From: MacDonald May [

Sent: Wednesday, June 04, 2014 9:25 PM

To: Stephen McNeil

Cc: Allan MacMaster; Randy Delorey; HFReview

Subject: Wheeler report Energy Well Integrity

Dear Premier McNeil,

I am writing you regarding the latest “discussion papers “ from the Wheeler Panel .We are

now a month after the closure of submissions from the public , and yet none of the information

provided by the public to the panel is included in any of their reports .As I volunteer , I have

made a submission, and responded to the “primer” and first two discussion papers . As of yet

there has been no announcement as to how the responses will be incorporated in the final

report .Dr. Wheelers introduction to the latest document appears to limit input to matters of

clarity , not correcting misinformation in the draft , or incorporating additional information into

the final report . Dr. Wheeler’s disinterest in public input was highlighted in today’s Chronicle

Herald regarding criticism from Duncan Keppie . It appears that after assembling a panel with

representation from gas industry insiders that gas industry sales brochures are regarded as

credible evidence , but public input is dismissed out of hand .

It was clear from the manner in which Dr. Wheeler structured the review and selected his

panel, that the focus of the review was to be myopic and reductionist , as opposed to holistic

and broad . The science of reductionism is the process of hiding “ death by a thousand cuts “ ,

each cut is presented in isolation of the others , and so far the panel has reports have restricted

a review of costs and risks to less than a single page . What I do find surprising is how

amazingly bad all documents have been, as Mr. Keppie said “garbage”

Yesterday Dr. Wheeler dumped two documents allowing 18 days for response . While Dr.

Wheeler and his panel are funded by the province, I am not .I have put hundreds of hours into

my submissions, and reviews of the panel documents , and it all appears to be a complete

waste of time, as Dr. Wheelers experts will dismiss all my concerns and evidence in pursuit of

what gives every appearance of a forgone conclusion .

One of the hallmarks of the reports prepared by Wheeler’s panel is that claims are

presented as facts , with no supporting reference . I quote the unsubstantiated claims of the

pro shale development panel without comment . Dr. Wheelers reports continue to be based on

false assumptions, wishful thinking and blinkered ignorance .Below are unreferenced

statements from Wheelers latest report Energy Well Integrity .In a few cases I have added a

“Note” , but in most cases not . I don’t disagree with many of the all statements , but claims

should be supported by evidence, and when conducting a review to assist government in its

decision making , there information should be referenced and supported by evidence, not “our

expert knows better than your expert”

“Technological advances are helping to reduce the incidence of leaking wells and are providing

means for better quality control and leak detection capabilities.”

“the frequency of substantial leaks is low, and the leakage rates are low as well”

“When leakage is identified, methods exist to rectify the problem. Although rigorous statistics

remain elusive, it seems that the number of problems encountered in Alberta and British

Columbia, both relatively mature regulatory environments, is not large.”

“Because possible future unconventional resource development in Nova Scotia would take place

using modern technology with multiple wellbores installed at each drilling site, it is a relatively

straightforward task to establish good monitoring and regulatory practices to ensure that the

site is geologically understood, that wells are properly installed, and that well abandonment is

done according to best practice guidelines”

“Moderate tectonic stresses and strong rock mean that wellbore quality will be excellent,

leading to high quality primary cementing operations, and therefore fewer cases of leaking

wells”

“Well construction practices have also evolved over many decades, as greater experience has

been gained in different geological conditions, and as new materials and techniques have been

developed.”

“Since the technique was first introduced in the late 1940’s, more than a million wells have

been hydraulically fractured worldwide,” NOTE this is a familiar theme in the papers produced

by Wheeler’s panel , basing safety of unconventional extraction on history of conventional

operations . The fact that the use of fractures in conventional oil and gas have not created the

problems that are ubiquitous with unconventional sources is ignored , yet despite this the report

frequently claims that there have been improvements made in well design and construction, a

statement Dr. Anthony Ingraffea PhD Rock Fracture Mechanics has ridiculed in numerous

presentations .

