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Drilling Completions and Pre-Production Activity

New Regulations on Oil & Gas Activity

A Colorado state commission has approved a rule that will require companies to monitor emissions from oil and gas sites earlier and more frequently then is currently done as Colorado officials implement a law overhauling how the industry is regulated. The Colorado Air Quality Control Commission voted unanimously for a rule to track emissions from the start of construction of a well and over the first six months of production. The monitoring of so-called preproduction, a phase that can produce high emissions of chemicals and health complaints from the public, is a new requirement.

The proposal is part of the implementation of Senate Bill 181. The 2019 law changed the state’s mission from fostering oil and gas development to regulating it in a way that protects public health, safety and the environment. The monitoring rule, thought to be the first of its kind in the country, builds on changes the Air Quality Control Commission made in December to require more frequent inspections of oil and gas equipment statewide. Companies will have to start monitoring programs for new wells starting May 1, 2021.

Colorado’s Air Quality Control Commission (AQCC) adopted new rules to reduce harmful air and climate pollution from oil and gas operations across the state. Once in effect, the rules will require high-frequency monitoring for gas leaks starting when construction on a well begins and continuing through the first six months of production, a period of time not addressed by other monitoring standards. The rules will also close emission loopholes in current federal standards by prohibiting natural gas venting during the early period of well completion. As other states seek to address pollution from the initial stages of oil and gas development, this move demonstrates the most comprehensive measures yet taken.

“In 2014, Colorado became the first state in the nation to tackle methane emissions during the production of oil and gas from wells across the state. Today, the AQCC continued that leadership by extending monitoring requirements to the pre-production phase and by prohibiting natural gas venting during completions when drilling activities can result in significant emissions of methane and other dangerous pollutants. These new rules mark continued progress in reducing the climate and health impacts of oil and gas operations in the state.”
Jon Goldstein, Director of Regulatory and Legislative Affairs, Energy, EDF, September 23, 2020

What the Colorado state air pollution control division calls “high-frequency” monitoring will start with well construction and continue through drilling, hydraulic fracturing and what’s called flow back, which is when groundwater and fluids used in fracking are brought to the surface and disposed of. Companies will have to get their monitoring plans approved by the state division.

Pollutants that will be monitored include methane, a potent greenhouse gas; benzene, known to cause cancer; and other chemicals that form ground-level ozone. The ozone pollution levels in several counties along the Front Range exceed federal standards.

How Is Well Construction, Drilling and Hydraulic Fracturing Being Monitored?

An optimal drilling operation requires close control over a number of parameters. Even though the drilling program may have recommendations related to drilling parameters, it is mandatory that rig personnel (e.g., driller, drilling supervisor, drilling and mud engineer) keep track of the operation development at all times in order to make necessary adjustments and to quickly detect and correct drilling problems.

A modern rig will have devices that display and simultaneously record most of the important parameters related to the drilling operation. Parameters that cannot be determined automatically, such as mud properties, will be measured, recorded, and controlled constantly as well. Some of the most important parameters include:

• Well depth
• Weight on bit
• Rotary speed
• Rotary torque
• Pump pressure
• Pump rate
• Fluid-flow rate
• Flow return
• Rate of penetration
• Hookload
• Fluid properties (e.g., density, temperature, viscosity, gas and sand content, salinity, solids content)
• Pit level

What Is Hydraulic Fracturing?

Hydraulic fracturing, informally referred to as “fracking,” is an oil and gas well development process that typically involves injecting water, sand, and chemicals under high pressure into a bedrock formation via the well. This process is intended to create new fractures in the rock as well as increase the size, extent, and connectivity of existing fractures. Hydraulic fracturing is a well-stimulation technique used commonly in low-permeability rocks like tight sandstone, shale, and some coal beds to increase oil and/or gas flow to a well from petroleum-bearing rock formations. A similar technique is used to create improved permeability in underground geothermal reservoirs.

Individual states regulate many aspects of oil and gas exploration and production. Federal land managers, such as the Bureau of Land Management (BLM), the U.S. Forest Service (USFS), and the U.S. Fish and Wildlife Service (USFWS) have some oversight of oil and gas activities on the lands they manage. This includes conducting environmental impact studies and enforcing environmental protections. The USGS role is to provide scientific research that helps with management options and decisions.

What Does Flow Back Mean?

Flow back is a water-based solution that flows back to the earth’s surface after completing the hydraulic fracturing of a shale gas reserve. This water-based solution consists of chemical additives, mud, clay, dissolved metal ions and TDS (total dissolved solids). The water becomes murky because of the abundance of suspended particles.

Flow back is prepared in the first ten days and the remaining solution can be prepared over a period of four weeks. The recovery volume from flow back is approximately 20-40 percent after injecting into the well for hydraulic fracturing.

When horizontal drilling and hydraulic fracturing were in their infancy, flow back testing was performed to clean the wellbore and its nearby reservoir rock areas by attempting to produce back as much of the treatment fluid as possible. Flow back is also used to get an indication of the amount and type of reservoir fluid (oil, gas, water) that can be produced and at what pressure, if any.

Flow back is very much associated with producing natural gas or shale gas through shale rocks using horizontal drilling and hydraulic fracturing. It is recovered from the well at the surface when the fluid is used to hydraulically fracture the shale formations.

Flow back is considered to be an important step in drilling operations. After it is recovered from the hydraulic fracturing operation it must be properly and safely disposed into the surface along with ground water. This water-based solution is purified before disposal using equipment such as:

  • Manual choke manifolds
  • Hydraulic choke manifolds
  • Plug catchers
  • Smug catchers
  • Sand separators
  • Control trailers

Drilling System Automation Roadmap

Drilling Systems Automation (DSA) is a fast-emerging technology now recognized as a game changer in oil and gas drilling operations. The key reason the drilling industry lags other industries in applying automation is that while many see it as inevitable, no consensus exists as to how to achieve DSA. This roadmap provides a mechanism to forecast technology developments, provide a framework to help plan and coordinate technology developments among disparate players, and to enable contributions from different industries.

The need for an industry roadmap is compelling. The well drilling and completion industry is highly fragmented and will require structure to enable the interoperability necessary to deliver functioning automated and autonomous systems. The roadmap will provide definition of supplier opportunities so that they can develop applicable products and services. A transformation of this scale across our industry requires consensus on how DSA will develop and must attract the requisite levels of investment. Entry of non-oil and gas industry players will enable the industry to access alternative skills and advanced technologies that are necessary for accelerating successful adoption. Fear of technology and personnel change is significant but can be overcome through a clearly communicated comprehensive way forward.

This Drilling Systems Automation Roadmap Industry Initiative, launched in 2013 as an all-volunteer organization and later converted to a Joint Industry Project (JIP), has created a DSA Roadmap Report to communicate the current state and expected development of Drilling Systems Automation (DSA) through 2025.


1. EXAMPLE Intergovernmental Panel on Climate Change, 1996, Climate Change 1995: The Science of Climate Change.

Images: “Arctic Methane Sea Ice” by NASA Earth Observatory