Fraud Blocker Beneath the Surface: The Orphaned Well Challenge  - Weston Solutions

Beneath the Surface: The Orphaned Well Challenge 

Maggie Graham serves as a Client Program Manager, overseeing Weston’s oil and gas programs for both Federal and Commercial clients. She has over 24 years of experience in environmental consulting, managing remediation projects, conducting site assessments, and ensuring environmental compliance. Throughout her career, she has continuously followed her clients and traveled to where she was needed most, from Houston to Colorado, to Alaska. During her time in Colorado, she managed an oil and gas remediation program, overseeing legacy contamination issues, and led a team to address them. Her work has also included response programs post-Hurricane Katrina, Harvey, Maria, and Irma, handling hazardous waste and emergency situations for the Environmental Protection Agency (EPA). Maggie’s career has been marked by her adaptability and expertise and her work has significantly contributed to addressing environmental compliance and legacy contamination challenges within the oil and gas industry. 

What is an “orphaned well”, how is it different than an “abandoned well”, and why are they a problem?  

That’s a good question!  These terms are often used interchangeably, but it really depends on the context. Since 1859, thousands of oil and gas wells have been drilled throughout the United States. The early decades of oil and gas extraction were completely unregulated, with environmental and operational regulations only coming about in the mid-1900s. During the unregulated era, companies would often drill a well and run it until it stopped producing or being profitable. Once the well stopped producing oil profitably, these companies could simply walk away from the well. 

An “abandoned well” is a well that has not been used for production, extraction, or injection of gas, petroleum, or other liquids within the preceding 12 months. It may also refer to a well from which the equipment has been removed or the well is considered dry and not equipped for production within 60 days after drilling, redrilling, or deepening.  

An “orphaned well” is defined as an oil and gas well that no longer has a legal owner responsible for it. Depending on the jurisdiction, it may also mean a well for which no owner or operator can be found due to a lack of records, or where the owner or operator is unwilling or unable to plug and abandon the well. So, all orphaned wells are abandoned, but not all abandoned wells are orphans.   

If a well is properly abandoned in accordance with the local jurisdiction and regulations, “abandoning a well” is a good thing, but understanding the context is key. Was it abandoned, and later “orphaned,” or was it properly plugged and abandoned according to the regulations? It’s important to know the difference.  

Orphaned wells and orphaned well sites can pose a danger to visitors, landowners, the environment, and our climate. They can leak oil and brine, contaminating the soil and water around them from old pipes, tanks, and a variety of unmaintained infrastructure. Orphaned wells also can release methane, an explosive hazard and a potent greenhouse gas.   

How does a well become orphaned?  

A well can be designated as “orphaned” through several methods. One such method is when the state’s oil and gas regulatory body rescinds the operator’s operating rights via an enforcement action. In other cases, an operator might voluntarily cease operations due to financial difficulties. Lastly, there are situations where the regulatory agency cannot determine the accountable party for “historic” oil and gas facilities due to a lack of comprehensive records. 

Orphaned wells can become legacy pollution sites and endanger public health and safety by polluting groundwater, releasing harmful gases such as methane, scattering the environment with decayed and hazardous equipment, increasing the risk of sinkholes, and negatively impacting wildlife. Numerous state regulatory bodies have established a process for handling orphaned wells. This process involves identifying the well, ranking it based on the state’s guidelines, and then categorizing them according to the available budget and the extent of work required at the well or site.  

For a variety of reasons, oil and gas operators may discontinue operation and maintenance of oil and gas facilities, effectively “abandoning” the facilities. Modern oil and gas regulations require operators to plug and abandon their wells and provide financial assurances (bonding) to protect the landowners and taxpayers, but these regulations historically were not always in place, the state may not have an oil and gas regulator, the financial assurance may be inadequate, or these regulations were not always adhered to. 

What does “Plug and Abandonment” mean, and why is it important?  

“Plug and abandon” (or P&A) is a term used to describe the procedure of permanently closing a well that has ceased to be productive or profitable. This process is necessary when a well is “dry” and not commercially viable, has exhausted its operational lifespan, or when continuing production poses safety risks or is no longer cost-effective. Proper closure of the well is crucial to mitigate any potential environmental or safety threats. 

