Monday, September 14, 2020

DEP Reports Conventional Oil & Gas Wells Had Nearly Twice The Violations Of Shale Gas Wells; DEP To Develop New Conventional Drilling Regs

On September 14, the Department of Environmental Protection issued its 2019 Oil and Gas Annual Report showing conventional oil and gas wells had nearly twice the violations of shale gas-- unconventional-- wells in 2019.
DEP reported 1,783 conventional oil and gas well violations against 985 for unconventional wells based on fewer inspections of conventional wells-- 12,027 versus 18,970 for unconventional wells.
The number of violations did decrease from 2018-- 3,017 conventional and 1,043 for unconventional.
DEP also said it reduced well permit issuing times by over 75 percent from 2017 to 2019-- 104 days to 26 days in 2019-- in the agency’s Southwest Regional Office which had significant permit processing issues.
DEP said the Southwest Regional Office reduced permit review times for associated erosion and sedimentation permits from 118 days in 2017 to 45 days in 2019.
Production from natural gas wells continues to increase. More than 6 billion Mcf of natural gas was produced, continuing an upward trend from previous years.
DEP is also said it is exploring new partnerships to address orphan wells, identifying better restoration practices, and developing better ways to manage stormwater on well sites.
The Details
Other details from the annual report include--
-- Permits Issued: 1,705 drilling permits were issued; 1,475 unconventional and 230 conventional [that’s down from 1,868 unconventional and 281 conventional in 2018]
-- Well Permit Review Times: The average time it took to issue a well permit dropped from 104 days in DEP’s Southwest Regional Office in 2017 to 26 days in 2019 and from 61 days in DEP’s Northwest Regional Office in 2017 to 26 days in 2019
-- E&S Permit Review Times: The average time it took to issue erosion and sedimentation permits dropped from 118 days in DEP’s Southwest Regional Office in 2017 to 45 days in 2019 and from 51 days in DEP’s Northwest Regional Office in 2017 to 23 days in 2019.
-- Wells Drilled: There were 787 wells drilled; 615 unconventional and 172 conventional [down from a total of 917-- 777 unconventional and 140 conventional in 2018]
-- Inspections: DEP conducted 35,324 inspections [18,970 unconventional, 12,027 conventional] and 
-- Violations: DEP found 5,496 violations [985 unconventional, 1,768 conventional] which is down from a total of 6,022 violations in 2018-- 1,043 unconventional, 3,017 conventional]
-- Penalties: DEP collected $4.1 million in fines and penalties in 2019
-- Water Recycling: 90 percent of produced fluids are recycled and reused; 8 percent of fluids disposed of in underground injection wells; most of the remainder of produced fluids not recycled or reused are transported to Ohio and West Virginia for underground injection well disposal.
“DEP will continue to improve environmental protections for oil and gas development while providing certainty for operators and the people that live, work, and play near Pennsylvania’s oil and gas communities,” said DEP Secretary Patrick McDonnell. “We are remaining vigilant in our oversight of the industry and bringing enforcement actions against companies that violate the laws and regulations of Pennsylvania.”
DEP continues to identify and plug orphan and abandoned wells in Pennsylvania, many of which predate regulatory oversight – a result of Pennsylvania’s 160-year history of oil and gas development. 
DEP estimates that there may be as many 200,000 abandoned oil and gas wells in the state, which can leak methane into the air and possibly contaminate groundwater or surface water. 
DEP and the Department of Conservation and Natural Resources have begun a field study in the Cornplanter State Forest to measure methane leakage from identified orphan wells. This research will help DEP better estimate methane emissions from the thousands of orphaned and abandoned wells in Pennsylvania.
“We know there are thousands of old, abandoned wells in Pennsylvania, but we don’t know how to quantify the threat these wells pose to our environment, especially from a climate change angle,” said McDonnell. “This research will help us put that into perspective and help guide how to prioritize well-plugging in the future.”
Next Steps
-- New Conventional Oil & Gas Regulations: After the General Assembly killed final updated regulations for conventional oil and gas operations in 2016, the PA Grade Crude Oil Development Advisory Council was formed to work with DEP to help develop a new “regulatory scheme.”
“Since 2016, the program has worked with CDAC as a body and with individual members to develop potential legislation and proposed regulations relating to conventional oil and gas wells. 
“Specifically, proposed rulemaking concepts were discussed at several CDAC meetings throughout 2016, 2017, and 2018. 
“In April 2018, program staff and CDAC members met and developed a scoping document outlining where agreement could be reached on potential legislative or regulatory language. 
“In 2018 and 2019, program efforts on this issue centered more directly on legislative language. 
“However, because legislative discussions have not resulted in a viable product, DEP plans to proceed with the development of a proposed conventional oil and gas rulemaking and will likely advance the rulemaking via several concise packages in parallel during 2020.
“These rulemakings propose to amend the Oil and Gas regulations applicable to conventional operators (Chapter 78) to update the environmental protection performance standards related to oil and gas activities. (2012 Oil and Gas Act, Clean Streams Law, Solid Waste Management Act, Dam Safety Encroachment Act, Land Recycling and Environmental Remediation Standards Act, Radiation Protection Act, Unconventional Well Report Act, Act 126 of 2014).”
-- Model Stormwater Plans: DEP said it plans to develop a post construction stormwater management model plan for use with Chapter 102 Erosion and Sedimentation permits
-- Pipeline Geologic Hazard Mitigation: One of the actions DEP said it plans to take next in the report is to establish guidelines for the identification and investigation of potentially hazardous geologic conditions along pipeline construction routes.
-- Seismic Monitoring: DEP is developing underground injection well permit seismic event monitoring requirements.
For more information on regulating oil and gas drilling in Pennsylvania, visit DEP’s Office Of Oil and Gas Management webpage.
[Posted: Sept. 14, 2020]  PA Environment Digest

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