And so Mr Holloway put me in his book like he promised…
And so Mr Holloway put me in his book like he promised…
I’m Jerry Lobdill. I am a chemical engineer and physicist (retired). I have been studying the technology used in drilling and completing horizontal gas wells since 2005.
I am unable to find more than a very few wells in the Barnett Shale whose production histories are consistent with even one successful refrack job.
In the gosanangelo.com piece Mr. Nicot suggested that some companies are refracking after, say, five years (quote below)
Mr. Nicot, please tell me what companies are doing this and if possible give me the API number of a refracked well.
I also ask Mr. Davis and Dr. Ireland for the same information if CHK is one of the companies that does refracking every 5-7 years, as was stated several years ago.
Please respond to this request by July 7, 2011 or send me email saying when I may expect an answer.
Thank you very much.
At 11:44 PM 6/29/2011, Kim Feil wrote:
Hello, I saw your name in an article http://m.gosanangelo.com/news/2011/jun/25/one-scarce-resource-for-another-water-151-and-of/
and was wondering if you knew of specific wells that have actually been successfully refracked?
My understanding is that every 5 to 7 years that horizontal wells need to be refracked in order to keep the 20 to 30 year promise of well production for natural gas.
In speaking with Charles E Davis, a Chesapeake employee last night, I thought he said that Chesapeake doesn’t plan on refracking their wells.
I heard that a well can be re-fracked up to ten times, but I never came across a well that has been refracked yet.
I also want to know about stacked wells (Carrizo has experience with this). Can stacked wells also be refracked? Are stacked wells more likely to have methane migration?
The water intensive fracking process is worsened by the alleged need to be refracked at a later date and with the drought conditions, I wonder just how profitable drillers can be if the price of water increases for everybody?
Thanks for at least answering my refrack question-if you have the well(s) name or lease number, that would be great.
The published regulation and specific excerpts from the regulatory text are included below for your convenience. We hope this information is helpful.
On August 16, 2012, the New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants – Oil and Gas Sector, signed last April, were published in the Federal Register. Here is the summary of today’s action, taken from the Federal Register:
This action finalizes the review of new source performance standards for the listed oil and natural gas source category. In this action the EPA revised the new source performance standards for volatile organic compounds from leaking components at onshore natural gas processing plants and new source performance standards for sulfur dioxide emissions from natural gas processing plants. The EPA also established standards for certain oil and gas operations not covered by the existing standards. In addition to the operations covered by the existing standards, the newly established standards will regulate volatile organic compound emissions from gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers and storage vessels. This action also finalizes the residual risk and technology review for the Oil and Natural Gas Production source category and the Natural Gas Transmission and Storage source category. This action includes revisions to the existing leak detection and repair requirements. In addition, the EPA has established in this action emission limits reflecting maximum achievable control technology for certain currently uncontrolled emission sources in these source categories. This action also includes modification and addition of testing and monitoring and related notification, recordkeeping and reporting requirements, as well as other minor technical revisions to the national emission standards for hazardous air pollutants. This action finalizes revisions to the regulatory provisions related to emissions during periods of startup, shutdown and malfunction.
§ 60.5375 What standards apply to gas well affected facilities?
If you are the owner or operator of a gas well affected facility, you must comply with paragraphs (a) through (f) of this section.
(a) Except as provided in paragraph (f) of this section, for each well completion operation with hydraulic fracturing begun prior to January 1, 2015, you must comply with the requirements of paragraphs (a)(3) and (4) of this section unless a more stringent state or local emission control requirement is applicable; optionally, you may comply with the requirements of paragraphs (a)(1) through (4) of this section.
For each new well completion operation with hydraulic fracturing begun on or after January 1, 2015, you must comply with the requirements in paragraphs (a)(1) through (4) of this section.
(1) For the duration of flowback, route the recovered liquids into one or more storage vessels or re-inject the recovered liquids into the well or another well, and route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into the well or another well, use the recovered gas as an on-site fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere. If this is infeasible, follow the requirements in paragraph (a)(3) of this section.
(2) All salable quality gas must be routed to the gas flow line as soon as practicable. In cases where flowback emissions cannot be directed to the flow line, you must follow the requirements in paragraph (a)(3) of this section.
(3) You must capture and direct flowback emissions to a completion combustion device, except in conditions that may result in a fire hazard or explosion, or where high heat emissions from a completion combustion device may negatively impact tundra, permafrost or waterways. Completion combustion devices must be equipped with a reliable continuous ignition source over the duration of flowback.
(4) You have a general duty to safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery.
§ 60.5430 What definitions apply to this subpart?
Reduced emissions completion means a well completion following fracturing or refracturing where gas flowback that is otherwise vented is captured, cleaned, and routed to the flow line or collection system, re-injected into the well or another well, used as an on-site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere.
This webpage includes the factsheets and summary of the requirements. http://www.epa.gov/airquality/oilandgas/actions.html
Senior Policy Advisor – Energy Issues
“I have worked in this community for 30 years and I’m very cognizant of the respiratory disease issues that will be compounded by the addition of these emissions to the atmosphere,” Blatt wrote recently in an objection letter to the West Virginia Department of Environmental Protection regarding Chesapeake Energy’s permit application to emit several air pollutants from the Dytko well pad, located along Stone Church Road.