“In onshore Nova Scotia, large volumes of gas at depth and pressures far above hydrostatic

pressure (10-11 MPa/km) do not exist.”

“standard well designs and safety measures are sufficient to address the small risk of a

blowout.”

“The first element in creating good wellbore integrity is to make sure each casing joint is

properly connected to the previous one so that no fluid leakage can take place through the

connection.” NOTE As Dr. Ingraffea has pointed out “ It is impossible to build a well that does

not leak”

“With modern cementing practices and quality control, having to immediately repair a new

well is a rarity.”

“Also, because the production casing is not exposed to mechanical wear, wellbore integrity is

seldom an issue after the well is properly completed. ”

“Nevertheless, as discussed later, behind-the-casing gas migration continues to be an issue is a

small percentage of energy wells.” this is footnoted to a previous footnote which reads ,”9 For a

broad yet detailed discussion of various potential environmental impacts of shale gas

development in a Canadian context, refer to the following publication: Council of Canadian

Academies, 2014. Environmental Impacts of Shale Gas Extraction in Canada. Ottawa (ON): The

Expert Panel on Harnessing Science and Technology to Understand the Environmental Impacts

of Shale Gas Extraction, Council of Canadian Academies. Commissioned by the Council of

Canadian Academies for Canada Environment, May 01, 2014. The author served on this Expert

Panel, and the sections in the Report on well integrity were in large part formed by the author.”

“The tendency in the industry is to increase the number of centralizers and scratchers to assure

a better seal for the region between the casing and the rock mass”

“Once the plug hits the shoe, it opens, and the cement slurry flows out of the shoe and up and

around the casing. Once the appropriate volume of cement is mixed, a second wiper plug is

placed in the casing to displace all of the cement into the exterior annulus while wiping the

inside of the casing clean.”

“In this way, future issues relating to well integrity and risks of interaction with shallow aquifers

will be minimized”

“All these factors, plus the fact that the pressure in the productive horizon is being lowered

because of continued depletion, means that maintaining well integrity would be relatively

straightforward. Any problems will most likely be associated with seepage of gas, not oil or

saline water, because gas is buoyant”

“If loss of casing integrity is observed at any time during production, the operator must fix the

problem”

“Pathway 1 remains speculative, and compared to other pathways, can reasonably be left to

effective monitoring and regulatory controls in the context of possible onshore Nova Scotia oil

and gas development.”

“By contrast, in Nova Scotia, there are only a few abandoned legacy wells that penetrate deep

into the shale gas strata, and the locations of these wells are well-known, so the risks of fluid

migration into these wellbores during hydraulic fracturing or other production activities are

likely minimal.” Note , in the MacIsaac Point area there are numerous abandoned wells and

their locations are not known.

“Pathway 5 would be of limited concern in Nova Scotia providing that good quality assurance of

the primary cementing operation is maintained.”

“It is a standard regulatory requirement that the corporation report gas migration events”

“Once the source is located, perf-and-squeeze operations can be used to shut the pathway

above the source and greatly reduce the chances of further gas seepage.”

“Although an undesirable event from a greenhouse gas and aesthetic perspective, the impact of

methane entering potable water sources is not a serious health issue in comparison to many

other chemical contaminants.26” Note , the claim is footnoted , yet the relevance of

comparison to “other chemical contaminants” appears irrelevant. Methane is an explosive gas,

and it’s presence in domestic wells and homes are likely to have impacts aside from toxicity ,

for instance EPA warnings to people in Pennsylvania to shower and do laundry only in well

ventilated areas .

