The evaluation was outlined by Gov. Wolf in a formal statement published in the July 30 PA Bulletin and comes in the wake of the Governor allowing House Bill 2644 to become law without his signature. Read more here.
“The legislature's action to withdraw the Environmental Quality Board's authority to establish bonding amounts for the conventional industry provides an appropriate occasion to revisit whether the Commonwealth is doing enough to ensure that this industry is being a good environmental steward by preventing the abandonment of wells and meeting its obligations as a prudent trustee of Pennsylvania's public natural resources for current and future generations.
“Evidence on this count is discouraging.
“Over the past five years, DEP has identified more than 17,000 violations at conventional oil and gas wells, and DEP has issued over 3,300 Notices of Violations to the conventional industry specifically due to attempts to abandon wells since July 1, 2017.
“In addition, over the past five years, operators of conventional oil and gas wells have failed to report production for an average of around 36,000 conventional oil and gas wells per year.”
Gov. Wolf said as a result of these concerns, DEP is reviewing existing processes and procedures and will be providing the following evaluations and recommendations to him by September 1:
-- Evaluation of the conventional industry's recent record of compliance with reporting requirements and performance requirements under existing law.
-- Evaluation of using existing authority, including increased exercise of civil penalty authority and forfeiting conventional oil and gas well bonds and requiring submission of replacement bonds, as methods to deter and motivate conventional operators to address abandoned wells and violations of the applicable law.
-- Recommendations for increased scrutiny of conventional oil and gas operators' requests for regulatory inactive status approval and permit transfers, because these steps are often precursors to improper abandonment of wells.
-- Evaluation of using existing criminal provisions related to conventional oil and gas operations as a means of deterring and motivating conventional operators to address abandoned wells and violations of the applicable law.
-- Recommendations for regulatory reform to comprehensively regulate conventional drilling according to modern best practices and industry standards.”
Updating Regulations
DEP is now in the process of updating conventional oil and gas environmental protection and waste disposal and handling standards, after the last comprehensive update was killed by the General Assembly in 2016. Read more here.
The first of two regulatory packages is expected to come before the Environmental Quality Board for action in the next few months, according to comments by Kurt Klapkowski, Acting DEP Deputy Secretary for Oil and Gas Management, at the July 25 meeting of DEP’s Oil and Gas Technical Advisory Board.
The second package-- dealing primarily with waste disposal, handling and similar requirements-- may not be ready to go back before oil and gas advisory committees until December 18 when DCED’s PA Grade Crude [Oil] Development Advisory Council meets.
The last draft of the waste handling regulation update was posted by DEP in September, 2021.
However, that draft did not address many key issues, like continuing to allow the road dumping of conventional oil and gas wastewater on dirt and gravel roads.
A comprehensive study released by Penn State in May found runoff from spreading conventional oil and gas wastewater on unpaved roads contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards. Read more here.
Unconventional shale gas operators are already banned from dumping their wastewater on roads.
It also did not address the issue of conventional oil and gas operators creating thousands of dumpsites across the state through practices allowing on-site disposal of drill cuttings and drilling wastewater. Read more here.
Related Articles:
-- 16 Oil & Gas Facility Spill, Soil, Water Contamination Cleanups Under Act 2 Land Recycling Program During July [PaEN]
-- New Abandoned Wells: DEP Records Show Abandoning Oil & Gas Wells Without Plugging Them Is Pervasive In Conventional Drilling Industry; Who Is Protecting Taxpayers? [2.23.22]
-- DEP Issues 20% More NOVs To Oil & Gas Well Drillers For Abandoning Wells Without Plugging Them In 2nd Quarter [PaEN]
-- Conventional Oil & Gas Drillers Dispose Of Drill Cuttings By ‘Dusting’ - Blowing Them On The Ground, And In The Air Around Drill Sites [5.2.22]
-- On-Site Conventional Oil & Gas Drilling Waste Disposal Plans Making Hundreds Of Drilling Sites Waste Dumps [6.6.22]
-- Penn State Study: Potential Pollution Caused By Road Dumping Conventional Oil & Gas Wastewater Makes It Unsuitable For A Dust Suppressant, Washes Right Off The Road Into The Ditch [7.26.22]
-- DEP Advises 18 Municipalities Where Road Dumping Of Conventional Oil & Gas Drilling Wastewater Is Occurring The Practice Is Illegal And Considered Waste Disposal [5.31.22]
-- Allegheny National Forest: Commercial Alternatives For Dust Suppression Makes The Practice Of Road Dumping Conventional Drilling Wastewater ‘Unnecessary’ On Roads [5.9.22]
-- Attorney General’s Office Reported To Be Investigating Conventional Oil & Gas Operators For Illegally Road Dumping Drilling Wastewater [4.22.22]
-- DCNR Bans Use Of Oil & Gas Wastewater On Its Over 6,500 Miles Of Dirt, Gravel Roads [1.25.22]
PA Environment Digest:
-- Links To Conventional Oil & Gas Drilling Articles
[Posted: July 29, 2022] PA Environment Digest
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