Three Key Takeaways from Ground Water Protection Council's Latest Report on Oil and Gas Regulations
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- Posted on April 6, 2018
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A recent report is helping shine a spotlight on three emerging issues facing the oil and gas industry and the agencies that regulate development practices.
The triennial report, funded by a consortium of government, industry and nonprofit stakeholders including EDF, was developed by the Ground Water Protection Council, an organization of state regulators working to protect the nation’s groundwater resources. The report surveys 300+ water protection strategies from 27 state oil and gas agencies. It evaluates how those strategies have evolved over time and identifies key issues for policymakers to consider going forward.
States conduct dozens of rulemakings every year on these topics and can benefit tremendously from this technical deep dive. Just this January, Indiana finalized rules that draw on previous editions of this report, with dozens of new provisions related to well integrity and surface water management. And Indiana is not alone — one senior regulator, Stan Belieu of the Nebraska Oil and Gas Conservation Commission, commented that the GWPC report allows agencies “to be confident that the regulations they develop are in tune with the efforts other states have made to continue protecting natural resources and the environment.”
Beyond tracking continuous regulatory improvement across the states, GWPC highlights 28 “regulatory considerations” for states looking to enhance their programs, providing a close look at emerging issues that will likely demand regulatory attention in the years to come. Here are three areas worth paying attention to.
Annular pressure management and technology
Oil and gas wells are made up of concentric steel pipes – the space between these pipes is called the “annulus.” Just like regular blood pressure testing monitors a person’s heart health, annular testing looks for pressure changes to evaluate a well’s structural integrity and whether a well might be leaking.
As the GWPC report notes, annular pressure testing is already a common industry practice. In fact, it’s one of the simplest and least expensive ways to evaluate a well’s level of integrity or proneness to leak – and a leaking well can contaminate land and water or, in severe cases, cause dangerous surface blow outs.
EDF has observed a growing number of states requiring regular monitoring of annular pressures at all wells, with reporting of routine and/or abnormal results – a positive regulatory trend that seems likely to continue.
GWPC notes that new resources are available to help guide formal rulemaking on annular pressure to ensure on-going well integrity. Regulators should consider such guidelines around annular pressure testing, which are consistent with well integrity recommendations developed by EDF and Southwestern Energy, in formulating new regulatory programs on annular pressure monitoring and reporting.
Beyond regulation, the report also notes the increased use of remote sensing technologies that allow continuous monitoring of well operations, including annular pressure. This is an exciting development that we’re watching closely, as the “digital oilfield” has the potential to reduce the frequency and severity of pollution events.
New ways to store and transport produced water
The U.S. oil and gas industry is increasingly looking at ways to recycle wastewater by using it to hydraulically fracture new wells. This reduces freshwater use, but one potential side effect of reusing more produced water in the oilfield is the risk of more spills or leaks.
Produced water often contains chemicals that could be harmful to human health and the environment if exposure occurs, and the more this water is handled, the greater the chance of spills and leaks. But as GWPC notes, “proper surface fluid handling methods can significantly decrease the likelihood of environmental harm from, or human exposure to, well treatment fluids.”
Additionally, the report notes, “[p]ipelines (both permanent and temporary) must be properly designed, constructed, and operated. This includes on-going inspection and maintenance, and ultimately decommissioning when removed from service.”
It makes sense that GWPC identifies new water storage options and produced water pipelines as two of this year’s emerging issues. In both cases, GWPC notes that the advantages of both practices also come with increased spill and leak risks that can be addressed through design and operational advancements.
With oil and gas companies reporting as many as 10,000 leaks and spills each year, preventing them is a critical step toward operations that safeguard the environment.
Alternative management strategies for produced water reuse
The report also discusses emerging interest in reusing wastewater outside the oilfield. Water scarcity and limitations on disposal wells have increased interest in managing this water in new ways, including disposal via surface discharge and for other non- oil and gas uses such as irrigation and power plant cooling.
The report makes clear that in the near-term, operators and regulators should focus on supporting innovations that further recycling of produced water within the oilfield, while keeping leaks and spills from storage and transport to a minimum. This cuts both the amount of water that must be permanently disposed of, as well as the amount of local fresh water used in oilfield operations.
For reuse of produced water outside the oilfield, the report emphasizes more long-term research is needed to understand the content of produced water, treatment requirements, potential health and environmental impacts, and what data is required to enhance existing regulatory programs to protect human health and the environment.
This is an important recommendation. EDF is working to advance science to minimize the environmental and human health risks associated with produced water. GWPC itself has also launched a major effort to define the type of research that will be vital to help regulators make informed, smart decisions on the reuse of produced water outside the oilfield.
As the oil and gas industry evolves, it’s crucial that state agencies keep pace to protect our water resources. GWPC’s report paints a broad picture that shows how state oil and gas agencies have continued regulatory improvement around well integrity and water protection across the board and how they can build on it further.
By Adam Peltz
Nichole Saunders contributed to this blog post.