PA Environment Digest Blog: DEP Issued At Least 472 Violations To 90 Conventional Oil & Gas Operators; 20 NOVs To 10 Shale Gas Operators For Abandoning Their Wells Without Plugging Them So Far In 2023

The Department of Environmental Protection has issued at least 472 notices of violation to 90 conventional oil and gas operators and 20 NOVs to 11 shale gas operators for abandoning their wells without plugging them so far in 2023, according to DEP’s Oil & Gas Compliance Reporting Database.

Just one conventional operator-- John B. Best-- was issued 64 notices of violation for abandoning conventional wells. John B. Best has 166 conventional wells registered in his name. [Read more here.]

Other conventional operators with 10 or more NOVs for abandoning wells include-- Diversified Prod LLC [36 NOVs]; Apollo Resources LLC [31 NOVs]; Dannic Energy Corp [19 NOVs]; The Production Co. LLC [22 NOVs]; Prosperity Oil Co. Inc. [21 NOVs]; EQT Gathering of PA LLC [12 NOVs]; Michael Harju [12 NOVs]; Medina Res. Dev. Co LLC [10 NOVs]; Pennfield Energy [10 NOVs]; Timberline Energy, LLC 10 NOVs].

The counties with the most abandoned, unplugged conventional wells issued NOVs so far in 2023 include: Venango (101), Westmoreland (74), Fayette (50), Washington (30), Erie (35), Allegheny (22), Greene (20), Warren (17), Beaver (13), Butler (12), Indiana (11) and Clearfield (11).

Shale Gas Abandoned Well NOVs

DEP also issued notices of violation to 10 unconventional shale gas operators for abandoning wells without plugging them on 11 well pads--

-- Chesapeake Appalachia, Inc: Stoorza Well Pad, Terry Twp., Bradford County;

-- EQT Chap LLC: Basista-Dermotta Well Pad, Sewickley Twp., Westmoreland County:

-- EQT Prod Co.: Phoenix Well Pad, Duncan Twp., Tioga County;

-- Frontier Natural Resources: Winner Well Pad, Keating Twp., Clinton County;

-- M4 Energy LLC: Triana Young Well Pad, Hector Twp., Potter County;

-- Penn View Exploration: Huff Well Pad, Franklin Twp., Butler County;

-- Roulette Oil & Gas, Inc.: Guardian Well Pad, Hebron Twp., Potter County;

-- Seneca Resources Co. LLC: LEH WT2973 Well Pad, Shippen Twp., Cameron County;

-- West Texas Operating Co.: Hillegass Well Pad, Stonycreek Twp., Somerset County;

-- XTO Energy, Inc.: Patton Well Pad, Prospect Borough, Butler County; and

-- XTO Energy, Inc.: Hall Well Pad, Springfield Twp., Fayette County.

DEP Just Started Plugging 100th Well This Year

On October 18, the Department of Environmental Protection announced it had just started to plug its 100th abandoned conventional oil and gas well this year. [Read more here.]

DEP has projects to plug 135 conventional abandoned oil and gas wells underway and have plugged 90 conventional wells with new federal funding from the Bipartisan Infrastructure Act. [Read more here.]

Gov. Josh Shapiro said at the October 18 event stronger laws are needed to hold conventional well operators responsible for their “legacy of corporate greed … of an industry that just simply got away with abandoning wells for far too long.” [Read more here]

A DEP report issued in December 2022 with more complete information that found between 2017 and 2021 DEP issued 3,123 notices of violation for abandoning conventional wells. [Read more here] The NOVs covered 2,246 conventional wells. [Read more here]

DEP’s newly released 2022 Oil and Gas Program Annual Report said conventional operators were issued 671 notices of violation in 2022 for abandoning wells without plugging them.

DEP’s 2021 Oil and Gas Program Annual Report said the agency issued 610 notices of violation to conventional operators for abandoning wells without plugging them.

In the two prior years, DEP issued 360 NOVs in 2019 and 453 in 2020 to conventional oil and gas operators for the same offense.

