Regulatory
Citation(s):
78.83.
Surface and coal protective casing and cementing procedures.
(c) The operator shall drill to approximately
50 feet below the deepest fresh groundwater or at least 50 feet into
consolidated rock, whichever is deeper, and immediately set and permanently
cement a string of surface casing to that depth. Except as provided in subsection (f), the
surface casing may not be set more than 200 feet below the deepest fresh
groundwater except if necessary to set the casing in consolidated rock.
Question:
An operator planned to use a two-string (not
including conductor) well design with a surface string more than 200 feet below
the deepest fresh groundwater, but the new regulations require a surface casing
set depth of no more than 200 feet beyond the deepest fresh groundwater
formation, so they will change to a
three-string design (surface/intermediate/production). The operator must
order new pipe to transition to a three-string design. Regional technical staff
indicate the Department may wish to be flexible in this situation,
especially where operators have already set and cemented conductor pipe. The
diameter of the conductor essentially dictates the number/O.D. of all inner
strings. The alternative would be to have operators rip out all cemented
conductor in order to reinstall larger conductor pipe.
Response:
It is acceptable to be flexible and allow the
original well design only if the conductor pipe was cemented at the time the
regulations were finalized.