Unexpected Drilling Fluid Releases Via ‘Lost Returns’ During
Horizontal Drilling Under Ohio Wetlands and Waterways in Constructing the Rover
Pipeline: Operational and Regulatory Issues
When I first heard the story about the large volumes of bentonite-slurry
drilling fluid spilled I wondered how they could lose so much. The fluid was
apparently not returning to the surface through the annulus (gap on the outside
of drill pipe) as designed but leaking into the subsurface – they had lost
circulation. Bentonite is used to coat the hole and limit fluid loss.
Apparently, the ETP-Rover drilling contractors were not expecting fluid loss of
that magnitude. An important question is whether they followed best practices
and were familiar enough with Ohio regulations. Early reports of the story
suggested that they were ‘dismissive’ of Ohio EPA’s requirements and fine.
Clearly, 2 million gallons of bentonite slurry drilling fluid in a wetland
should not be dismissed lightly. Ohio EPA suggested it could take decades to
get the wetland back to its previous state. It seemed to be suggested that
ETP-Rover were claiming that as an interstate pipeline they were not subject to
Ohio laws and statutory fines but only regulated by FERC. With influence from
the Ohio EPA, FERC then told them to not begin any new horizontal drilling
until the previous releases were adequately cleaned up. FERC seemed also to be
concerned with the degree of fluid loss in one of the six locations – about 2
million gallons. They were also cited by the state for releases into a quarry near
drinking water sources and for air and storm water pollution. They were also
cited in West Virginia for sediment control failures resulting in excessive
sediment deposited in streams. In at least one case ETP/Rover opted to put
casing in a bore in order to fix hole-collapse issues.
ETP/Rover submitted a detailed list of what they would do going
forward. This was a positive development in that they acknowledged their lack
of preparation for contingencies and inadequate regulatory reporting.
Cases such as this need to be documented and analyzed to
limit and prevent future occurrences. The subsurface situation needs to be
thoroughly analyzed and understood through geology, hydrology, borehole
characteristics, cuttings samples, jointing & fracturing, and drilling
fluid properties. It also needs to be updated as new information from drilling
becomes available. In this case, apparently some of the lost returns did find
their way to the surface and into the wetlands. Regulatory protocol by the
company should be analyzed and adjusted accordingly. Regulatory agencies need
to review their protocols as well. With FERC-regulated natural gas pipelines
the pipeline company typically submits various response plans for possible
contingencies. Perhaps, a response plan for ‘lost and intermittent drilling
fluid returns’ beyond certain parameters would be useful, if not already in
place. In any case it appears there is an agreed upon and more detailed
protocol between the company and both regulatory agencies being developed. Perhaps
this will set a precedent for this issue in horizontally drilling under
waterways. Clearly lost circulation during drilling is a major issue in certain
areas. This is most problematic when close to surface and/or near groundwater
sources. Apparently, borehole collapse issues have occurred as well so that
some sort of borehole casing may be utilized. In this case it may be that the
sheer size of the pipeline (42 inches) and the larger borehole size is an
important factor.
Updated news is that Ohio EPA found diesel fluid mixed in
with the drilling mud and increased the statutory fine from $430,000 to over
$900,000. Further updates have the Ohio EPA statutory fines at $2.3 million and
ETP is balking at paying up and had apparently planned to involve Ohio’s
Attorney General. While those fines are high apparently ETP was balking at
paying the lower fines as well. Fines for spills by oil and gas companies vary
presumably with the projected costs for cleanup, remediation, and long-term monitoring.
Williams had fines in Pennsylvania related to pipeline construction that went
into the hundreds of thousands and so did upstream oil and gas companies
accumulated fines for other oil and gas spills. I don’t believe any of the
other companies balked at paying the fines. Duke Energy was leveled a $6
million fine after negotiating the fine down from $28 million then down from $6.8
million for the Dan River coal ash spill which resulted in 39,000 tons of coal
ash slurry entering the river. They also had to clean it up as they could and
provide water for those affected. Energy Transfer Partners (ETP) is mainly a
company that builds, maintains, and operates oil pipelines including the
controversial Dakota Access pipeline. Oil and natural gas pipelines have
different regulatory requirements and regulating agency jurisdictions. FERC is
a chief regulator of natural gas pipelines.
ETP also added third party independent inspectors for the last
horizontal/directional (HDD) drilling sites as a result of the new FERC
requirements. They also added an annular pressure tool to monitor pressure
changes in the annulus that might indicate fluid loss or reduced circulation.
However, in late September ETP/Rover was cited for several new violations which
put the total violations at 13. These included failure to apply for a construction
storm water general permit and for a release of soapy wastewater used for
drilling that required 6000 gallons of water to be recovered by vacuum truck
from a local waterway.
Rover Pipeline is partially in-service and is expected to be
fully in-service in early 2018. As a large diameter natural gas pipeline with
3.25 BCF/day capacity the environmental and regulatory issues should be
examined and should help in preparing for similar large pipeline construction
in the near future.
References:
Duke, regulators settle Dan River coal ash spill fine for $6M – by Robert
Walton, in Utility Dive, Sept. 28, 2016
More Rover Pipeline HDD Activities Can Resume – in Pipeline News, Oct.
23, 2017
Rover Pipeline HDD Activities Can Resume in Michigan – in Pipeline
News, Oct. 11, 2017
Ohio Regulators Cite ETP for More Rover Pipeline Violations – in Pipeline
News, Sept. 27, 2017
Ohio Increases Fines to $2.3 Million Against Pipeline Developer – in Pipeline
News, Sept. 20, 2017
Rover Pipeline Construction Stopped in West Virginia – in Pipeline
News, July 26, 2017
FERC Denies Request to Resume Rover Pipeline Drilling – in Pipeline
News, May 25, 2017
