Unexpected Drilling Fluid Releases Via 'Lost Returns' During Horizontal Drilling Under Ohio Wetlands and Waterways in Constructing the Rover Pipeline: Operational and Regulatory Issues

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