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The informational session held on April 28, 2022, by DEP Oil and Gas Management Team to provide participating stakeholders, local government officials, academic institutions and commonwealth citizens with information relating to the Infrastructure Investment Jobs Act and the commonwealth’s projected plans to plug orphan and abandoned oil and gas wells, its needs, timelines and vendor protocols is now available online.
Funding may become available to advance DEP's efforts to plug orphan and abandoned wells in Pennsylvania. For that reason, DEP would greatly appreciate that your firm completes its registration survey. The survey will assist DEP in assessing your interest, availability and ability to perform plugging and plugging support work. Click here to take the survey.
The training held on March 10, 2022, by DEP Central Office staff to provide participating oil and gas industry professionals and other attendees with information relating to a number of DEP Oil and Gas forms is now available online.
On February 9, 2022, Bureau of Oil and Gas Planning and Program Management posted an E&S Plan Template for Well Plugging Activities in DEP’s eLibrary (8000-FM-OOGM0007). The new document was designed for earth disturbances associated with well plugging activities that require the development and implementation of a written E&S Plan but do not require an Erosion and Sediment Control Permit (E&S Permit). The form is designed to guide operators in the development of an E&S plan that is specific to their project. Properly completing the form, making it available at the project site and implementing its contents will demonstrate compliance with the 25 Pa. Code Chapter 102 requirements.
The Departments of Environmental Protection (DEP) and Conservation and Natural Resources (DCNR) have completed the first phase of well plugging work. This was the first phase of a four-phase project in Cornplanter State Forest, Forest County. The work included plugging 12 abandoned oil and gas wells. The 12 wells, some of which are believed to have been in the forest since the 1920s, are located in Harmony Township. Final site restoration of these wells will be performed during the Spring of 2022. Phase two of well plugging will also be released for bid in the Spring/Summer.
Old, decaying abandoned wells not only act as a significant source of climate-warming methane emissions, but in many cases, can leak oil and gas into water, soil and sometimes nearby homes, creating an explosion hazard.
Benefits associated with the Cornplanter project include:
- Conservation of approximately 1,260 acres of state forest land;
- Protection of cold-water fisheries that include Hunter Run, McCaferdy Run, Jamison Run, and Dawson Run;
- Reduction in methane emissions to the atmosphere;
- Protection of public trail users and valuable recreation areas including Hunter Run Trail System and Lashure Interpretive Trail;
- Increased opportunities for forest management; and
- Increased availability of public lands for healthy, outdoor recreation without risk of injury.
DCNR provided funding to the DEP Well Plugging Program to manage contracts to properly plug abandoned wells where no responsible party can be identified. DCNR bid the project and is responsible for overall project management and contract oversight, while DEP provided the technical specifications for the contract documents and also is providing on-site inspection services of the work. DCNR awarded the contract to Howard Drilling, LLC, of Mount Jewett, PA on January 4, 2021, and plugging work commenced on March 29, 2021. There are more than 1,735 known oil and gas wells on public lands that have no responsible owner and are eligible to be plugged under DEP’s Well Plugging Program. Statewide, there are more than 8,700 abandoned wells in Pennsylvania, but it is estimated that there are an additional 200,000 abandoned wells across the state.