The “potential to emit” amounts of sulfur dioxide, carbon monoxide, formaldehyde and other chemicals that may be released at the sites can vary, depending on the type of operations involved, according to legal advertisements posted by Chesapeake. In addition to the pollution from the well sites, Chesapeake also will release emissions from its local compressor stations. One of these is just off the Interstate 70 Dallas Pike exit near The Highlands, while another is in the Sand Hill area near the Marshall/Ohio County border.
Chesapeake confirmed the potential to discharge various amounts of these materials on an annual basis from their compressor operations: carbon dioxide, nitrogen oxides, carbon monoxide, methane, carbon dioxide equivalent, benzene and formaldehyde. There will also be various amounts of volatile organic compounds, particulate matter, sulfur dioxide, acetaldehyde, acrolein, ethylbenzene, methanol, n-hexane, toluene, xylenes and nitrous oxide.
“In particular, carbon monoxide of 40.28 tons per year will be produced by this well pad. This is of grave concern because the exposure to respiratory disease and creation of the ozone layer are toxic to lung disease,” Blatt continued regarding the Dytko well.
Stacey Brodak, senior director of corporate development for Chesapeake, emphasized the proposed emission levels “meet the same stringent requirements as any other facility and are within the allowable emission limits.”
“We support the role of the DEP to regulate the emissions at our facilities, including asking for and receiving public comments. We trust in the DEP’s ability to evaluate those comments and place them in the appropriate context,” she added.
Even if the emission levels fall within the DEP’s standards, Blatt said public officials need to consider the possible negative impacts.
“My major concern is for the health and welfare of the children of Stone Church Road as well as for the elderly who have chronic debilitating diseases as the result of living and working in the Ohio Valley. Exacerbation of this health crisis is, I believe, an eminent danger,” he said.
Kelly Canon to the rescue as I didn’t get the footage of my questions that only yielded one answer…that first question being “Does the budget include the $2,400 fee per gas well”? The answer by Chief Crowson was “NO we haven’t been collecting it”.
I asked if we could budget for better air emission detecting equipment for these drill sites and how for the last five years I’ve asked for a FLIR camera. I gave examples after naming off the equipment we currently use (PID’s, 4GasRae, AreaRae, and TVA) which effluents our equipment isn’t capturing like Benzene below 100 ppb, formaldehyde, possibly hydrogen cyanide, and how we don’t screen for fracking chemicals like hydrochloric acid. I asked for spectrometer equipment that speciates the effluents on the spot rather than having the air tests sent to a lab and finding out seven weeks later what the first responders and the neighborhood was breathing.
I also said we need to ramp up our semi annual testing of Lake Arlington for VOC’s and heavy metals because of 50-100 drill casing laterals under our reservoir. I commented that the LABC well control event was explosive to the underground and we don’t know if there was any damage to those casings even though that was a mile away and those laterals are about 7,000 feet deep. I said that the science isn’t settled as to how the faults and fractures may communicate with ground water supplies. To which our City Manager thanked me for the comments and moved on to the next person’s question about the budget. So I left mumbling about how my questions weren’t answered.
Maybe next year we’ll get the proper equipment?
Update I have videos at the City of Arlington council room where TCEQ held a workshop for the industry to learn how to comply with new reporting requirements. I have some footage of “pushback” like they never keep any MSS records?..The date in my archives is 10/5/12.
Almost 11 million hrs of idling trucks spewing diesel carcinogens in Barnett Shale in 2012!
“…(NCTCOG) staff estimated that on average, each truck idles for approximately six hours. Although most respondents were water haulers, an assumption was made that loading and unloading activity is consistent regardless of the type of cargo (e.g. water, rock, mud, or equipment), so this estimate of six hours per day was held constant across all phases and for all analysis years.”
And on page 34 for Tarrant county, here is the per day emissions…
And keep in mind this is just the “truck fracking traffic” related emissions…it does not include the other Barnett Shale emission sources (engines, compressors, tank flashes, etc.) during the pre and post production phases of gas drilling & compression …which include MSS emissions (maintenance, start-up & shut-down) activities….and of course can not possible include the unplanned upsets (accidents) emissions……in our Arlington airshed.
