-- Discussion of the first-ever assessment of how well conventional oil and gas drillers comply with state environmental laws DEP released on December 29 that concluded the industry accepts non-compliance as a norm. Read more here.
-- Conventional industry challenge to final regulation limiting VOC/methane emissions from conventional oil and gas facilities;
-- Update on proposed Chapter 78 conventional waste management regulations [Read more here];
-- Update on new federal conventional oil and gas well program [Read more here];
-- Update on the leak of an estimated 1 billion cubic feet of natural gas from Rager Mountain gas storage area in Cambria County [Read more here]; and
-- Response from Dr. William Burgos on how the Council misrepresented his positions on the Penn State study of the environmental impacts of spreading drilling wastewater on roads.
Compliance Report On The Industry
The DEP compliance report on the conventional industry concluded, “(the) conventional oil and gas industry’s recent record of compliance with Pennsylvania law is simply not good, particularly with regard to improper abandonment of wells.”
“A significant change in the culture of non-compliance as an acceptable norm in the conventional oil and gas industry will need to occur before meaningful improvement can happen.”
“This record of non-compliance will require DEP to further develop and refine its techniques for deterring violations and encouraging compliance with relevant statutory and regulatory provisions.
The report looked at environmental compliance in the industry between 2017 through 2021. Read more here.
Final VOC/Methane Limits
The meeting packet includes a three-page list of questions for DEP on the final regulation setting VOC/methane emission limits on conventional oil and gas operations for discussion.
As reported by Marcellus Drilling News, three industry groups representing the conventional oil and gas industry filed a lawsuit in Commonwealth Court December 5 in an attempt to block implementation of DEP’s emergency final VOC/methane limits regulation on conventional oil and gas facilities. [Read more here.]
Because of that litigation, it is unlikely DEP will be able to respond to those questions.
Council Misrepresentations Of Road Spreading Study
Dr. William Burgos, lead author of the Penn State study released in May on the environmental impacts of road spreading conventional drilling wastewater, wrote a memo to the Council on how the conventional industry misrepresented his positions on the study and its contents in a resolution it passed in August.
On May 26, Penn State University and the Department of Environmental Protection released a new study of spreading conventional oil and gas wastewater on unpaved roads by Penn State researchers, who found the wastewater running off the roadways after spreading contains concentrations of barium, strontium, lithium, iron, manganese that exceed human-health based criteria and levels of radioactive radium that exceed industrial discharge standards.
The study also found the wastewater is only about as effective as rainwater at controlling dust, but worse for the environment.
“The ineffectiveness and potential pollution of wastewater spreading make the practice an unsuitable alternative for dust suppression on Pennsylvania roads, the team reported to the DEP’s Office of Oil and Gas Management.” Read more here.
On August 18, conventional oil and gas drillers on DCED’s PA Grade Crude [Oil] Development Advisory Council passed a motion recommending DEP's acceptance of the Penn State study showing their drilling wastewater dumped on roads is bad for human health and the environment be rescinded and industry representatives by involved in rewriting the study. Read more here.
Among the ways Dr. Burgos said the conventional oil and gas industry misrepresented his positions were--
-- The request to rescind DEP’s acceptance of the Penn State report by the industry is “unwarranted because it is unsupported by scientific fact.”
-- On the statement in the industry resolution that he agreed samples were not representative of conventional wastewater in Northwest Pennsylvania-- “CDAC misunderstood and misrepresented my position” “I did not agree.”
-- The “CDAC misunderstood and misrepresented my position” -- “I did not agree” 2,500 pCi/L of combined radium is not representative of conventional wastewater. “...2,500 pCi/L is representative” and wastewater spread on roads “could readily equal or exceed this value.” [60 pCi/L is the Nuclear Regulatory commission standard]
-- The resolution pointed out the new Penn State study did not reference three previous studies done by DEP on the issue of road spreading and radioactive elements. Dr. Burgos responded, “While the validity of a study’s scientific results does not depend on references to previous work, I reviewed those reports and plan to cite them in future publications. All three reports support our findings,” including DEP’s 2013/2016 TENORM study of naturally occurring radioactive material in oil and gas wastewater, drill cuttings and natural gas itself completed with the help of Perma-Fix Environmental Services.
Click Here for the full response from Dr. Burgos.
The conventional industry responded to the memo from Dr. Burgos by picking small sections from a transcript of his remarks that supported their position and annotated the resolution the Council passed in August.
