From:
MacDonald May [macdonald-may@ns.sympatico.ca]
Sent:
Friday, June 06, 2014 7:04 PM
To:
HFReview
Cc:
Stephen McNeil; Randy Delorey; Allan MacMaster
Subject:
Energy Well Integrity
Dear Dr. Wheeler ,
“Well construction practices have also evolved over many decades, as greater
experience has
been gained in different geological conditions, and as new materials and
techniques have been
developed”, Isn’t it ironic that as construction practices have improved the
natural gas industry
has never had a more negative impact on the areas it operates in ? What is
apparent is that
the new technologies used by the industry are the problem, and the solution
is to prevent the
development of shale gas industry .
“For example, the well may be held in an inactive status to conform to
agreed-upon limits
(prorated production), awaiting a decision to re-stimulate or develop another
formation
intersected by the wellbore, waiting for equipment availability, or awaiting
abandonment.” Or
waiting to be resold at inflated value to one of the big gas and oil
companies , who last year in
the USA wrote down over $14 billion between what they paid for leases and
what the leases are
worth https://www.youtube.com/watch?v=6Rs_X6uJD88.
“Well Abandonment involves making sure that the wellbore possesses integrity,
rectifying any
problems that might exist, then placement of a series of sealing plugs,
usually only within the
innermost open part of the well, to insure that there is no pathway for
fluids to migrate from
one zone to another, or to migrate up to the surface.” Except that “making
sure” doesn’t exist ,
best laid plans of mice and men. Apparently well abandonment is a huge
problem
http://www.geofirma.com/Links/Wellbore_Leakage_Study%20compressed.pdf.
“Wells drilled to access unconventional oil and gas resources are not
significantly different
from other wells used in the oil and gas industry around the world. However,
the relatively
recent developments of long horizontal wells, multi-stage hydraulic
fracturing, and multi-well
pad design are somewhat novel, compared to the old paradigm of one vertical
wellbore per
surface site, so consideration should be given to the impacts of changing
development
practices.9” It’s either “somewhat novel” or a “paradigm” shift . It is
exactly that thinking that
has led to the creation of the shale gas nightmare .The unconventional gas
industry has
consistently underestimated the negative impacts on human animal and
environmental health
from their operations by failing to recognize that having shifted the
paradigm, “we’ve been
fracking for 60 years..” is misleading .
“If this integrity is inadequate at the beginning of the process, just after
the hole is completed,
or if this integrity is breached any time during active well operation, the
operator must fix the
problem. With modern cementing practices and quality control, having to
immediately repair a
new well is a rarity .” Do the authors have evidence to support any of these
claims ? As Dr.
Dussealt points out in a recent paper “Leakage rates remain poorly quanti?ed
and remedial
workovers are often challenging. Subsequent costs attributed to remedial
workovers are often
signi?cant and present an economic strain on the industry as well as lost
pro?t, reduced
exploration and production and, therefore, foregone royalties.” As Al
Appleton says , “ No
government to my knowledge is going to be willing to tell a gas fracing
industry, ‘you have a
$15 million well here, you must stop it because you are violating something
environmental
’”https://www.youtube.com/watch?v=tGTrRQAEPs4. The evidence is clear that gas
companies
do not shut down and fix leaking wells.
“ The best guarantee against future leaky well problems is a high quality
initial well installation
(primary cementation), so attention should be paid to well casing and
cementing.” There are no
guarantees , well integrity is the result of luck . Common sense tells us
that a good job is more
likely to produce a lucky result than a bad job , but there is no guarantee .
As Dr. Anthony
Ingraffea famously stated , “ It is impossible to build a well that does not
leak , you can quote
me on that”. According to Dr. Ingraffea, 6% of new wells leak from day one
and eventually all
wells leak .
“ Although well cementing does not have to take place under direct
supervision of a
professional engineer, it is important to verify that the appropriate
materials and procedures
are used and that the installed well meets mandated performance criteria
(pressure tests, bond
log quality). In this way, future issues relating to well integrity and risks
of interaction with
shallow aquifers will be minimized”, minimized but not prevented, even if
everything humanly
possible was correctly done .Only keeping shale operations out of Nova Scotia
assures noninteraction with aquifers.
