Some frack addicts are exploiting a loophole in the state drilling regulations; which appears to allow a well to be fracked with napalm. What they are not thinking about is the environmental hurdles; namely how many pizzas they are going to have to buy for the survivors.
Horizontal wells are permitted in New York state. In the Town of Barton, there were three horizontal well drilled into Black River, but not fracked, by Talisman back in 2007. All were dry and are now plugged.
Fracks under 300K gallons are permitted / not prohibited. So, if the horizontal well involved less than 300K gallons of fluid, it could be permitted under the drilling regulations of the state. Accordingly a straw-man operator has filed two LPG frack permits in Tioga County, one for a vertical test well, the other for a horizontal completion.
However, in order to be permitted, the wells have to get environmental approvals. Such an experimental, proprietary technology is not anticipated by the generic environmental regulations, the 1992 GEIS or SGEIS, and would therefore be subject to a site specific environmental review – which it would fail.
The reason propane was used is that it can transport the frack sand etc. in a liquid form – then in theory recycle some of it when returned to the surface as a gas, then re-compressed to a liquid and re-doped with frack sand, repeat on each stage of the completion. So 300K gallons X 10 repeats = 3 M gallons cumulative – in theory. Unfortunately, that’s not what actually happened in practice, which is one reason GasFrac went out of business. It’s hard to recapture the propane (and separate it from produced methane) on the well site, particularly when the well explodes.
Water can be recycled too – but much of it is lost, and can be slow to remove from the formation. So it would be tough to frack each stage of a long lateral within the 300K gallon limit – it would take weeks/months, and your last frack would be down to say 50K gallons net of the 300K you started with. Time is money over a hole, and trying to stretch 300K gallons via recycling over a long lateral would be pricey if not hydrologically impossible. Hence the LPG technology – intended for xeric environments.
The 300,000 gallon limit was derived from industry suggestions made prior to the invention of HVHF technology. This loophole could be closed by either limiting the amount of fluid used on all stages of completion to say 50,000 gallons, or specifically prohibit any fluid other than water as the transport medium.
Meanwhile, would continue to put pressure on the DEC to close loopholes, since this is, in fact a loophole – at least in the drilling (if not the environmental regs) despite the fact that the well permits being used to flag it (thanks frackers !) are evidently publicity stunts aimed at proving that there is a loophole (thanks again, gasholes).
Meanwhile, this PR stunt gets attention from both sides of the Frack Wars. In early July, a handful of farmers formed “The Snyder Farm Group” and filed an application with the NY State Department of Environmental Conservation (DEC) for a permit to fracture shale using gelled propane. It’s not high volume hydraulic fracturing, said their lawyer, whose office is listed as the HQ of Tioga Energy – “so the DEC should be able to allow it under the 1992 Generic Environmental Impact Statement (written before gas-fracking was invented).”
About a month later, the Tioga County legislature adopted a resolution supporting the Snyder Farm group’s efforts to frack with gas. Soon after that this same resolution began showing up on the agenda of Tioga County towns, including Candor. On Aug 11, Snyder Farm Group spokesman Kevin “Cub” Frisbie called Candor town supervisor Bob Riggs and asked the town to support the same resolution (he emailed the resolution later that same day). That very night, the town board considered the resolution, with Riggs stating (incorrectly), “By current law this is all approved and they’re just asking the surrounding municipalities to endorse that.”
No, LPG fracks are not “approved.” They don’t even exist, except as a fracking fairy tale.
Note that GasFrac is on the original application, but since GasFrac no longer exists, and “Tioga Energy Partners” is an Albany attorney, not an operating company, this begs some questions:
1. Which contractor is going to frack it ?
The short answer is not Gas Frac. STEP bought the remains of GasFrac, and decided to mothball the highly specialized equipment. Including the robots trained to actually run the frack. That leaves… no contractor qualified to even attempt it.
The DEC routinely permits gaseous fracks – nitrogen is used on test fracks. Since there is no licensing in NYS for frack contractors, no certification, no routine OSHA oversight, etc. anybody could show up with enough propane to frack the well. Then call Dominos.