“Gas entering shallow groundwater wells may be a nuisance, including exceptionally an

explosion hazard, but other than making groundwater unpalatable in some cases, no severe

health impacts appear to have been demonstrated at this time”

“Once the commercial life of a shale gas well is over, often fifteen or more years, it must be

abandoned according to stipulated practices laid down by the regulatory body” Note there is no

evidence of any shale gas operations lasting 15 years. the average life of shale development,

according to economist Deborah Rogers is 6.5 years

“If there is any detectable surface casing vent gas flow, which occurs in perhaps 10-15% of

wellbores30” , footnote 30 reads “30 Surface casing vent flow data are registered with the

regulatory agency; therefore, there are excellent statistics available in this area, in contrast to

gas migration behind casing, where there are few data, insufficient to make strong quantitative

conclusions.”

“evidence of seepage or loss of pressure integrity between the intermediate string and the

production string, remediation must be implemented to reduce such flows to negligible values

before the well is sealed.”

“Cement bond logs, temperature logs, and noise logs may be used to identify the source of the

gas migration to guide the location of the perforating action, and the well will have to be

monitored for SCVF before abandonment. Exceptionally, several perf-and-squeeze operations

may be required to reduce seepage rates to mandated levels”

“Probably 70% of these wells have been plugged and abandoned, and although there are many

instances of gas migration, which must be fixed when noted, there do not seem to be major

environmental problems arising from the existence of these abandoned wells at this time.”

“This is not an easy statement to verify because methane seepage has not been considered by

toxicologists as an issue worthy of their attention, and this is supported by the lack of

publications in this area. Certainly, there are many areas in the world (Pennsylvania, central

Alberta) where natural seepage of methane is endemic,”

“In any case, most jurisdictions have “orphan well” funds, provided by a levy on production, that

are used to fix wells for which an owner cannot be found; otherwise, the responsibility is that

the owner fix the leaking abandoned well to the standards set by the regulatory agency.”

“Perf-and-squeeze operations are less likely to be needed in Nova Scotia, for reasons discussed

before and because general oilfield practice continues to improve. If they are, there is a

concern that in very stiff dense rocks, the high pressures needed to force the cement into the

cement-rock system will tend to wedge open natural fractures that could serve as future

pathways behind the casing.”

“Better sealing agents that can flow into small cracks and which tend to wet the surfaces of the

cracks would be more effective than cement to seal wellbores, but such materials (low viscosity

resins for example) have not been widely adopted. As in many other cases, there is insufficient

publicly available data on the efficacy of practices such as cement squeezing, and there is also

a reluctance to adopt somewhat more demanding and expensive techniques for sealing

wells.”Note, an interesting reference to industry’s endemic disinterest in wells , once they are

no longer producing.

“Better sealing agents that can flow into small cracks and which tend to wet the surfaces of the

cracks would be more effective than cement to seal wellbores, but such materials (low viscosity

resins for example) have not been widely adopted. As in many other cases, there is insufficient

publicly available data on the efficacy of practices such as cement squeezing, and there is also

a reluctance to adopt somewhat more demanding and expensive techniques for sealing wells.”

“Summery and Conclusions ,

Unconventional oil and gas development using modern well cementing and completion

techniques leads to generally good wellbore performance, but there will never be a 100%

success level in sealing all wellbores against all possibilities of future leakage. Continued

technological advances are helping to reduce the incidence of gas migration around active and

abandoned wells through improvements in cementing methods (for example more centralizers,

better denser cement formulations etc.), new materials for correcting leakage problems, better

methods for detecting poor-quality cement behind the steel casing in the hole, even better

methods of detecting slow methane seepage around old abandoned wellbores. Despite all these

advances, human error will always occur; in the case of oil and gas wellbores, the risks

associated with inadequate well integrity are not great, as shown by years of experience with

hundreds of thousands of wells in the western provinces. Nevertheless, vigilance and explicit

quality assurance practices are necessary to keep incidents of human error low, and to rectify

problems that may have arisen because of such an error.

The most important wellbore integrity problem, at least in North America and perhaps

internationally, seems to be gas seepage along the outside of casing, and this may not be a

severe environmental problem because the incidence of leaking wells can easily be reduced,