It’s clear the full transcript supports Dr. Burgos’ position because it puts those hand-picked remarks in context.
The meeting packet also includes draft minutes from the August 18, 2022 meeting for Council action.
Click Here for the full meeting agenda and available handouts.
Joining The Meeting
The meeting will be held in Room 248 of the Gemmell Student Center, 1048 Payne Street on the Pennsylvania West University campus in Clarion from 10:00 a.m. to 3:00 p.m.
Click Here to join the meeting via Microsoft Teams. Meeting ID: 231 481 419 418 Passcode: 6Xq9e2 . The meeting will also be available by telephone-- +1 267-332-8737, Conference ID: 391 110 544#
Visit DCED’s PA Grade Crude [Oil] Development Advisory Council webpage. Questions should be directed to Adam Walters, adwalters@pa.gov or call 717-214-6548.
PA DEP Public Notice Dashboards:
-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - Feb. 4 to Feb. 10 - 12 NOVs For Abandoning Wells Without Plugging Them [PaEN]
-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - Feb. 11 [PaEN]
-- DEP Posts 57 Pages Of Permit-Related Notices In Feb. 11 PA Bulletin [PaEN]
PA Oil & Gas Industry Compliance Reports:
-- DEP 2021 Oil & Gas Program Annual Report Shows Conventional Oil & Gas Operators Received A Record 610 Notices Of Violation For Abandoning Wells Without Plugging Them [PaEN]
-- Feature: 60 Years Of Fracking, 20 Years Of Shale Gas: Pennsylvania’s Oil & Gas Industrial Infrastructure Is Hiding In Plain Sight [PaEN]
Related Articles - Unleashing The Industry:
-- Natural Gas Industry, Senate Republicans Launch Effort To Unleash The Industry, Reduce Regulation, Call For Automatic Approval Of Permits, Limit Public Comments [PaEN]
-- House Committee Fails To Address $70 Million In Penalties On Natural Gas Pipelines Or Real Concerns Of People Living Near Gas Production & Distribution Facilities [PaEN]
-- Senate Budget Hearings: PA’s Experience With New Pipeline Construction Shows State Laws Not Strong Enough To Prevent Environmental Damage, Protect Public Safety [PaEN]
Related Articles This Week:
-- Natural Gas Industry Tells House They Want Faster Permit Reviews, But Didn’t Say They Don’t Use 40% Of The Well Permits They Get From DEP; Industry Practices Keep Energy Prices High [PaEN]
-- DCED Conventional Oil & Gas Drilling Advisory Council Feb. 16 Meeting Agenda Includes Discussion Of Poor Compliance Record Of Industry, Status Of Regulations Updates, Challenge To VOC/Methane Regs [PaEN]
-- Ohio/PA Train Derailment, Pipeline Explosions, Uncontrolled Releases Put Spotlight On Public Health, Safety Threats Posed By Petrochemical, Natural Gas Industrial And Pipeline Infrastructure In PA [PaEN]
-- Inside Climate News: DEP Took 9 Days To Inspect Natural Gas Liquids Plant That Caught Fire On Christmas Day In Washington County [PaEN]
-- Inside Climate News - Jon Hurdle: PA Environmental Officials Took 9 Days To Inspect Natural Gas Liquids Plant That Caught Fire On Christmas Day In Washington County
-- DEP Citizens Advisory Council To Hear Updates From Oil & Gas, Abandoned Mine Reclamation Programs Feb. 14 [PaEN]
-- Marcellus Drilling News: Shale Gas Companies Play ‘Dirty Pool’ By Reactivating Expired Leases By Claiming They Are Part Of Back-dated Pooling Declarations [PaEN]
-- Senate Environmental, Consumer Protection Committees To Hold Feb. 27 Hearing On Grid Reliability And Winter Storm Elliot [PaEN]
-- Post-Gazette - Anya Litvak: As More Utility Customers Struggle To Pay Their Bills, More Are Also Cut Off For Nonpayment [Cost Increases Due To Natural Gas Price Spikes]
-- PA Physicians For Social Responsibility Host Feb. 22 Webinar On Radioactive Contaminants From PA Oil And Gas Operations [PaEN]
-- Better Path Coalition To Host Feb. 22 Webinar On How Green Is Blue Hydrogen? Made From Natural Gas [PaEN]
[Posted: February 8, 2023] PA Environment Digest
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