To: Dr. David Wheeler

June 20, 2014

Chair of the Nova Scotia Review of Hydraulic Fracturing Committee

From: Barbara Gallagher

Chair of Citizen Action to Protect the Environment

Dear Dr. Wheeler,

I am submitting a response to the discussion paper, Energy Well Integrity, on behalf of Citizen Action to Protect the Environment (CAPE), a Hants County-based, registered non-profit society. This particular document was of considerable interest to our group since most of our members live within the Windsor- Kennetcook Block for which a production lease had been in place prior to the moratorium on fracking.

Once again we are concerned about the bias evident in this document and the pro-gas spin that has been put on the material, while downplaying the negative aspects of the information. After noting the style of writing for the Executive Summary (ES), we wonder if it was actually written by the lead author, Dr. Dusseault, who was a co-author of the recently released (May 22/14) report, Towards a Road Map for Mitigating the Rates and Occurrences of Long-Term Wellbore Leakage (will refer to as Wellbore Leakage report).

We can’t help but question the specific criteria that were used to define “generally excellent wellbore integrity” referred to in the ES of the Energy Well Integrity (EWI) document We find that there is plenty of evidence to the contrary in the Wellbore Leakage report, in what appears to be a more evidence-based scientific document, and reports that:

“Wellbore leakage is a threat to the environment and public safety because of potential groundwater quality deterioration, contributions to greenhouse gas emissions and explosion risks if methane gas accumulates in inadequately ventilated areas.”

“Wellbore leakage will likely only become worse with time as new wells are completed and old wells are abandoned.”(p.1)

Another statement in the Executive Summary of EWI, “When leakage is identified, methods exist to rectify the problem” is misleading. Issues with remedial workovers are pointed out in the Wellbore Leakage report:

-Remedial efforts are often unsatisfactory, with success rates of less than 50%

-On average 3 interventions are required to arrest gas migration

-There are reports of remediated wellbores later developing leakage problems, with significant remedial costs, ranging from an average of $150,000/well to a high of almost $8 million (p.50)

The evidence does not support the following from EWI:

“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”(p. 7).

These specific issues were identified as needing to be addressed to improve well integrity in the Wellbore Leakage report:

_ Cementing companies recommend excellent cementing programs. However, best practices are not necessarily followed in terms of using a sufficient number of casing centralizers, use of scrapers, and providing sufficient time and casing reciprocation for full mudcake removal because of time constraints and unexpected events in the field.

_ Quality control of the cement formulation in the field is often less than perfect. Because rectification of a poor cement job is both a time-consuming nuisance and expensive, poor cement jobs may be tolerated.

_ Over the years, all kinds of additives and special formulations have been promoted by vendors. In general, these have not been widely adopted, and there is little or no third-party verification that these additives are substantially more effective in achieving a superior quality primary cement job. Without this independent verification, regulatory agencies are hampered in the development of guidelines.

_ Usually, there is no direct supervision of the cementing operations by an engineer from the cementing company who wrote the well completion program; rather, it is executed by field crews without senior technical supervision. Drilling engineers from the oil company may not be present on site to ensure adherence to work plans.

_ Cement bond logs should not be run solely with excess pressure in the casing (beyond hydrostatic) because this flexes the casing outward slightly, reducing any microannular space that may have developed and giving falsely optimistic data. Furthermore, there are no standardized and regulated methods of interpreting cement evaluation logs in a consistent manner for quality assurance.

_ The development of microannuli and fractures following wellbore completion is mainly attributed to the cement’s susceptibility to changing stress conditions and cement shrinkage. Better primary cement that does not shrink or become cracked from flexure is needed.

_ The slow development of a continuous gas path behind the casing is not well-recognized or acknowledged by the cementing companies and the oil companies. Perf-and-squeeze remediation of behind-the-casing seal failure has a poor track record, likely even poorer than has been noted in the technical literature because of persistent under-reporting of negative results.

Methods for improving the success rates and costs of well work-overs are needed. Alternative sealing materials have been suggested to overcome obstacles presented by the use of cement, however, the limitations of such sealants are unknown. Performance assessments of various sealants are required. (p 62)

The lack of mandated third-party testing of performance assessment (PA) of cement bond logging (CBL) tools is a concern. It was noted that these tools might also be run by the same company that performed the cement job.

