Ohio Environmental Council, December 9, 2011
Comments to ODNR’s Division of of Oil and Gas Resources Management about the draft rules Oil and Gas Well Construction to Implement O.R.C. Sec. 1509.17.
“Our concerns take two forms. The first set of concerns are conceptual, the second set are specific to the language of the draft rules. The draft rules, as currently written, are for one static period of time, the point in time that the well is constructed.
The major problem with this approach is that it assumes that the conditions that occur at the point of construction will remain static over time. In fact, that is exactly what will NOT happen.
This newly drilled well will have to exist in a dynamic situation where conditions are always changing, for the life of the well as an oil or gas generating well and as potentially a future Class II injection well.
While these draft rules discuss construction and testing at the time of installation, they DO NOT call for ongoing testing and maintenance which will be critical if the wells are to function safely over time.
It is possible that the issues of ongoing testing and maintenance will be covered in another set of draft rules, but it is also possible that they will not be addressed at all and so, therefore, they should be commented on – and corrected by the Department – here and now.”
Click below to read OEC’s full comments.