Marcellus Shale Environmental Advisory
Under the new regulations, the Control and Disposal Plan required for each well site must include a pressure barrier policy identifying those pressure barriers to be used. The plan must also contain a list of emergency contact phone numbers which are required to be posted at the well site during drilling, completion or alteration of the well.
Blowout prevention equipment is now required for drilling in any "unconventional formation" (e.g., Marcellus Shale). Additional controls for blowout preventors are required, and an inspector certified by the Independent Association of Drilling Contractors or other approved organization must be present when blowout prevention equipment is installed or when its use is required.
Production reporting requirements were modified to require Marcellus Shale gas wells to submit to the DEP a bi-annual production and status report for each well. The reports must be submitted electronically.
Regarding well record and completion of report requirements, the rules added a new requirement for a certification by the operator that the well has been constructed in accordance with the regulation and any applicable permit conditions. Additional records regarding the chemical constituents and quantity of the stimulation fluids used must be submitted. There is, however, a provision which allows the well operator to designate portions of the stimulation record as containing trade secret or confidential/proprietary information, which the Department would then be required to hold confidential, subject only to the requirements of the Pennsylvania Right-to-Know Law.
Marcellus Shale gas well operators should carefully review the new regulations and be prepared to implement these extensive and detailed new requirements.
The full text of the new 25 Pa. Code Chapter 78 regulations are available here.
Blowout prevention equipment is now required for drilling in any "unconventional formation" (e.g., Marcellus Shale). Additional controls for blowout preventors are required, and an inspector certified by the Independent Association of Drilling Contractors or other approved organization must be present when blowout prevention equipment is installed or when its use is required.
Production reporting requirements were modified to require Marcellus Shale gas wells to submit to the DEP a bi-annual production and status report for each well. The reports must be submitted electronically.
Regarding well record and completion of report requirements, the rules added a new requirement for a certification by the operator that the well has been constructed in accordance with the regulation and any applicable permit conditions. Additional records regarding the chemical constituents and quantity of the stimulation fluids used must be submitted. There is, however, a provision which allows the well operator to designate portions of the stimulation record as containing trade secret or confidential/proprietary information, which the Department would then be required to hold confidential, subject only to the requirements of the Pennsylvania Right-to-Know Law.
Marcellus Shale gas well operators should carefully review the new regulations and be prepared to implement these extensive and detailed new requirements.
The full text of the new 25 Pa. Code Chapter 78 regulations are available here.
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