“In the absence of such independent PA studies and third-party interpretation, the operator and the regulator must retain a healthy skepticism of the claims of commercial CBL providers.” (p. 39)

The use of enhanced recovery methods (steam injection, hydraulic fracturing, etc.) elevates the mechanical and thermal loading on wellbores, and significantly increases the probability of leakage problem development during the operational lifetime of the wellbore, before final abandonment. (p. 40)

Cornell fracking expert Anthony Ingraffea has documented that chronic leakage rates in newly fracked shale gas wells in Pennsylvania can run as high as seven per cent.

Evidence suggests that within a short period of time (decades), leakage as the result of abandonment failure will significantly increase and with it gas leakage problems. (p. 41, from Wellbore Leakage report)

This certainly adds support for Dr. Ingraffea’s famous statement that 60% of fracked wells will leak after 30 years, and eventually all of them.

John Cherry, one of North America's leading experts on groundwater contamination, who chaired the expert federal panel on the impact of fracking in Canada, has called the shale gas industry "a mess", and criticized the lack of science on the technology. He warned that no Canadian jurisdiction has set up proper monitoring to protect groundwater in areas of intense oil and gas activity. He acknowledges that hydrologists understand the freshwater zone and petroleum engineers understand the deep zone, but expresses serious concern that nobody understands the intermediate zone. “In other words, the scientific community knows little about how the repeated puncturing of the middle zone might allow methane to creep to surface or into groundwater.”

CAPE members were extremely disappointed to see this paragraph from page 17, clearly demonstrating bias, included in what we had anticipated would be a document with objectively presented facts from a panel of experts.

“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, the seepage rates are small in general, and the environmental consequences of seepage of natural gas into aquifers and into the atmosphere are not catastrophic, albeit undesirable.”

We would like scientific proof that these rates of seepage can be reduced, because the sources sited above indicate otherwise. We also believe that the evidence over time will demonstrate that the consequences of seepage of gas into aquifers are not only undesirable, but also unhealthy, and extremely costly to our communities on multiple levels.

It’s pointed out in the Wellbore Leakage report that “The short-term (20-year) impact of CH4 as a greenhouse gas is so powerful (over 60 times larger than the impact of CO2 – although CO2 is more persistent), that small amounts of methane have a disproportionate effect on greenhouse effects and short-term warming” p.15). A footnote on p. 60 notes that while in 2001, the Global Warming Potential of 23 kg CO2 per kg CH4 (IPCC, 3rd Assessment, 2001) was used,

“The more recent IPCC equivalent effects for methane over a short time period (twenty years) recommend numbers as high as 70, rather than 23, indicating that the short-term contribution of methane to the greenhouse effect is startlingly large. This is driving concern in USA in particular to reduce the magnitude of fugitive methane emissions.”

CAPE members question why the GHG effects from methane have basically been ignored in the Wheeler document.

We note that the incidence of ‘communication’ between wells is downplayed, with “ fluid migration up an offset well during hydraulic fracturing, has happened at least once in practice in Canada”p.13. Considering that individuals on the expert panel are being paid to research specific aspects of a topic, we have to conclude that they chose not to disclose that in 2010 the BC Oil & Gas Commission had already documented 18 such communications in BC and western Alberta.

We are also concerned after learning that it could be the responsibility of the owner to “ fix the leaking abandoned well to the standards set by the regulatory agency”(p. 16). We interpret this to mean that Nova Scotian taxpayers could be left with significant long-term cleanup costs if shale gas drilling occurs and isn’t profitable for the energy companies.

In Wellbore Leakage it’s explained that processes related to cement shrinkage and corrosion result in possible leakage development decades following abandonment. The authors point out that currently there is no monitoring regulation in Canada that requires operators to test wellbores for leakage following final abandonment, so in fact, leakage occurrences and rates for abandoned wells are therefore unknown (p. 59).

If changes that are made to regulations to improve the systematic monitoring of abandoned wells occur in the near future, we strongly recommend that they be tested for compliance and efficacy in other areas in Canada, before shale gas drilling is permitted in NS.

CAPE members consider the first paragraph of the Executive Summary too subjective with assumptions/statements not supported by facts. We would like to see it replaced with something supported by evidence that actually indicates that there is a definite problem with wellbore integrity, such as:

Because of the real issues associated with greenhouse gas emissions and

possible groundwater quality deterioration, we believe the more significant issue affecting the social license of the oil and gas industry is long-term wellbore integrity. (p. (i) Wellbore Leakage report).

Respectfully submitted,

Barbara Gallagher B Sc, M Ed

Chair, CAPE

Cc:

Premier Stephen McNeil

Hon. Randy Delorey

Hon. Andrew Younger

Maureen MacDonald

MLA Chuck Porter

MLA Margaret Miller