“Later in this discussion paper, the remote possibility of interwell
communication during
hydraulic fracturing is discussed, as this involves a potential impairment of
wellbore integrity”
The BC Oil and Gas Commission reports 18 cases of well communication
http://www2.gnb.ca/content/dam/gnb/Corporate/pdf/ShaleGas/en/CaseStudies.pdf
, at
distances up to 750 meters .
“Any problems will most likely be associated with seepage of gas, not oil or
saline water,
because gas is buoyant.” gas leaks faster than fluids , so gas leaks are more
common, but over
time we could see that gas escapes is a harbinger of things to come .
“If loss of casing integrity is observed at any time during production, the
operator must fix the
problem.” Who is going to make the observation, and who is going to fix the
problem ? Will we
employ the “honour system” ?
“Gas in groundwater is a widespread natural phenomenon, especially in
geological conditions
where there are deep or shallow methane sources, such as coalbeds,
intermediate depth gas
accumulations, and other organic sources . It is interesting that in the
absence of shale gas
operations this widespread phenomenon isn’t a concern .
“However, a recurring issue in well integrity assurance and development of
unconventional oil
and gas in new areas is the lack of scientific-quality baseline groundwater
data” . That isn’t a
recurring issue with well integrity, it is a recurrent issue with shale gas
developers denying
responsibility for the damage they caused by pretending it was a pre-existent
condition.
“ Often, the only data available are from local water wells which may be
tapping only one zone
or may be mixing water from several groundwater zones, or may be contaminated
by organic
matter in the well” . That is an excellent example of gas industry culture of
denial at work ,to
the industry the problem is everything but fracking .
“Once the commercial life of a shale gas well is over, often fifteen or more
years” Where is
there an unconventional shale gas well producing for fifteen years ? The
life of a shale well is
less than seven years , with production rates falling 63% annually .
“How long after abandonment will the sealed wellbore integrity be maintained?
The answer to
this question is not well-known at present” nor does it matter, eventually
all the seals will fail,
long after the gas companies are gone , long after the government of the day
is laid to rest
.Abandoned wells are ticking time bombs.
As with the other discussion papers and the primer , this paper
relies on false
assumptions, wishful thinking and conclusions not based on evidence . An
Imaginary regulatory
system , imaginary improvements in technology , and an imaginary accident
free world, are all
anticipated by the authors . While the paper acknowledges that gas leaks
from wells are
ubiquitous , it only discusses methane . VOC’s including BETX and other
hydrocarbons escape
and mix with the nitrogen oxides from pumps and exhaust, creating ground
level ozone , so the
acute health impacts of methane isn’t the issue , but the smog and known
human carcinogens
in the air around shale operations.
A recent flyover of shale development in Pennsylvania found methane
levels at 100-1000
times above EPA estimates . Shale gas development has replaced cattle as the
number one
source of methane emissions in the U.S. and as a potent greenhouse gas is of
great concern
globally.
It is shame that the discussion papers haven’t made accuracy a
priority. I had assumed
that the purpose of all the discussion papers was to establish “neutral
ground” ( ‘Just the facts
M’am’ ) to serve as a basis for discussion. It is regrettable and greatly
concerning to see that
the bias of the papers goes unnoticed by the expert panel . The discussion
papers consistently
down plays the significance of any information that might cause alarm, and
consistently
exaggerate the safety, and assumed benefit’s of shale gas development .
A “Can Do” attitude is central to oil and gas industry culture . Oil
and gas is an industry
that embraces risk, which is why drilling rigs are the most dangerous
workplaces in North
America . It isn’t that drilling is inherently more dangerous than any other
occupation, it is
simply that the industry is “risk friendly”. Failing to appreciate risk
makes every activity more
dangerous. Whatever regulations and standards established by government
agencies, the “best
practices” will be carried out by crew of “roughnecks” who work long hours at
hard dangerous
work and often use illegal drugs rather than admit to exhaustion. Regulations
designed by
people in cozy offices often are deemed unworkable and ignored by working
men.
With all due respect,
Geoffrey May
Margaree Harbour