SB 4 Well Stimulation Treatment Regulations - Second Revised Text of Proposed Regulations

SB 4 Well Stimulation Treatment Regulations - Second Revised Text of Proposed Regulations

Thanks to everyone who made comments - in the most recent, proposed SB 4 California Well Stimulation Regulations (Second Revised Text), the language regarding risk analysis for well bores and known faults have been separated and now occupy two Sections where each is given further detail and consideration.

The frac well area analysis for geologic and known faults is now 5 times the ADSA.

The “Axial Dimensional Stimulation Area” are the estimated axial dimensions, expressed as maximum length, width, height, and azimuth, of the area(s) stimulated by a well stimulation treatment.” The image compares fracture variations on model estimates.

But... Subseismic Monitoring after the Fracturing has been changed from a threshold of “2.0 or greater” to “2.7 or greater” as measured at the CISN.

A key change in the threshold of seismic activity reporting and monitoring was recorded in the new proposed text: “the operator shall monitor the California Integrated Seismic Network for indication of an earthquake of magnitude 2.7 or greater.”

It was only after great effort and a number of cogent comments by veterans of oil field legal struggles through the years, that subseismic monitoring became part of SB 4.

Subseismic Stress Relief

Subseismic activity of magnitude 2.7 - That's the operator's reponsibility threshold. Under the 'good' neighbor notification and well monitoring protocols, the public can ascertain the timeframe of the operations and monitor the area at the CISN for changes and trends. As data is gathered per oil-field, neighborhood, or Hydrocarbon Basin, perhaps it can be mapped at DrillingMaps.com – adding to that site's already abundant and useful information.

DrillingMaps.com
http://www.drillingmaps.com/
National oil and gas drilling health and safety map. A Reference web-site.

DrillingMaps.com on Facebook
https://www.facebook.com/Drillingmaps?fref=nf
The map was inspired after listening to multiple groups of parents tell stories about sick kids and families living in close proximity to various oil and gas drilling, refining and energy operations.

The DrillingMaps blog:
http://blog.drillingmaps.com/
Very cool, snazzy looking blog that navigates quickly through a myriad of topics and a visual array of flashcards. “Crowd Sourcing Oil & Gas Health & Safety Issues”

Seismic Activity in the Vicinity of Hydraulic Fracturing

SB 4 and Seismic Activity in the Vicinity of Hydraulic Fracturing

1785.1. Monitoring and Evaluation of Seismic Activity in the Vicinity of Hydraulic
Fracturing.
(a) From commencement of hydraulic fracturing until 10 days after the end of hydraulic
fracturing, the operator shall monitor the California Integrated Seismic Network for indication of an earthquake of magnitude 2.7 or greater occurring within a radius of five times the ADSA anticipated fracture length from each point of fracture.
(b) If an earthquake of magnitude 2.7 or greater is identified under subdivision (a), then the following requirements shall apply:
(1) The operator shall immediately notify the Division and inform the division when the earthquake occurred relative to the hydraulic fracturing operations.
(2) The Division, in consultation with the operator and the California Geological Survey, will conduct an evaluation of the following:
(A) Whether there is indication of a causal connection between the hydraulic fracturing and the earthquake;
(B) Whether there is a pattern of seismic activity in the area that correlates with nearby hydraulic fracturing; and
(C) Whether the mechanical integrity of any active well within the radius specified in subdivision (a) has been compromised.
(3) No further hydraulic fracturing shall be done within the radius specified in subdivision (a) until the Division has completed the evaluation under subdivision (b)(2) and is satisfied that hydraulic fracturing within that radius does not create a heightened risk of seismic activity.

In the first two drafts, “well bores” and “geologic features and faults” were combined under

1784. Evaluation Prior to Well Stimulation Treatment Radius Area Analysis and Design.

“The well stimulation treatment area radius analysis shall include identification and a review of all well bores located completely or partially and faults (active or inactive) within two times the ADSA”

In the most recent, (dare I say final) proposed text, the Sections regarding risk analysis for well bores and faults are separate and given further detail. Notice that the area analysis for geologic and known faults is now 5 times the ADSA.