Order of the Commonwealth Court of Pennsylvania dated January 6, 2021 in Marcellus Shale Coalition v. Department of Environmental Protection of the Commonwealth of Pennsylvania and Environmental Quality Board of the Commonwealth of Pennsylvania, Docket No. 573 MD 2016
– The Department provides notice of the January 6, 2021 Order of the Commonwealth Court of Pennsylvania (Order), which clarifies the compliance deadlines in 25 Pa. Code § 78a.59c(a) (relating to centralized impoundments). The Commonwealth Court issued its Order in response to a Joint Application for Relief Requesting Clarification of the Compliance Deadlines in 25 Pa. Code § 78a.59c(a) filed by the Department, the Environmental Quality Board, and the Marcellus Shale Coalition in the case of Marcellus Shale Coalition v. Department of Environmental Protection of the Commonwealth of Pennsylvania and Environmental Quality Board of the Commonwealth of Pennsylvania, Commonwealth Court Docket No. 573 MD 2016. The Commonwealth Court’s Order directs the Department to publicize the Order in the Pennsylvania Bulletin; notifying the regulated community and public of the correct compliance dates. The Commonwealth Court’s Order extends the April 8, 2017 deadline from 25 Pa. Code § 78a.59c(a) to Monday, June 7, 2021 and extends the October 8, 2019 deadline to Monday, January 8, 2024. Click here to view the January 30, 2021, issue of the Pennsylvania Bulletin.
DEP has recently completed a comprehensive analysis of both regulatory requirements and an industry standards document updated in December 2018 relating to blowout preventer (BOP) function and pressure testing (American Petroleum Institute (API) Standard 53, Well Control Equipment Systems for Drilling Wells). In response to the analysis, the agency has rewritten a frequently asked questions (FAQ) document to align it with the current, best technical thinking associated with effective BOP testing measures. BOP equipment provides a last line of defense when an operator runs the risk of losing control of a well (uncontrolled flow of pressurized gas and liquids toward the surface).
The updated FAQ establishes that following the referenced API guidelines for both function and pressure testing, as written, are acceptable and provide superior safety measures. More specifically, the API guidelines provide consistent, system-wide testing procedures during BOP set-up, use, and transition to nearby wells on a multi-well pad. Further, the guidelines provide specific procedural steps that ensure comprehensive function and pressure testing at test intervals that have been fully vetted.
With the release of this FAQ, DEP has clarified that following API Standard 53 is consistent with the intent of the 2011 rulemaking language associated with 78a.72/78.72 (e) and (f), and would be in compliance with DEP’s regulations. The updated FAQ provides a transparent and clear mechanism for an operator to pursue a contemporary, superior BOP testing procedure, as allowed by the referenced regulations. In cases where an operator is proposing a method not consistent with the FAQ or the section 78a.72/78.72 testing requirements, DEP has also developed a new form, 8000-FM-OOGM0017, that can be used to document requests for DEP review and approval associated with modified BOP testing procedures. All of these new resources are available for reference and implementation, effective immediately.
On June 18, 2020, IRRC unanimously approved (5 members in favor, no members opposed) the DEP final form rulemaking to increase the unconventional well drilling permit fee.
Learn more about the Final Form Rulemaking.
DEP recently received a request regarding the use of newly formulated Class L cement in the construction and plugging of oil and gas wells. Joppa Class L cement is a low CO2 (lower environmental impact) oil well cement designed for normal slurry applications for cementing oil and gas wells. In 2019, the American Petroleum Institute (API) added the Class L designation to Annex B of Specification 10A. Class L composite well cement is manufactured by inter-grinding Portland cement clinker and one or more forms of gypsum with pozzolanic material. Fly ash, silica fume, and natural pozzolans all qualify as pozzolanic materials. API also allows the addition of suspension agents in Class L cements. The API Monogram is pending.
After review of available laboratory testing data, DEP has determined that the Class L blend of cement “meets or exceeds the ASTM International C 150, Type I, II or III Standard or API Specification 10” and also meets requirements of Section 78.85(a)(1)-(5) and 78a.85(a)(1)-(5) when used in accordance with the manufacturer’s specifications and standards for well cementing. This determination has been made based on a detailed review of laboratory testing data for the blend and comparison of laboratory performance to Class A blends. Accordingly, operators may use the Class L blend to meet the requirements of Sections 78.85 and 78a.85. This determination applies for use in Pennsylvania at any oil and gas well sites, either previously permitted, in the process of permitting or at future permitted wells.
See Deputy Secretary Perry’s memo for details.