Texas Sharon says the operators have had to keep track of MSS all along and only have to give up this info in two situations..1) if exceeded the reporting threshold2) if requested via PIR (which she says she has never been able to get that info even when it was requested).For the COG to effectively help on the SIP (State Implementation Plan) for the Barnett Shale emissions, we need the whole Barnett Shale emissions picture.Will the COG please try to get the non-mobile pre & post production Barnett Shale emissions numbers …ie site set up, drilling, fracking, flowback, drillouts/getting wells into production, storage & flash tank emissions, etc.?Will the COG also try to get the maintenance emissions projections (blowdowns, methanol piping treatments, acidizing treatments, nitrogen lifts/re-stimulations etc.?If this falls into another department of the NCTCOG, please forward this email on as appropriate.The drillers can opt out of the TCEQ annual emissions inventory if they are under the emissions thresholds…
Not to be confused with the NSPS quado rules that basically say any new gas wells completed have to capture the gas……
Electronic Code of Federal Regulations View past updates to the e-CFR. Click here to learn more. e-CFR data is current as of August 12, 2015 Preview by Yahoo So my hope is that if (this NEW?) MSS reporting makes some drill sites go above the emissions thresholds, then the operators HAVE to get the PROPER Standard permit from the state (not an honor system PBR).This information will not help in those cases where two different operators are close in proximity yet their emissions are not aggregated, but maybe next legislative session someone can tackle this?With that said I hope that the TCEQ Emissions Inventory includes MSS emissions and not just post production equipment emissions. And if the NCTCOG undertakes finding out the complete emissions profiles, it would be a way to check to make sure all the operators have the proper permits. This would not duplicate the work of the TCEQ who currently uses an honor system in reporting emissions.Prime example is the Lake Arlington Compressor Station used a PBR from 2007-2009 (possibly longer prior to the PIR) before it changed ownership (a couple/few) times and was finally operating under a Standard permit….https://barnettshalehell.wordpress.com/2013/08/21/lacs-handly-compressor-station-permit-info/Thanks Chris for helping us understand the true emissions numbers for these padsites and compressor stations in our neighborhoods. Where was the NCTCOG or the State Dept. of Public Health with offering to assist in any health and environmental impact studies when Urban Drilling was being discussed?Sincerely,Kim FeilFrom: TXsharon <
To: kim feil <firstname.lastname@example.org>
Sent: Friday, August 14, 2015 4:07 PM
Subject: Re: was this a profracking stance or did I imagine that?
Operators are required to report REPORTABLE emission events to the TCEQ within 24 hours.SUBCHAPTER F: EMISSIONS EVENTS AND SCHEDULED MAINTENANCE,STARTUP, AND SHUTDOWN ACTIVITIESDIVISION 1: EMISSIONS EVENTS§101.201Effective January 5, 2006The non-reportable events are kept by the company but the code says they have to submit that information upon request from TCEQ. MSS emission reporting is not new. I don’t think they have enforced it but the industry is supposed to keep a record of all start up, shut down and emergency emission events. Some are reportable and some are not but the record keeping has been a requirement for a long time. I read your comment on the ST article.
On Fri, Aug 14, 2015 at 9:01 AM, kim feil <email@example.com> wrote:RE: maintenance startup shutdown I did find new studies but they were in California
I attended a 2012? TCEQ workshop in Arlington at city hall to help industry guys learn how to do state and federal required record keeping…I videoed some push back to the (MSS reporting?) process cause it was new… I have lots of footage of that event. I posted that on your facebook…here is my comment on that star telegram article about cutting corners …Since Chesapeake, the predominant driller in Arlington, is poised to be piece-mealed out or taken over, I’ll enjoy my biannual $20 royalty check even more if its signed by a foreign owned company…like China..(boom). California learned the hard way to become environmental savy and decades later when they started the unconventional fracking over there…you betcha 13 impressively resumed authors got together and released this document. I only read 1/3 of it and when they got to the how deep do they need to drill so it doesn’t communicate with ground water and bantered back and forth about the pathways and other moving targets like fault lines (natural and now man-made) I had to stop reading cause it only proved that we are truly guinea pigs in this whole quest for cash in our dash for gas. No wonder DicK Cheny created that Halliburton loophole with its fracking exemptions to the Clean Air & Water federal laws…”nope dat dere weren’t no accident” (no pun). But if you drink water and suck air in the Barnett Shale, you might want to read that document….https://ccst.us/publications/2014/2014wst5.pdf
So my mad dash for the camera and my respirator along with my banging heart and surging blood pressure was for naught THIS TIME. The media outlets need to be sensitive to those who live in the gaspatch and are awake to the risks….Turns out the BIG RIG they were talking about was an 18-wheeler on fire…not a drilling rig…I’m so SHALE SHOCKED.
I thought that the big rig they were talking about was on Randoll Mill Rd. Last week I snapped this pic when I took the young biologist* who interviewed me on what effluents affecting air quality were concerning to me.
UPDATE here’s the twitter pic of the BIG RIG..
Speaking of Shale Shock…..and I thought I could not see anything more shocking…..imagine living here….(this is in Mansfield TX)…*IAD-X.com air quality study info here…
*Natasha M. Kreitals Ph.D.
Thank you for the links. We are still in the lab trying to work on the technology. Our focus is primarily volatile compounds in enclosed spaces (so those that get trapped in your home). Talking to people like yourselves is helping us identify what the needs are so we can hopefully meet them. With your suggestions we will go back to the lab and work on the flexibility. So thank you for the follow up and suggestions.
Benzene, my respirator sporting mannequin that Harriet named, wasn’t yet born…..here he is at the Levitt Pavilion in Arlington….
BTW Benzene has his own Facebook page.