A 203-page review of DEP’s Oil and Gas Regulatory Program just released by the State Review of Oil and Natural Gas Environmental Regulations (STRONGER) found Pennsylvania’s program is “well-managed, professional and meeting its program objectives.”
At the same time, the group said DEP needs to develop a standardized way of tracking violations and enforcement actions, should develop a consistent method to determine surface casing depths to protect groundwater and develop guidance for pre-drilling water sampling.
The STRONGER voluntary and independent review program has conducted four other reviews of Pennsylvania’s program, this most recent done in May by a panel including industry, government and environmental representatives.
The STRONGER report also identified several strengths in Pennsylvania’s Program--
-- Staff Resources: Commended DEP for increasing its staff and resources to address additional permitting, inspection and enforcement activities as well as noting the passage of new legislation (Act 13 of 2012) to distinguish regulation of Marcellus Shale and conventional oil and gas wells.
-- Abandoned Wells: DEP was commended for their public participation activities associated with the abandoned sites program. Public participation activities with respect to abandoned wells have been occurring for many years by local individuals and environmental groups. These groups have been especially proactive in searching for abandoned oil and gas wells. Two such groups are the Senior Environmental Corp, who searched for abandoned wells in Oil Creek State Park in Venango County and “Save Our Streams PA,” who is involved in finding abandoned wells in Potter and McKean Counties.
-- Radiation Study: The report noted DEP’s comprehensive study of radiation levels specifically associated with Marcellus Shale well development (TENORM study) now underway is the first of its kind in the nation.
-- Stormwater Management: Commended DEP for its stormwater management program and the adoption of a new stormwater management policy that relies on the use of Best Management Practices for the control of erosion and sedimentation at drilling and related sites.
-- Hydraulic Fracturing Program: DEP was commended for its hydraulic fracturing program. Standards for well casing and cementing require that the operator conduct those activities to control the well at all times, prevent migration of gas or other fluids into sources of fresh groundwater; and prevent pollution of fresh groundwater. The report noted the well completion report requirements and chemical disclosure requirements exceed public disclosure and reporting requirements of the STRONGER Guidelines.
A complete copy of the report is available online.
