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Posts Tagged ‘well stimulation’

Despite favorable environmental reviews from both the Obama and Trump Administrations, the California Coastal Commission, empowered by the Courts, voted last week to prohibit the resumption of hydraulic well stimulation at DCOR’s Platform Gilda (map above).

Of course, as is always the case offshore California, the regulatory and legal battles will continue. The Secretary of Commerce may choose to overrule the CCC, in which case further litigation is certain.

This dispute comes at a time when the CCC, which operates with extraordinary autonomy, is undergoing a performance review by Commerce. Needless to say, the Commission and its supporters are not thrilled with the oversight.

In light of the spotlight on “offshore fracking,” I wanted to draw attention to a 2019 National Academies workshop that considered this very issue. I had the opportunity to participate in this workshop and was impressed by the input from industry and govt representatives.

Key points from the workshop:

  • If wells are not completed effectively, the value of drilling is negated, and it is impossible to deliver the oil or gas production needed to make the wells economically sustainable.
  • The frac pack (as is proposed for Platform Gilda) is one of the most commonly used completion techniques worldwide.
  • A gravel pack uses sieved sand as a filter to prevent formation sand from entering the wellbore, while the frac pack combines the gravel pack with hydraulic fracturing to create wide fractures filled with sieved sand that aid in connecting the reservoir to the wellbore.
  • Frac packs can create 50- to 250-foot fractures to stimulate production in a well.
  • Well stimulation offshore, which has been in practice for decades, has far less negative impact potential than well stimulation onshore.
  • Hydraulic fracturing minimizes the number of wells needed to develop a reservoir with the result being less environmental impact potential. This completion technique allows for the development of natural resources not previously considered commercially viable.
  • Offshore California, oil and gas formations typically have low permeability, and production is dependent on natural fractures. The objective is to enhance the flow of oil and gas from the tight matrix pores into the fractures.

The workshop graphic below highlights the differences in well stimulation risks onshore vs. offshore. The graphic is a bit unfair in that the onshore risks are being effectively mitigated. The main point is that much of the onshore risk potential doesn’t exist for offshore well stimulation.

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The Supreme Court has decided to allow the 9th Circuit decision on offshore well stimulation to stand.

From a regulatory and technical standpoint, the 9th Circuit decision is highly questionable. The limited well stimulation operations offshore California were conducted 9-31 years ago and were carefully reviewed and monitored. No fluids were released or escaped to the marine environment.

During the Obama administration (and under the capable leadership of Directors Brian Salerno and Abigail Ross Hopper), BSEE and BOEM conducted a Programmatic Environmental Assessment (EA) and issued a Finding of No Significant Impact (FONSI) from the use of specific well stimulation treatments in oil and gas activities on the Pacific OCS. The 9th Circuit decided that wasn’t enough and the SCOTUS chose not to review their decision.

Given the current state of Pacific offshore operations, the court decisions will have little or no effect on well activity now or in the foreseeable future. If the BSEE well permitting site is up-to-date, there have been no Pacific well operations in the past 3 years. For the 2 years prior to that, the only well operations were for plugging and abandonment purposes. Therefore, the main concerns are the decision to require an EIS prior to any future well stimulation operations, and perhaps more importantly, the implications of the decision on offshore operations elsewhere.

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A full EIS is needed!

Further to the summary from the 2016 EA announcement, it appears that the only Pacific Region well operations over the past 2 years have been for plugging and abandonment purposes. The legal circus continues with or without actual operations.

There have been 24 well stimulation treatments (21 of which involved hydraulic fracturing) on the OCS offshore California between 1982 and 2014, and these were conducted on four of the 23 platforms. Reservoirs on the OCS off Southern California tend to be much more permeable than onshore reservoirs, and are already highly naturally fractured. Therefore, little permeability enhancement has been required for their development. As described in the scenario evaluated in the EA, the future use of Well Stimulation Treatments is expected to continue to be occasional rather than essential to hydrocarbon production from these platforms.

BOEM, 2016

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