Texas Well Integrity Rule Revised

by Gray Reed & McGraw
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The Texas Railroad Commission has clarified and strengthened Rule 13, relating to requirements for drilling, putting pipe down, and cementing wells. The amendment will go into effect on January 1, 2014.

Generally, the revisions govern the casing and cementing of all wells, unlike previous versions.  Highlights are:

  • New and more precise definitions, for example, “hydraulic fracturing”.
  • Transfer from the Texas Commission of Environmental Quality (TCEQ) to the Groundwater Advisory Unit of the Oil and Gas Division of the RRC of responsibility for determining at what depth usable-quality water must be protected.
  • The authority to require a better quality of cement mixture to further protect groundwater that could be harmed by a poor casing job or the use of below-grade cement.
  • A cementing report must be filed with the RRC within 30 days of completion of a well or within 90 days of cessation of drilling, whichever is earlier.
  • Operators will be required to pressure-test well casings to the maximum pressure expected, monitor the annular space for pressure changes that could indicate a casing leak, verify the mechanical integrity of surface and intermediate casing when drilling time exceeds 360 hours, and seek prior approval before setting surface casing deeper than 3,500 ft.
  • Additional testing on wells less than 1,000 ft below usable groundwater
  • Use of air- and water-based drilling fluid until surface casing is cemented.
  • New requirements for well control measures and blowout preventers.
  • Additional cementing when an injection or disposal well is within a quarter mile.

The effect of the amendment is to more clearly outline the requirements for all wells, consolidate the requirements for well control and update the requirements for drilling, casing, cementing and fracture stimulation.

These revisions are timely, amid the debate over whether there should be  federal rules governing hydraulic fracturing.  Here is an article in Scientific American offering arguments for and against federal fracking rules.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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