On July 10, the Department of Environmental Protection released its 2018 Oil and Gas Annual Report which summarizes compliance, inspection and other activities taken by the Oil and Gas Management Program.
The Annual Report points to DEP’s online Compliance Report Viewer which shows there were 6,162 violations found at conventional (5,033) and unconventional (1,129) wells sites during a total of 36,873 inspections of conventional (13,388) and unconventional (18,830) well sites.
This same database linked to from the Annual Report showed a total of 707 follow up enforcement actions-- 568 for conventional wells and 139 for unconventional wells.
However, the number of violations reported in the text of the Annual Report said there were a total of 4,060 violations for 2018-- 3,017 for conventional wells and 1,043 for unconventional wells.
So, either the number of violations for conventional wells increased from 3,273 in 2017 to 5,033 in 2018 or, alternatively, decreased from 3,273 in 2017 to 3,017 in 2018.
So, either unconventional well violations increased from 821 in 2017 to 1,129 or, alternatively, increased from 821 in 2017 to 1,043 in 2018.
Either way, conventional wells are found to have way more violations than unconventional wells. The number of violations at conventional wells tripled since 2015 from 1,024 to (using even the lowest number DEP reported) 3,017 in 2018.
DEP noted the surface activities inspection process moved to tablet computers, making it much more efficient and getting the results to operators and the public faster. All inspections are now done electronically.
The report also said internal restructuring and continued expansion of electronic tools increased permitting and inspection efficiency, while also increasing the overall strength of DEP’s oversight, even as unconventional gas production reached a record level in Pennsylvania.
“DEP attained new levels of efficiency in the permit application and review process as well as site inspections in 2018, and we continue to seek new avenues to improve customer service and environmental protection,” said Secretary Patrick McDonnell. “Governor Wolf and DEP have made permitting and inspection efficiency a priority – reducing overall permit backlog by more than 90 percent since 2016, and improving inspection efficiency while ensuring compliance with our environmental regulations.”
Penalties
DEP reported collecting $4,140,382 in fines and penalties in 2018, bringing the amount of fines collected in the Oil and Gas Program since 2011 to about $36.9 million.
DEP collected $3.5 million in penalties in 2017.
Gas Storage Fields
The Annual Report notes DEP regulates 60 underground natural gas storage fields in Pennsylvania, but beyond providing a fact sheet showing their general locations, there is no information on how many inspections DEP has done, the results of those inspections, the number of violations or follow up enforcement actions.
Permitting
DEP issued 1,868 unconventional well permits in 2018, about 160 fewer than the previous year. Sustained low commodity prices coupled with longer wellbores contributed to a decline in permit applications. An interactive map shows well drilling locations by county.
DEP issued 281 conventional oil and gas permits, 78 more than in 2017.
Across DEP permit backlog has been reduced from more than 8,700 in early 2016 to just 635 in June 2019. Inspection efficiency has also improved by approximately 20 percent through the use of portable tablets and other technological improvements.
The year also brought advancements in permitting, according to DEP. DEP launched an updated Erosion and Sediment Control General Permit, ESCGP-3, in electronic format and provided extensive training to industry on both the new requirements and the electronic application.
This surface-activities permit is the second permit to go online, following the subsurface well-drilling e-permit, which rolled out in 2017.
Electronic permit applications eliminate DEP data entry, ensure that applications are complete when submitted, and enable operators to pay permit fees online.
In addition, DEP simplified its internal oil and gas permit review structure statewide, grouping personnel into surface and subsurface programs for enhanced communications and teamwork.
By the end of the year, average review time for the ESCGP had dropped to 157 days in the southwest and 85 days in the rest of the state. The average time to review well-drilling permit applications shortened to about 39 days statewide.
Gas Production
Unconventional well operators produced 6.1 trillion cubic feet of natural gas, an increase of .8 trillion cubic feet over 2017 and the largest volume of natural gas produced in Pennsylvania in a single year.
Through a comprehensive outreach program, DEP assisted operators in achieving a record high 97 percent submission rate for required emergency response plans in 2018, capping several years of effort to increase compliance in this area.
The interactive, multimedia annual report offers several levels of data: the year in review; deeper detail and historical data; and educational overviews of drilling and the regulatory process statewide.
For example, users can compare how much gas was produced over the past 10 years, and drill down to see production by individual well.
Visit DEP’s Gas Production Reporting webpage to generate reports.
Production Fluids
DEP reports 90 percent of the fluids used to drill and produce conventional and unconventional oil and gas wells are recycled or reused in Pennsylvania. About 7 percent of fluids are disposed of in underground injection wells.
About 20,000 to 50,000 gallons of fracking fluid are used in a conventional well and about 15-20 million gallons for an unconventional well.
There are no statistics in the Annual Report showing the actual amounts of drilling fluids and how they are disposed of.
Click Here to go to DEP’s Oil and Gas Production and Waste Reporting webpage to generate reports on waste generated for unconventional and conventional wells.
[Note: A recent study of DEP’s data shows between 1991 and 2017 conventional and unconventional oil and gas development in Pennsylvania generated 398 million barrels of liquid waste [16,716,000,000 gallons], including 57 million barrels [2.39 billion gallons] in 2017 alone.
[During the same time period, over 7 million tons of solid waste was generated from conventional and unconventional oil and gas development in Pennsylvania, including over 1 million tons in 2017.
[More than half of the liquid waste that remains in Pennsylvania was reused in extraction operations, the study found, a practice that can result in more concentrated levels of salinity and chemical residues with each subsequent use, according to the study.
[Researchers note that the pervasiveness of this practice raises questions about how to treat or dispose of these more concentrated waste streams in the future, when drilling operations slow or cease, diminishing the demand for wastewater reuse.
[For more than a third of liquid waste from all oil and gas operations - 35 percent - the final location is unknown, often because reporting reflects only intermediary locations for transfer or storage.
[Some of the state's liquid waste - 7.6 percent, or 30 million barrels [1.2 billion gallons] over the study's time period - is sent to municipal or other water treatment plants, which discharge into surface waters like rivers after treatment, according to the study.
Orphan/Abandoned Wells
DEP reported it has located 12,164 orphan and abandoned wells and working to locate more. It has plugged 3,412 and 8,752 remain unplugged.
This is out of an estimated 200,000 orphan and abandoned wells in the state.
Staying Informed
The annual report also features a section on the many ways the public can stay up-to-date on regulations, for example, by signing up for email notifications or attending Oil and Gas Technical Advisory Board meetings in person or by webinar.
Reaction
Marcellus Shale Coalition president David Spigelmyer released this statement on the report-- “As this report confirms, tens-of-thousands of talented and well-trained Pennsylvanians across our industry work hard each day to protect our environment and the communities where we’re privileged to work.
“Unconventional natural gas producers are more efficient in the use of resources, reusing and recycling 90 percent of the water we use, while driving record production levels in Pennsylvania.
“And we are doing so with an inspection compliance rate that exceeds 98 percent, reflecting our collective commitment to safety, operational excellence and public health.
“These significant achievements have helped enhance our air quality, lowered energy costs for families, and created significant opportunities for good-paying manufacturing jobs across the Commonwealth.”
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