The procedure of plugging and abandoning a well usually encompasses multiple stages. These include the extraction of the production apparatus from the well, dismantling the wellhead and related infrastructure, and installing cement plugs at specific depths within the wellbore to segregate and securely close off production zones. Subsequently, the well is sealed off permanently using a mechanism known as a wellhead plug (or plugs) which are installed to inhibit the movement of fluids or gases among distinct geological layers. Depending on the well, multiple cement or mechanical plugs may be needed to adequately seal off the oil and gas producing zones if there is more than one.  

What is the purpose of well-plugging and abandonment in the oil and gas industry? 

If these oil and gas sites are not properly managed, they could potentially disrupt the agricultural activities or future plans of the landowner, inflict damage on local wildlife, pose environmental threats, or even become a public safety risk. 

These wells pose significant risks to human and environmental health by leaking toxic chemicals into the air, contaminating groundwater, and emitting methane. The EPA estimates that methane emissions from over 2 million inactive, unplugged wells, of which documented orphaned wells are a subset, range from a CO2 equivalent of 7-20 million metric tons per year (approximately the emissions of 2 to 5 million cars). They can also lower property values and land productivity. 

The act of correctly sealing and decommissioning wells is vital for the protection of our environment. The oil and gas sector strives to reduce the likelihood of adverse events and safeguard the environment through effective plugging and abandonment procedures. This process is an essential part of managing the lifecycle of oil and gas resources. By effectively sealing and discontinuing non-producing wells, operators can decommission unprofitable assets, distribute resources more effectively, and fulfill bonding obligations. 

What are the key steps involved in locating and documenting orphaned wells?  

In acquiring land, the presence or status of wells was often considered less important than the land acquisition itself. This sometimes resulted in a lack of comprehensive due diligence. These early, unrecorded wells are now being unearthed in public spaces, agricultural lands, commercial properties, and even residential areas. The discovery of these wells is frequently triggered by incidents related to health and safety. Given the probable age of these wells and the records of their whereabouts, their status and condition are often shrouded in ambiguity or inaccuracies. For example, the exact coordinate systems of latitude and longitude that we rely on today were not in existence when many of these wells were drilled. Well locations are often noted by Sections, Townships, and Ranges, which will give us the right vicinity but makes finding precise well locations difficult. 

The current strategies for well detection involve field scientists traversing suspected orphaned well land parcels on foot. Success has also been found with the use of unmanned aerial vehicles (drones) equipped with magnetometers and light detection and ranging (LiDAR), conducting interviews with landowners, scouring historical records at local libraries, examining historic topographic or Sandborn maps, and performing thorough land and title searches at county tax assessor offices. 

How is Weston helping our clients solve orphaned well problems? 

While Weston is not focused on the actual well plugging effort, the challenge of dealing with orphaned wells extends beyond successfully sealing these wells. The initial step involves identifying the well and confirming the absence of a responsible party. A file investigation needs to be performed at the local tax assessor’s office, a search for land titles and mineral rights must be undertaken, and any possible well records, which may have been managed by different organizations over time, need to be scrutinized.  

In certain states, well records have been digitized and can be searched online. However, in some states the records are still physically stored within numerous boxes and cabinets. A manual search of the files would then be required to review well logs, ownership documents, and production records. 

Depending on the site, the next step once the well is located may be to have a specialized and experienced service company plug the well. Due to the unknown condition and history of many of these wells, it is best to use a company that specializes in orphaned well work for this kind of well plugging. Weston has established relationships with the best orphaned well-plugging firms in the country and is happy to refer our clients to one in their area.  

At times, the immediate course of action is not to plug the well, that may be deferred until later based on available funding; instead, the first step may involve conducting an environmental characterization of the well site. This is where Weston’s expertise comes into play. It is important to inventory the oil and gas equipment remaining onsite, collect representative soil and groundwater samples to check for legacy impacts from the well operation, and collect representative waste characterization samples from inside any tanks or equipment that was left behind. Buried flowlines, buried tanks, leaking pumps, and diesel-powered engines all may have released hydrocarbons, hydraulic fluids, produced water, and other chemicals on the surface and subsurface. Asbestos pipe wrap and lead-based paint can be present at legacy oil and gas sites also, posing hazards that Weston is skilled at identifying and mitigating. We typically work side by side with specialized oil and gas personnel called a roustabout crew, that may be decommissioning a well pad while we are onsite performing the environmental characterization. 

