SHORTCOMINGS OF STATE WIDE RULE 13 of the RRC

This is another analysis by reader, Lionel Milberger that proves the Texas Railroad Commission provides no protection for Texas citizens. Last week, Milberger analyzed the Railroad Commission’s rule SWR 36 and detailed how that rule is not protecting the public from deadly H2S Gas.

14 May 2009
Lionel Milberger
REV = 0, 14 May 2009

SHORTCOMMINGS OF STATE WIDE RULE 13 of the RRC

1. GENERAL: Rule 13 governs the RRC’s requirements for Casing, Cementing, Drilling and Completion Requirements. This paper only includes comments relative to land oil and gas producing wells.

2. SHORTCOMMINGS:

a. Surface Casing: Although Surface Casing is required to be set below the Protection Depth, and cementing of this string is required from the shoe to the surface—cement over entire length– no cement bond log of any kind is required to show that adequate cement quality is present outside the casing. The only requirement to be reported is to show that the correct idealized volume of cement was pumped in the cementing operation.

b. Other Casing strings: Other than the above discussed Surface Casing, NO other casing strings are required in the subject wells. If the operator elects to include other casing strings (such as intermediate or production strings) then some cementing and rudimentary testing requirements are present.

c. Tubing String: Tubing is required ONLY in flowing oil wells. A packer is not required for any producing wells even if tubing is run in a gas well.

d. Tubing & Casing Connections: The rule makes NO MENTION of any requirements for, or use of, connections/couplings of any type what-so-ever.

e. Pressure Testing of Casing: The highest test pressure required is only 1,500 psi. It is not clear what fluid or gas is to be in the casing during testing, nor, does the rule specify where the test pressure is to be measured.

3. SUMMARY: There was a time when I thought that “Tubingless Completions” in the present-day high pressure, high temperature (HPHT) gas wells being drilled was very dangerous—but, after my recent studying of Rule 13, there’s no wonder it’s allowed. And it’s even worse than that, no casing (other than surface pipe) is REQUIRED! Damned tough Rule! This is just another example to prove that RRC’s Rules provide NO protection to the average citizen who lives on the land!