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Steptoe & Johnson PLLC: Mechanical Integrity Assessment in Pennsylvania

By Stephen C. Smith

Well operators in Pennsylvania must inspect each operating well at least quarterly to ensure it is in compliance with the well construction and operating requirements as required by Pa. Code title 25, § 78.88. At a minimum, inspections must determine:

(1) The well-head pressure or water level measurement
(2) The open flow on the annulus of the production casing or the annulus pressure if the annulus is shut in
(3) If there is evidence of gas escaping from the well and the amount escaping, using measurement or best estimate of quantity
(4) If there is evidence of progressive corrosion, rusting or other signs of equipment deterioration

Pa. Code title 25, § 78.88(b).

The quarterly mechanical integrity testing and annual reporting regulatory obligation (more frequent reporting is required if the well is not structurally sound) became effective in 2011, but Pennsylvania Department of Environmental Protection (PA DEP) deferred enforcement of it while they developed a fairly elaborate electronic reporting format. In a “Marcellus Shale Development” Fact Sheet recently issued, the PA DEP advised that these requirements are effective “the fourth quarter of 2013” and the report is due by February 15 of the year following the inspection. The PA DEP developed a Mechanical Integrity Assessment page with links to the reports, instructions, FAQs, etc., which is available here.

Stephen Smith focuses his practice on environmental and energy-related matters including regulatory counseling and litigation, administrative law, governmental affairs and lobbying.

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