approve the plans.
Keller said the reports are available for public review through the e-submission public interface.
54 Well Incidents
Keller said DEP has received 54 well “communication” incident notifications. Two incidents required immediate notification.
“The two incidents that were immediate notification, those incidents had fluids observed at the surface. One was an apparent communication with an abandoned well, and the other one was a release of fluids apparently from an offset Marcellus well,” said Keller.
“The remaining 52 incidents, generally based on the information we received through the notifications, resulted in impacts to offset Marcellus wells,” said Keller.
“[Impacts include] maybe increased water production is an example, or decreased production, increases in pressure. Some annular pressure increases were noted on Marcellus wells, offset Marcellus wells, and impacts to drilling operations were also noted as part of the 52 incidents that were submitted.”
Process Working
“Based on the incident notifications we received and communications with the district, the AOR process appears to be working,” said Keller.
“The surveys are resulting in operators and the DEP identifying and evaluating known and unknown wells that may be impacted by hydraulic fracture.
“Operators are using this data to assess potential impacts to offset wells and implement moderating activities accordingly.
“If anomalies are observed at a well undergoing hydraulic fracturing or impacts are observed at offset wells, operators are notifying DEP and communicating with the adjacent operators.
“In response to these incidents, operators are pausing, ceasing, now modifying hydraulic fracturing operations, and skipping stages, etc., equipping offset wells for potential impacts, meaning maybe installing tanks, secondary containment, also maybe performing some well interventions and even plugging wells,” said Keller.
Resource For Other Investigations
“The AOR submittal reports, and even if an operator chooses to do what's called a site specific report, they become very valuable for our staff to use when investigating other water supplies and stray gas cases,” said Keller.
“And also we can compile this information and try to identify patterns for what's occurring.
“Maybe with communication incidents we're seeing... maybe one area we're seeing a lot of lateral-to-lateral Marcellus communication from what we've learned from some of these incident notifications.
“So this data could be used to determine and investigate if there are any patterns that might reveal something unique going on in that particular area,” Keller explained.
Improvements
Keller suggested there needs to be a faster entry of data on the location of abandoned wells being developed as part of the federal well plugging program funded by the Bipartisan Infrastructure Act.
Having that information more quickly would help in the Area of Review development process.
“Similarly, going back to the data we get from all the incident notifications, we could maybe even spatially document some of these communication incidents into some kind of mapping component or something that's viewable more in a spatial manner,” said Keller.
Conclusion
Kurt Klapkowski, DEP Deputy for Oil and Gas Management, said, “I think from my perspective, the success isn't necessarily so much the impacts that the offset well is occurring or not.
“But what are the operators able to do and prepare for before they actually go through the process of hydraulically fracturing the well, and are they addressing those types of concerns up front?
“And a good example of that was the Barron well in Washington County where range resources discovered a gas well under pressure that was in the zone of influence and came to us and said, ‘Will DEP plug this well? We'll pay for it if you plug it.’ [Read more here]
“And we did. And it was a well that was in the middle of a mobile home park.
“And if they had fracked into that well and caused significant methane migration in that situation, I think that would've been a disaster.”
“I think the other question that this particular case presents is, are the distances appropriate and conservative enough?
“And I think, again, because we've got one incident out of 5,400, that's a pretty good number in terms of that.
“I feel pretty comfortable that these distances are adequate distances for operators to be considering these issues in the subsurface and what impacts their hydraulic fracturing operations might actually have.”
DEP has an Area of Review FAQ to describe this process.
For more information on Board activities, visit DEP’s Oil and Gas Technical Advisory Board webpage. Questions should be directed to Todd Wallace, at twallace@pa.gov or (717) 783-6395.
NewsClip - Well Communication:
-- The Energy Age Blog: Well Communication Events Over Past 8 Years
Related Articles - Communication Incidents:
Related Article This Week:
-- DEP Reports The Number Of Methane Contaminated Water Supplies From Oil & Gas Drilling Is Up ‘Across The Board,’ ‘Not A Good Trend’ [PaEN]
-- DEP Pursuing Federal Funding To Further Define Human Health Impacts Of Abandoned Conventional Oil & Gas Wells [PaEN]
-- Spring Road Dumping Season Underway As Conventional Oil & Gas Operators Get Rid Of Their Wastewater [PaEN]
-- Susquehanna River Basin Commission Approves 8 Shale Gas Drilling Water Withdrawals, Adopts New General Permit For Cooperative Fish Nurseries [PaEN]
[Posted: March 20, 2024] PA Environment Digest
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