Improving Plugging and Abandonment Procedures

Daily news feeds and internet searches abound with abundant negative images about the oil and gas industry. These images feed the negative messaging that anti-fossil fuel groups are eager to magnify. In response, regulators add regulations—often without industry input. If the industry is going to rehabilitate its image, it must demonstrate its desire to be “pro-environmental.” Not only does this preserve the industry’s license to operate, it will likely result in a better regulatory climate.

How Abandoned Wells Hurt the Oil and Gas Industry’s Image

One of the most visible and negative images involves plugged wells that are leaking and flowing. The damage done to the surface and subsurface is significant and creates a visualization that is hard to deny.

Beyond their negative imagery, poorly plugged wells release methane and other corrosive gases, not the least of which is deadly hydrogen sulfide. Many leaking plugged wells produce anywhere from a nuisance smell to a toxic fluid flow on the surface, harming livestock and other animals. Their sub-surface issues are harder to document but can be even more damaging. Once a freshwater zone is cross contaminated by a leaking well, that zone is forever contaminated. Overall, improperly plugged wells can create health issues for nearby residents, animals, and crops. None of this presents the oil industry in the best light.

One thing increasing the frequency and seriousness of leaks is the rise of injection wells disposing of produced water. A recent SMU study revealed a connection between rising pressures in saltwater disposal (SWD) injection formations and leaks/releases in abandoned wells. And with CO₂ injection for carbon capture and storage (CCS) also slated for growth, the issue is likely to increase.

How the Oil Industry Can Make a Difference

This is not just a responsibility for regulators. The industry is ultimately responsible and will incur the brunt of environmental liability and bad publicity unless it takes action.

The consensus is that the Texas Railroad Commission’s plugging form, the W-3, and related standards for plugging a well have not been updated in over 50 years. During this time, technology and best practices have surely improved.

Updating and improving the procedures and requirements could be a significant step toward improving plugging and could improve the industry’s image. Certainly, in the public relations battle, abandoned wells leaking or venting make dramatic—and persuasive—visualizations.

Operators know the technology better than regulators and can best advocate for more rigorous plugging standards. This would also demonstrate how the industry is a leader in being responsible—not just the whipping boy.

But Regulators Have a Key Role Also

From drilling to plugging, there are steps that regulators like the RRC and the Texas Commission on Environmental Quality (TCEQ) can take to ensure the best practices for plugging.

Agencies can more actively enforce plugging and remediation rules with a well whose operator is known if/when solvent begins leaking. Prompt enforcement would remove another public relations opportunity for the opposition and improve relations with landowners and neighbors.

The RRC reports that it plugged almost 2,000 wells in the last two years (2023-24) with state funds. Late in 2024, the agency asked the Texas Legislature for $100 million in additional emergency funds to further boost their efforts. This budget and effort should be leveraged to explore regulation and other improvements. It would allow the RRC to foster a new generation of best practices that can then be followed by the industry.

Food for Thought: Potential Improvements for a P&A Procedure

Improved best practices range from the regulatory side to the actual plugging operation.

1. The RRC’s W3 form was last updated in the early 1980s. In the ensuing 40-plus years, plugging technology has advanced drastically, so updating that form’s requirements would be a significant step toward safer plugging of today’s wells when the time comes. Plugging technology has also advanced greatly in recent years, and the RRC and/or the TCEQ must update their requirements for procedures and verification at the end of a well’s life.
2. Each well to be plugged should have a wellbore diagram submitted with the W-3, both an “as-is” and an “as-proposed” version. This is not currently required by the RRC. For most wells, this should be easy. Others that have changed ownership, not as much—certainly not accurate ones. But accurate downhole information is essential for generating proper plugging procedures.
3. Better define the weight and actual composition of the material to be used to load the hole. Stories exist of 9.5-pound brine with a muddy appearance taking the place of true 9.5-pound mud. Even more important is mud viscosity, which the rule ignores. The problem here is that the mud-brine mixture will separate and lose viscosity, reducing the plug’s efficacy. A freshwater viscous mud provides cement plugs a much better chance of being placed properly, at depth, and without saltwater contamination.
4. If a temperature or bond log was not run at completion (or is lost), then a bond log should be run prior to plugging, unless cement circulation is proven in the record. A temperature log recorded when the cement is set, or a bond log during completion, would show the quality of the cement job and the location of any plugging issues that need to be addressed. Identifying the top of the downhole cement is foundational to a good plug job and would eliminate needless perforating and squeezing, which affects casing integrity.
5. Running a bond log for each plug candidate should be considered. In the time since the well’s drilling and temperature logging, degradation of the cement and pipe could be extensive. The plug job relies on these elements being in good condition. If not, further steps, including more cement, would be required to properly plug the well. Further, bond logs could identify whether wellbores have deviations. These deviations would likely result in the casing directly contacting the sub-surface, creating areas where cement cannot circulate around the casing, exposing it to the formation and producing a leak point.
6. Set timelines for plugging a well. No one wants to pay for plugging, and there is a chance that a zone could be developed uphole. However, a shut-in or temporarily abandoned well will only degrade with time due to the downhole fluid exposure. While that makes it challenging to recomplete, it also makes it a poor wellbore to plug. Reasonably limiting the interval between discontinuing production and commencing plugging would likely preserve the plug’s integrity, making future leaks less likely.
7. Track ownership and responsible parties. Per RRC rules, the company that plugs a well (and files the W3 report) is responsible for the plug’s performance and is liable for its sufficiency. While the operator may attempt to shift liability when selling the property, by RRC rules, it cannot be transferred.
8. Upgrade the RRC and other regulatory staff. Substandard pay results in turnover and less qualified personnel overseeing these and other regulatory matters. The average tenure is 6.5 years, according to a 2022 state study, meaning agency personnel’s experience to address these issues is lacking. With such short average tenure, employees have difficulty gaining the experience and knowledge needed to fully understand the industry, technological advances, and how to improve operations.

We Can and Must Do This

The problem will not go away—but will, in fact, only grow. As of 2022, the U.S. had more than 3.2 million orphan/abandoned wells, with Texas alone exceeding 150,000—all of which need plugging. Add in the continuing increase in water and CO2 injections, and the potential for further leaks can only grow. One wonders if the 40-plus year-old procedures for plugging wells are sufficient, considering the increased downhole pressures and fluid types now routinely injected around the plugged well.

I am a longtime member and supporter of the oil and gas industry! Our industry has the knowledge, license, and responsibility to elevate our business practices–especially given its environmental and societal impact. My hope here is to help my industry raise its standards for protecting the community and the environment, proving to naysayers that we are indeed committed to doing everything possible to solve these issues and make everyone’s world better.

Grant Swartzwelder is the Founder of OTA Environmental Solutions, a full-service environmental firm providing equipment, field services, and emissions consulting. Additionally, he is co-founder of ESG Dynamics, which provides environmental data analytics for the oil industry—analytics that assist in A&D, Waster Emissions Charge reduction, and Health Checks. 

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