Wednesday, July 28, 2010

DEP has proposed tougher standards for Oil & Gas drilling

From the FORESTcoalition:

The Public Comment Meetings are finished and there are only about ten days to get in your comments by e-mail.

These regulations call for more stringent standards for O&G drilling operations.

These regulations are vital. They upgrade requirements for testing, well casing, welding, cementing and other steps to prevent blowouts, migration of gas and release of fluids which could contaminate our waterways and aquifers.

The public comment period will end on 8/09/10.

If you missed the hearings, please submit your official written testimony via RegComments@state.pa.us

or via USPS at:
Environmental Quality Board
P.O. Box 8477, Harrisburg PA 17105-8477

• Be sure to use subject heading “CH 78 Regulations”
and include your full name and address.

Talking points – Choose the topics most important to you:

• Safety - Marcellus depths and pressures are so far beyond what was “normal” in the 1980’s, we must upgrade the Oil & Gas regulations to ensure safety.

• Prevent stray gas migration [ contaminating local waterwells]

• Cementing – Use Texas standards
DEP’s definition for cement sets a 24-hour compressive strength standard of at least 500 psi; however, other states, such as Texas, have found that standard insufficient to prevent vertical migration of fluids or gas behind pipe. Texas requires an additional 72-hour compressive strength standard of at least 1,200 psi across critical zones of cement.

• Cementing – Upgrade the details
Ensure better cementing by documenting the chemical composition of the mixture. Expand the “cement ticket” definition to include:

(a) a requirement for the operator to test the mixing water pH and temperature and note it on the cement ticket (this is standard industry practice and aids in determining cement quality);

(b) a record of the Waiting on Cement [WOC] time, which is the time required to achieve the calculated compressive strength standard before the casing is disturbed in any way. Allow no shortcuts.

• Protection of Water Supplies -

DEP must clarify §78.51 to explain what constitutes an adequately restored or replacement water supply for homeowners. There should be a set timeframe for acting upon a complaint filed by a landowner.

Revise §78.51(c) to read: Within 24 hours of the receipt of the investigation request, the Department will send a technical team to the field site to examine the situation and determine whether immediate action is needed to shut down operations.

• Blowout Preventer –
Blowouts are very serious work safety, and environmental situations. Blowouts may result in human injury, fire, explosion, oil spills and gas venting. Suggestion: Require all wells to be drilled with a Blow-Out Preventer once the surface casing is installed and cemented. No exceptions.


§78.72 (c) requires BOP controls to be accessible during an emergency; this is logical. However, the regulation should also require that the operator to place the BOP controls on the rig itself. BOP controls need to be accessible both on the rig and at a location a safe distance away from the drilling rig. Recent accidents show the need for this.

“Safe” = absence of risk. While it is not possible to eliminate all the risks inherent in drilling, we have to ensure that the standards are as bullet-proof as we can make them. There should be no “weasel clauses” that allow misinterpretation, no omissions, no compromises because of industry arm-twisting or whining that DEP is “unfriendly”.

Your statements are needed so the IRRC can see strong public support for the new DEP CH 78 regulations.

Remember, it is the Department of Environmental Protection.

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DEP’s proposed regulations are at:
http://www.pabulletin.com/secure/data/vol40/40-28/1248.html

DEMAND ACCOUNTABILITY!

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