DEP’s December report said the conventional oil and gas industry had a “culture of non-compliance” and recommended a series of steps to better enforce existing laws against conventional operators abandoning wells. [Read more here]

The report recommendations include--

-- Develop and issue a standard order whenever a notice of violation is issued for abandoning or failing to plug a well.

-- Develop and issue a standard bond forfeiture notice to go with the order for abandoning or failing to plug wells to begin the forfeiture process where bonds exist.

-- Develop and issue a standard penalty assessment for abandoning or failing to plug a well to collect civil penalties.

-- Deny additional well permits, block permit transfers and suspend permits if these orders are violated or if other significant non-compliance occurs.

-- Develop and issue a standard lien on property for failure to pay penalty assessments or court judgements.

-- Tighten requirements for permit transfers and designating wells as inactive to avoid setting up circumstances where wells can be more easily abandoned.

Developing standard documents will save DEP staff time and legal review before they are issued, meaning the whole process is much quicker than it is now.

The report also notes DEP can refer oil and gas operators to the Office of Attorney General or county District Attorney for criminal enforcement and should “consider referral of appropriate cases to the Office of Attorney General for criminal prosecution under the environmental statutes.” [Read more here]

Unfortunately in 2022, the General Assembly passed and Gov. Wolf signed into law legislation that prevents DEP from increasing well plugging bonding amounts for 10 years for new conventional wells to what it would cost taxpayers to plug those wells if operators walk away. [Read more here.]

In May, Democrats on the House Environmental Resources and Energy Committee reported out House Bill 962 (Vitali-D-Delaware) to restore DEP’s authority to review conventional oil and gas well plugging bonding amounts to help prevent the routine conventional well abandonments. [Read more here]

The bill was Tabled with no action in July.

Current state law also exempts conventional wells drilled before April 18, 1985 [which is most of the 350,000 wells] from having any bonding at all to cover plugging.

By some calculations, state taxpayers are on the hook for over $5.1 billion in well plugging liabilities, between the fact pre-April 1985 wells are not required to have any plugging bonds and the inadequate bond amounts we have now. [Read more here.]

As the 2023 compliance numbers show, as incomplete as they are, conventional oil and gas well abandonment is still a pervasive practice in the conventional industry. [Read more here]

Conventional Operators Issued NOVs

The following 90 conventional oil and gas operators were issued notices of violation for abandoning and failing to plug their wells--

Alpha Wells Inc.

American Natural Resources

Apollo Resources LLC [31 NOVs]

Armac Resources LLC

BCD Prop, Inc.

Bialy Gas Production LLC [13 NOVs]

BV Gas LLC

Bear Lake Prop LLC

Bemorich, Inc.

Best, John B. [64 NOVs]

Big Dog Energy

Blackrock Enterprises

C&S Resources, Inc.

Cedar Valley Energy, Inc.

Chestnut Ridge Energy of PA, Inc.

Cobra Resources LLC

Dannic Energy Corp [19 NOVs]

Dev Well, Inc.

Diamond Energy Partners

Dietterich, Randy A.

Dietz Gas & Oil, Inc.

Diversified Prod LLC [36 NOVs]

DJW Enterprises

Eastern Gas Transmission & Storage, Inc.

EQT Gathering of PA LLC [12 NOVs]

EQT Prod Co.

EXCO Resources PA, Inc.

First American Energy

Five Star Investment Group

FM Sloan, Inc.

Fortress Energy Corp

Fyrerock Reservoir Consulting

Go Energy LLC

H&S Gas & Oil

Hyde Park Foundry

Iron PA Land LLC

Jeanne B. Plementosk & A&M Zinchiak

K Petroleum, Inc.

Kenic Gas & Oil, Inc.

Kennedy Fuels, Inc.

Keystone Land Resources

Knoll, John E.

L&B Energy LLP

Langer, Raymond D.

Leatherwood LLC

Manufacturers Light & Heat Co.

Marco Drilling, Inc.

Medina Res. Dev. Co LLC [10 NOVs]

Michael Harju [12 NOVs]

Naser, William L.

Niche Energy, Inc.

