On January 29, 2013, the Texas Railroad Commission (“Commission”) withdrew previously proposed amendments to §3.13, relating to casing, cementing, drilling and completion requirements; §3.99 relating to Cathodic Protection Wells; and §3.100 relating to Seismic Holes and Core Holes. The proposed amendments are technical and should be reviewed for impacts on current drilling activities. Given the importance of these new amendments, the Commission voted to set the comment period for 45 days. Comments will be due by noon on April 1, 2013.
Some of the Commission’s key proposed amendments are:
Potential Flow Zone. A new term to address those zones that can cause bradenhead pressure in an annulus when the zone is not isolated.
Cement Sheath Thickness. Lowering the wellbore requirement to at least 1.5 inches greater than the nominal outside diameter of the casing.
Casing. A requirement that casing be cemented across and extending above all formations permitted for injection or disposal within 1/4 mile radius of the well to be drilled; and that casing be required for productive zones, potential flow zones, and zones with corrosive formation fluids.
Casing. Allowing the use of calculation, temperature survey, or a cement evaluation tool to determine the top of cement.
Surface Casing Evaluation. Allowing verification of casing integrity through a casing-evaluation tool instead of a mechanical-integrity test.
HFT. A requirement that a mechanical-integrity test be conducted before beginning hydraulic fracturing treatments and monitor all annuli on a well during treatment.
New Notice Requirements. Notification to and approval by the district director before setting surface casing deeper than 3,500 feet.
Testing of Blowout Prevention Equipment. Required testing of Ram-type equipment before drilling the plug on the surface casing and before encountering any high-pressure formations.
Drilling Fluid Program. A program to provide detail on the characteristics, use, and testing of drilling fluid.
The proposed amendments are attached. If you have any questions regarding commenting on the proposed amendments, please contact any of the lawyers listed above.