By Ralph KisbergIn order to try and understand the repeated violations Inflection Energy has been piling up, I requested a sampling of files on wells on different pads. I found 4 types of violations: – Improper Surface Casing Depths – Failure to Submit a Well Record within 30 calendar days of cessation of drilling or altering a well – Exceeding Permitted Anticipated True Vertical Depth (TVD) – Failure to Plug an Abandoned Well If there are other violations Inflection has racked up, they weren’t found at the wells I looked at, so this may not be a complete report, just a look into some seemingly recurring issues. Improper Surface Casing Depths On 12/28/15 DEP sent Notice of Violation to Inflection for Improper Surface Casing Depths on a total of 10 wells on 6 different well pads in Eldred and Upper Fairfield Townships. The DEP found the violations while reviewing Inflection’s Well Records. The well pads are: TLC – 3 wells cited Nature Boy Costello – 1 cited ARW Hillegas – 2 Hamilton- 2 Eichenlaub- 1 Biddle Eichenlaub – 1 “During our review, the Department noted that casing was installed below or above the depth allowed by regulation, according to the depth entered for the Deepest Fresh Groundwater (DFGW)…. Based on the information provided, the surface casing strings were either installed to a depth greater than 200’ below the depth of DFGW or less than 50 feet below the DFGW or at least 50’ into consolidated rock, whichever is deeper. …. The primary objective of the regulations citied above is to prevent the migration of gas or other fluids into sources of fresh groundwater… (In 2011) the Department established a limit for surface casing installation depths of 200 feet below DFGW in an effort to prevent the occurrence of shallow gas intrusion causing defective cement… (In the case of the first 9 wells listed above) it does not appear that the wellbore was extended beyond 200 feet below the depth of DFGW in order to seat the surface casing in solid rock… (In the case of the well on the Biddle Eichenlaub pad, it does not appear that a gas show or related justification was encountered to terminate the freshwater protective casing shallower than 50 feet below the DFGW or at least 50 feet into consolidated rock, whichever is deeper. Please provide a written response within 30 days of receipt of this letter which includes:
- A written explanation of why the surface casing installation depth was extended greater than 200 feet below DFWG or shallower than 50 feet below the DFWG or at least 50 feet into consolidated rock, whichever is deeper; and
- The steps being taken to prevent the recurrence of the violations listed above.
- TLC 2H ( 081-21470) – the TVD reported on the well record ( 8,718 feet) exceeds the permitted anticipated TVD ( 8,150 feet) by 568 feet. This well is in production.
- TLC 4H (081-21472) – the TVD reported on the well record