Dear RDA Members and Friends, In addition to discussions about Act 13 requirements for plugging gas wells, existing abandoned and orphaned gas wells have also been in the news lately. To gain an understanding of scope and seriousness of this situation, we invite you to visit the Save Our Streams PA web site, and consider becoming a member of this organization, based in Potter County. From the site: Pennsylvania is home to thousands of orphan, abandoned, un-plugged and lost oil and gas wells. With the increase in natural gas drilling and horizontal hydrofracturing, the risks posed by lost, orphan and abandoned wells are growing. Our mission is: To locate, promote awareness, adoption and plugging of lost, abandoned and orphan wells. To call upon the landowners , industry, developers and our government to recognize the hazards posed by these wells and to plug them adequately. According to the DEP, there are records on just over 140,500 of the estimated 325,000 oil and gas wells drilled in Pennsylvania since 1859. Of these recorded, approximately 88,300 are operating wells with known owners who are responsible for plugging them when they reach the end of their useful life. There are 44,700 wells known to be plugged. The remainder are wells considered to be orphans. Many abandoned, unplugged wells are lost.
Orphan, abandoned, unplugged, or improperly plugged wells may and often do act as a conduit, or pathway, allowing methane or other fluids to travel between formations to aquifers or the surface.
These wells have the potential to contaminate Pennsylvania's forests, streams, and groundwater. For images of what abandoned wells look like, and visual evidence of their potential for serious harm, see these videos provided by Save Our Streams PA:
http://www.youtube.com/watch?v=1LcnqpbQuHA http://www.youtube.com/watch?v=ytQ08PawhIY&feature=related An interview on the radio program Allegheny Front, "Department of Energy Takes Orphan Well Search to New Heights", aired on April 28th. Interviewer Kate Malongowski spoke with two guests: Shane Seddon of Fugro Airborne Surveys, hired by the Department of Energy to look for abandoned wells in a few square miles of Washington County, and Rick Hammack with the National Energy Technology Lab. Here's an excerpt from Hammack: An abandoned well provides a conduit... These gases could be, of course, methane, natural gas, or something like radon. If wells aren't known, if you build a house over the top of a well that's not sealed, the well itself can provide a conduit for radon to come up and invade the basement. Certainly, Pennsylvania has a long experience with houses that have exploded because of gases that have accumulated in peoples' basements and have ignited. So it's a real problem here in Pennsylvania. A transcript of the show is available here: http://www.alleghenyfront.org/transcript.html?storyid=201204261347150.513401 In Act 13, well plugging requirements are found in section 3220, and section 3225 concerns bonding. If anyone out there can decipher the language in these portions of the law, please enlighten us. In a letter to the Williamsport Guardian to be published in the June/July Issue, the Governor's Energy Executive Patrick Henderson states that, " ( under Act 13 PA now has) ... among the highest well bonding amounts in the entire nation, up to a total of $850,000". In the Act, it seems a bond is must cover "...water supply replacement, restoration and plugging requirements...". There are varying amounts mentioned based on the number of wells drilled and well bore length. At the last meeting of the Sullivan County Energy Task Force, representatives from O-Tex Pumping graciously shared an overview of their work, held a very open and honest Q and A session, and gave a tour of their facility near Laporte. O-Tex's only business is cement work on well casings and well plugging. When asked what is the average current cost to plug a well here in PA, their answer was around $30,000. Reading Act 13 it appears the bonding requirement, essentially, is $4,000 dollars per well under 6,000' long horizontally and $10,000 for wells greater than 6,000' horizontally, with a small one-time fixed fee that increases in increments with the number or wells an operator drills. Other caveats include the EQB's ability to adjust the amounts every two years and a "no bond may be required in this clause in excess of" limit that varies, but at the low end is $35,000 for an operator of less than 50 wells. One other thing to keep in mind, once a well is plugged doesn't mean it will stay plugged forever. Cement shrinks over time and the earth moves. Who is going to pay for re-plugging in future centuries? Frankly, it is all confusing. Is there a provision in the Act to force drillers to seek out, "adopt" and plug old abandoned and orphaned wells in their drilling units, as NY supposedly will include if it ever makes a decision to allow shale-gas drilling? Maybe Mr. Henderson, who is rumored to at least occasionally look at these newsletters, would be willing to enlighten us on these very specific issues of well bonding and plugging requirements? If anyone of you out there has a better understanding of this portion of the law, please let us know. There will be rulemaking comment periods associated with Act 13. Some have already come and gone. It is difficult to keep up with them when so many appear from different agencies and also different levels of government. Industry does a good job of looking out for their interests via that process; we do not. And frankly, for a newsletter that goes out to well over 1,000 people, very few have the time or feel they have a good enough grasp of the issues to comment. We try not to overwhelm you with requests to comment, but if we catch the opportunity to do so on well plugging, we will ask. We could use help in following the PA Bulletin and finding out when comment periods are open. Any volunteers? (If so, kindly reply by email) For those of you who would like to get involved in the well plugging issue in a much more fun way, there is another option from our friends at Save Our Streams PA. On Nov. 1st, 2011, they kicked off a "Scavenger Hunt" program for locating lost, orphan and abandoned wells. It is basically like a geocache game, but with an important outcome, as the end game is to photograph and GPS locations of these wells. A great way to get the kids and grandkids out in the woods doing something fun and helpful. See the website www.saveoursteams.org for details.
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