From 2023 to 2024, Weston performed over 60 site investigations and characterizations on orphaned well sites on behalf of the Colorado Energy and Carbon Management Commission, Orphaned Well Program. This involved collecting hundreds of soil samples and documenting current site conditions, communicating with landowners for access, and preparing summary reports with recommendations for next steps. In Arizona during the past year, Weston provided desk-top orphaned well site characterizations for over 60 orphaned or potentially orphaned wells, followed by field surveys to locate and assess the wells for prioritization. Field surveys included drone and hand-held magnetometer surveys and methane screening.  

Once legacy impacts have been determined by Weston, we are able to identify the source(s), delineate the extent of the impacts, characterize, or recommend an appropriate remedial technique, and help our clients properly clean up the sites so that they can be useful again or a property transaction can proceed. Some of my most memorable orphaned well sites are in the farm and ranch lands of northeastern Colorado where old pump jacks and well houses are deteriorating in the middle of beautiful agricultural areas. Being able to serve a small role in returning these areas to be of beneficial use is the best part of my job.  

In addition to site characterization, Weston also offers grant application writing services. Federal funding has been made available to support state programs to locate and properly abandon orphaned wells through the Bipartisan Infrastructure Law in 2022 which created three types of grants for state orphaned well programs (initial grants, formula grants, and performance grants). Weston can perform the research, documentation, and technical writing for a robust grant application package.  

How can orphaned well environmental contractors, like Weston, optimize efficiency and reduce costs?  

Environmental contractors specializing in orphaned wells, such as Weston, can enhance efficiency and cut costs through several strategies. The initial step to cost-saving involves circumventing unexpected issues in the field by gaining a thorough understanding of a well and its location before mobilization. A method to prevent such surprises is through an exhaustive review of both well and county records. Using historic aerial imagery can also be beneficial by providing a clearer understanding of the pad configuration, which may have changed over time. This research aids in understanding the well’s configuration, its location, site accessibility, and any impacts from legacy operations. It also paves the way for contemplating potential alternatives for repurposing the site. By performing this due diligence ahead of time, the appropriate contingency equipment and experienced staff will already be onsite to handle the site’s challenges.  

Site visits should also be consolidated to minimize mobilization and save on costs. For example, the sampling of tank waste can be scheduled to coincide with the pulling of flowlines by the roustabout crew. This allows for flowline sampling and an examination of the subsurface while the flowlines trench is exposed. Clear and effective communication with the roustabout crew or drilling contractor is another crucial aspect. This ensures that everyone is on the same page regarding timelines, schedules, and expectations, thereby preventing potential misunderstandings, rework and delays. The roustabout teams are often requested to share their observations of any soil discoloration, leaks, or odors they detected during the decommissioning process. These insights can be valuable when Weston steps in to conduct a detailed site characterization investigation. 

Weston also enhances efficiency via its Enterprise Visualization and Analytics (EVA) Team, which has designed a system that can be used across the entire lifecycle of the orphaned well project. We have helped several clients, including the EPA, build efficient and effective data management strategies and have helped to evolve the tools and processes for managing data to meet the ever-changing technology platforms. 

The Orphaned Well EVA System combines field data collection using tablet computers with web-based geospatial technologies (GIS) that allow the entire project team to have a common operating picture of project status and technical data. Weston ensures swift client access to data for real-time decision-making regarding each site, such as illustrating methane emissions screening results. This is achieved by capturing information directly from the field, electronically importing analytical data from labs, subjecting all data to a specific quality assurance (QA) process, and making all approved data available for near-instantaneous use.  

Lastly, employing a local analytical laboratory can help reduce sample shipping costs and expedite turnaround times. By adopting these strategies, contractors like Weston can significantly improve their management of orphaned wells in terms of both efficiency and cost-effectiveness.