Northeast Consolidated Energy Partners

Northwestern Well SVCS

Nucomer Energy LLC

OWS Acquisition Co. LLC

PPP Future Dev. Inc.

Pecora Enterprises

Pennfield Energy [10 NOVs]

Penn View Exploration

Peoples Natural Gas Co.

Petro Erie, Inc.

Prosperity Oil Co. Inc. [21 NOVs]

Puma Energy

Questa Petro Co.

Range Resources Appalachia

Rannuff Oil & Gas Co.

Reel Resources

Rice Drilling B LLC

Riverstone Farm

Roulette Oil & Gas LLC

Schenker, John

Schrecengost, Fred M.

Schreiner Oil & Gas

Southwell, Russell C.

Stedman Energy, Inc.

Steele Molnar Holdings

STK Resources LLC

Stonehaven Energy MGT

Suchko, Andrew F.

T&F Exploration, LP

Tatonka Oil Co. LLC

The Production Co. LLC [22 NOVs]

Timberline Energy, LLC 10 NOVs]

Tunnel Ridge LLC

Turm Oil, Inc.

Utica Resources

West Silas

West Texas Operating Co.

Report Violations

To report oil and gas violations or any environmental emergency or complaint, visit DEP’s Environmental Complaint webpage.

Check These Resources

Visit DEP’s Compliance Reporting Database webpage to search their compliance records by date and operator and the Inspection Reports Viewer.

Sign up for DEP’s eNOTICE service which sends you information on oil and gas and other permits submitted to DEP for review in your community.

[Note: The 2023 numbers are not complete due to the way DEP keeps adding inspection reports to its Oil & Gas Compliance Reporting Database. The database does not indicate if or how these violations were resolved.]

[Note: If you believe your company was listed in error, contact DEP’s Oil and Gas Program.]

[Note: These may not be all the NOVs issued to oil and gas companies during this time period. Additional inspection reports may be added to DEP’s Oil and Gas Compliance Database.]

Resource Links - Well Abandonment:

-- DEP Report Finds: Conventional Oil & Gas Drillers Routinely Abandon Wells; Fail To Report How Millions Of Gallons Of Waste Is Disposed; And Non-Compliance Is An ‘Acceptable Norm’ [PaEN]

-- House Hearing: Let’s Work Together To Make Conventional Oil & Gas Industry Practices Cleaner, Respect Property Rights, Protect Taxpayers And Prevent New Abandoned Wells [PaEN]

-- EDF: Pennsylvania Has 55,000 Oil/Gas Wells At High Risk Of Being Abandoned; 51,000 Wells At Risk Of Being Transferred To Low Solvency Owners; Current Conventional Well Owners Abandon 561 Wells A Year, On Average [PaEN]

-- EQB No Longer Has Statutory Authority To Change Conventional Oil & Gas Well Bonding Amounts To Help Prevent 400 to 600 New Well Abandonments A Year; Adopts Proposed Changes To Water Quality Standards For Comment [PaEN]

Special 2023 Oil & Gas Compliance Reports:

-- DEP Issued At Least 472 Violations To 90 Conventional Oil & Gas Operators; 20 NOVs To 10 Shale Gas Operators For Abandoning Their Wells Without Plugging Them So Far In 2023 [PaEN]

-- DEP Issues Record 5,653 Notices Of Violation To Conventional Oil & Gas Operators So Far In 2023; ‘Culture Of Non-Compliance’ Continues [PaEN]

-- Shale Gas Operators On Track To Have More Violations In 2023 - Frozen Gas Infrastructure; Explosion; Pad Fire; Uncontrolled Gas Venting; Frack Outs; Major Spills; Pipeline Crashing Thru A Home Highlight 2023 So Far [PaEN]

Weekly PA Oil & Gas Industry Public Notice Dashboards:

-- PA Oil & Gas Weekly Compliance Dashboard - Nov. 11 to 17 -- 37 Conventional Abandoned Wells; 1,260+ Shale Gas Spill; 1,000 Gallon Conventional Oil Spill In State Park; Rager Mtn Gas Storage Still Not Cleaned Up [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - November 18 [PaEN]