The contact person on the application is Todd Bellar, who, per LinkedIn, is Vice President Marketing- Appalachia Patterson-UTI Drilling Company LLC, of Eighty Four, PA, down in SW PA, around Washington PA. Info about Patterson, a drilling contractor is here: Patterson UTI. No indication that Patterson/ Universal has ever fracked a well with propane, or can do so with GasFrac’s proprietary technology. But, if their crews like pizza, there’s always a first time.
The attorney/ “Tioga Energy” have replaced a non-existent napalm fracker with a fracker that has never fracked with napalm. Makes sense right ? For a fracking hoax.
2. Is the proposed lateral long enough to be commercial ?
Depending on the formation/ depth, etc. the lateral would have to be approximately as long as comparable producing wells in that formation/ depth etc. Which would be hundreds if not thousands of feet.
3. If 2 is “maybe” or “yes” then who is going to pay for it ?
The listed operator is a straw man. To complete and produce a commercial horizontal LPG well, some bone fide operator is going to show up with several million dollars.
4. Before 1,2,3 happen, the vertical well test has to show significant potential.
That seems very unlikely in the Marcellus at current gas prices, and fairly iffy in the Utica. From what we know, the Utica produces dry gas in a pocket of productivity on the Pa. side of the border. So this would be a wildcat for the Utica, and a low probability well for the Marcellus.
What this all underscores is that, in “banning fracking” the DEC focused on what they said they were focused on (and that we were focused on) high volume water fracks, not this rather quixotic loophole.
5. Just how many pizzas are we talking about here ?
Since the DEC has approved gaseous fracks – such as nitrogen – for tests, and since there is no licensing, certification of fracking service companies, crews or methodologies, they may see this LPG frack as within the scope of their fracking regulations – leaving the question of an environmental review, which would have to be flagged and challenged.
It would be a unique SEQRA, since the panel would have to estimate how many people would be blown up, how many barns leveled, cows fried, fish poisoned, and pizzas required for the survivors. Color me skeptical – that this is anything other than a PR stunt – like the fairy tale “secession” of FrackLand from NYS.
Status of permit applications:
The DEC could approve the vertical stratigraphic well Snyder E-1 at any time. Application was accepted last May. I heard that the only thing stopping them is that the operator, Tioga Energy Partners, has linked the two application. A stratigraphic test well is non-producing.
According to the well database, DEC has yet to accept as complete the application for horizontal Snyder E-1A, even though they accepted the check back in May. (This propane frac is a hot potato for DEC.) While the 1A could produce if they find enough gas, there is no gathering line and compressor station to service it.
Even with permits in hand, they can’t spud before someone puts-up the million to drill and frack. Because a permit is good for only six month, there is no rush to get the applications approved until the finances are in place.
Brian’s notes on the foiled well permit applications:
For the vertical E-1 (stratigraphic), bottom is 9,530′ — probably the top of the Black River Fm. This is that same depth as on the DEC Oil & Gas Database.
For the horizontal E-1A (production?), the top of the target Marcellus is 3,975′ on the application, the length of the lateral leg is 3,151′, and the length of the hole is given as 6,605′. Here Utica is 9,500 to 10,000′.
The application fee is based on the depth drilled. For the vertical well E-1, $3,900 was paid (4/30), but for the horizontal well E-1A only $1,620 was paid (5/27). The application fee for E-1A is cited as $2,760 in the Certification, which sounds closer to the mark. Did DMN have a half-price sale on applications that day?
The second page is missing from both applications. The comments section there usually has details of casing requirements. Says something about how DMN regulates that the casing requirements are an afterthought for the comments section rather than a fill-in-the-blank part that makes sure all data are entered.
The site plat and spacing (4/15) and the Submission Certification (applied 4/22) are for the E-1A . Those for the E-1 are missing, but presumably those documents predate the receipt of 4/30.
The site inspection (6/22) is for the vertical E-1, but that for horizontal E-1A is missing, although presumably it would be identical. It was done by Joseph (Joe) Yarosz, Mineral Resource Specialist, Phone: (607) 739-0809
In the DEC well database, the vertical E-1 application is dated 5/19, three weeks after receipt of fee. The application for the horizontal E-1A is not recorded, despite the application fee having been accepted 5/27.
There is a cover for a Frac Proposal from GasFrac (3/28) but the rest is missing.
If these nine pages are the complete response to TT’s FOIL for Snyder E-1 and E-1A, then there are a lot of pages missing.”