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Chesapeake Response to EPA

Chesapeake Response to EPA

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Published by Frank Gallagher

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Published by: Frank Gallagher on Jul 14, 2011
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Chesapeake Energy CorporationRequest for Information ResponseMay 19, 2011
1
1. Legal name and address of Respondent.q
Chesapeake Energy Corporation6100 N. Western Ave.Oklahoma City, OK 73118
2. Business of the Respondent. Include the primary Standard IndustrialClassifications (SIC) and North American Industrial Classifications System(NAICS) codes.
SIC Code: 1311NAICS Code: 211111
3. Year the Respondent first owned and/or operated the Facility.
Chesapeake Energy Corporation defines the facility to be the Atgas 2Hwell with the boundaries being the area of disturbance noted in theESCGP-1 document contained in Appendix A. The Company began sitepreparation and building operations in May 2010 and began drilling theAtgas 2H well on December 27, 2010.
4. Date and state of incorporation of Respondent.
Chesapeake Energy Corporation filed articles of incorporation in the stateof Oklahoma on November 19, 1996.
5. Provide a description of the drilling operations conducted at the Facility, whenthose activities began, and if and when drilling operations were completed at theFacility.
Drilling operations commenced on December 27, 2010 and continued untilFebruary 15, 2011, at which time drilling operations were completed.Surface casing of 13 3/8” was set and cemented on December 28, 2010.Intermediate casing of 9 5/8” was set and cemented on January 4, 2011.Production casing of 5 ½” was set and cemented on February 15, 2011.
6. State at what point in the well drilling or well completion process the releaseoccurred and provide a description of the events leading up to, through andfollowing the release.
Immediately prior to the release, Chesapeake Energy Corporation wasconducting hydraulic fracturing activities through its service providerPumpco Services. Hydraulic fracturing operations began at the Atgas 2Hwell on April 18, 2011. The operations proceeded in three stages, with thethird stage beginning shortly after 9:00 p.m. on April 19, 2011.The wellhead began to leak at approximately 11:15 p.m. on April 19, 2011,during the third stage of hydraulic fracturing operations. Chesapeakeresponded promptly and prudently to the circumstances presented by theincident in order to regain control of the well and ensure public safety, andto protect the environment. NOTE: The time of the onset of the event
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Chesapeake Energy CorporationRequest for Information ResponseMay 19, 2011
2was inadvertently misstated in our April 29, 2011 submission, in responseto Question 2.
Description of actions to regain control of the well and ensure public safety 
Immediately upon onset of the leak, location personnel began work toassess and stabilize the situation and ensure safety. Notification also wasprovided to Chesapeake management and appropriate personnel weredispatched to the location, including construction personnel to assist asneeded with fluid control, drilling personnel to assist with well controlefforts, and security personnel. Well control specialists also weremobilized to the location.The first contracted well control team member arrived on site atapproximately 12:30 AM. The first responder was certified as a WellControl Supervisor by the International Association of Drilling Contractors(“IADC”). Chesapeake’s local manager, also certified by IADC as a WellControl Supervisor, arrived on site at approximately 1:03 AM. A thirdcertified Well Control Supervisor, arrived by approximately 1:15 AM.These three certified professionals constituted our well control team andled the formulation and implementation of Chesapeake’s initial responseefforts. At 8:00 AM, the three specialists were joined by an additional wellcontrol team member.In an effort to stop the wellhead release, the well control team assessedthe incident and formulated a well control plan. As part of this plan, aformulation of heavy fluid and plugging materials was designed to stemthe flow from the well. Materials required for pumping the lost circulationmaterial were being mobilized in the early hours of the incident (heavy killfluid, plugging debris). During this time, the team was designing the fluid,assembling necessary materials, mobilizing and preparing equipment, andassessing the best approach to the well to accomplish the injection.The first of the plugging attempts, implemented at approximately 6:47 AM,reduced flow only a small amount; the second attempt, implemented atapproximately 10:00 AM, reduced flow by approximately 50 percent; thethird and fourth attempts, at approximately 12:27 PM and 1:00 PM,respectively, also reduced flow. These early actions by the well controlteam were successful at reducing the release from the well byapproximately 70 percent.Prior to the fourth attempt, additional contract well control personnel(Boots and Coots) arrived on site. This team continued to carry forwardthe well control plan being implemented by the first responding controlteam by making additional plugging attempts.
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Chesapeake Energy CorporationRequest for Information ResponseMay 19, 2011
3At approximately 7:00 PM on April 20, after consultation with the wellcontrol team, and to mitigate further risk to personnel and equipment,plans were finalized to mobilize the completions crew and all non-essentialequipment off location. Equipment was removed, the primary containmentwas repaired, the location was cleared, and all ignition sources wereremoved from location. This work continued until 11:15 PM, when theLower Explosive Limit (“LEL”) monitors registered low methane levels atthe wellhead. At this time the location was cleared of personnel andequipment and secured until daylight.As a part of Emergency Response Preparedness, a general BradfordCounty Marcellus Plume analysis was created in 2009 for use in earlyincident safety risk assessments. Due to the fact that the well release wasexpected to turn primarily to gas on the evening of April 20, Chesapeakerequested Boots and Coots to undertake a site-specific plume analysis forthe location in order to assess safety precautions. This analysisaccounted for actual well conditions, weather and topographic features ofthe location. The analysis showed no danger to adjoining residentsexisted.At approximately 5:45 AM on April 21, the flow from the well turnedprimarily to gas. A single pumping unit and associated auxiliaryequipment were rigged up on April 21 to conduct a fifth plugging attempt.This was conducted at approximately 3:50 PM, and was successful instemming the well flow. Following evaluation of the need for furtheraction, a coil tubing intervention was conducted the morning of April 25,bringing the well under permanent control.
Description of actions taken to protect the environment 
Chesapeake’s design for pad construction and our spill containmentmeasures are designed to control on-site fluids, including rainwater. Insummary, the site design utilized by Chesapeake included:
 
Primary containment surrounding all fill sides of the pad
 
Upslope diversion ditches
 
Sedimentation/runoff capture ponds
 
Siltsox
 
High density plastic based bermed secondary containments
 
Two vacuum trucks on location during completion operations
The design employed at the well pad substantially reduced the fluiddischarge from the well pad during the incident. The vacuum trucksbegan collecting fluid promptly after the incident began shortly after 11:00
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