The well stimulation treatment area radius analysis shall include a review of all geologic features, including known faults (active or inactive), within five times the ADSA to ensure the geologic and hydrologic isolation of the oil and gas formation during and following well stimulation. For all such geologic features, the operator shall provide:

(A) An evaluation of whether the geologic feature may act as a migration pathway for injected fluids or displaced formation fluids; and
(B) An assessment of the risk that the well stimulation treatment will communicate with the geologic feature.
(4iii) If five times the ADSA a radius of five times the anticipated well stimulation treatment length from a point of treatment extends beyond the productive horizon being evaluated for possible well stimulation treatment, then the well stimulation treatment area radius analysis shall include a review of the geological formations adjacent to the productive horizon. The operator shall assess the mechanical rock properties, including permeability, relative hardness (using Young's Modulus), relative elasticity (using Poisson's Ratio), and other relevant characteristics of the geological formations to determine whether the geological formations will ensure the geologic and hydrologic isolation of the oil and gas formation during and following well stimulation.
(5) The well stimulation treatment area radius analysis shall include identification of all water within two times the ADSA a radius of twice the anticipated well stimulation treatment length from each point of well stimulation treatment.

Chapter 4. Development, Regulation, And Conservation Of Oil And Gas Resources
Subchapter 2. Environmental Protection

“ADSA” or “axial dimensional stimulation area” means the estimated axial dimensions, expressed as maximum length, width, height, and azimuth, of the area(s) stimulated by a well stimulation treatment.”

“The well stimulation treatment area analysis shall include identification and a review of all well bores located completely or partially within two times the ADSA to ensure the geologic and hydrologic isolation of the oil and gas formation during and following well stimulation.

STRICKEN/changed from: (a radius of twice the anticipated well stimulation treatment length from each point of well stimulation treatment)

The well stimulation treatment area analysis shall include a review of all geologic features, including known faults (active or inactive), within five times the ADSA to ensure the geologic and hydrologic isolation of the oil and gas formation during and following well stimulation.

STRICKEN/changed from: (a radius of five times the anticipated well stimulation treatment length from each point of well stimulation treatment)

(b3) Utilizing the well stimulation treatment area analysis conducted pursuant to subdivision (a), the operator shall design the well stimulation treatment so as to ensure that the well stimulation treatment fluids or hydrocarbons do not migrate and remain geologically and hydrologically isolated to the hydrocarbon formation. A well stimulation treatment shall not be designed to employ pressure exceeding 80% of the API rated minimum internal yield on any casing string in communication with the well stimulation treatment.

1784.2. Cement Evaluation Prior to Well Stimulation Treatment.

Defining well pressures: The word failure is replaced with the word breach.

“Any breach would lead to a shut-in wellbore.” There are monitoring parameters and repair s that would be attempted first. Great consideration is given to halting a producing well.

How is a breach different from a failure?

A 'well failure” implies a “breach” that has contaminated regions of geologic strata (aquifers, or surface waters by way of frac/production fluids moving through more porous strata by virtues of it's permeability to the surface, i.e., methane and fluids migration) which may include drinking water or irrigation wells, or impacted the natural world as covered by law.

Public Interest Test – The “CATCH All” Exemption

Government Code section 6255 allows public agencies to withhold records when, “on the facts of the particular case, the public interest served by nondisclosure clearly outweighs the public interest served by disclosure of the record.” As the California Supreme Court has stated: “This provision contemplates a case-by-case balancing process, with the burden of proof on the proponent of nondisclosure to demonstrate a clear overbalance on the side of confidentiality.”

The catch-all exemption, or “balancing test,” has resulted in the creation of what is known as the “deliberative process privilege.” The balancing test has also been applied or rejected in certain cases addressing particular records.

Deliberative process privilege. The “deliberative process privilege” may exempt disclosure of records revealing the deliberations of government officials or information relied upon by the officials in making decisions that they would not otherwise receive if the information were routinely disclosed. According to the California Supreme Court, which created the deliberative process privilege in 1991, “the key question in every case is whether disclosure of the materials would expose the government’s decision-making process in such a way as to discourage candid discussion with the public officials and thereby undermine the government’s ability to perform its functions.”

It is important to note that the deliberative process privilege is not an absolute bar to the disclosure of records that may reveal an official’s deliberative process. The government must also apply the “balancing test” set forth in the Public Records Act. So, records may be withheld where, in addition to exposing the decision-making process, the public interest served by nondisclosure clearly outweighs the public interest served by disclosure of the record.

Jouridictional MOUs cloud the process are only an in-house solution. It's up to us to help each other over the gaps in governance in this game-changer thrust on our democracy.

Ban Fracking And Extreme Extraction

STEAM INJECTION IS LITERALLY GLOBAL WARMING
constant comments, and informative research links;
http://banslickwaterfracking.blogspot.com/

Tomas DiFiore