Tuesday, January 24, 2023

DCED’s Conventional Oil & Gas Drilling Advisory Council Meets Feb. 16

PA Grade Crude [Oil] Development Advisory Council is scheduled to hold a hybrid meeting February 16 at the Pennsylvania Western University campus in Clarion.

The agenda for the meeting has not been announced, but the December 15 meeting canceled due to weather was to include these topics--

-- Final regulation limiting VOC/methane emissions from conventional oil and gas facilities [See below];

-- Presentation on radioactive material in drilling wastewater by a consultant-- Perma-Fix Environmental Services;

-- 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.

First Conventional Industry Compliance Review

Another possible agenda item is the first-ever assessment of how well conventional oil and gas drillers comply with state environmental laws DEP released on December 29.  Read more here.

The report 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.

Background On Agenda Items

Here is some background on the possible agenda items.

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.

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.”

[Note: One of the three studies was 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.

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.  The meeting will also be available by telephone-- +1 267-332-8737, Conference ID: 391 110 544#

Click Here for more information as it becomes available.

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 - Jan. 14  to 20  [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - Jan. 21  [PaEN]

PA Oil & Gas Industry Compliance Reports:

-- 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’

-- 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]

-- PA Oil & Gas Industry Has Record Year: Cost, Criminal Convictions Up; $3.1 Million In Penalties Collected; Record Number Of Violations Issued; Major Compliance Issues Uncovered; Evidence Of Health Impacts Mounts


-- StateImpactPA - Rachel McDevitt: PA Conventional Oil & Gas Drillers Abandoned Thousands Of natural Gas Wells In 5 Years, Ignored State, Law Report Says

-- Center For Coalfield Justice Blog: DEP Reports Conventional Oil & Gas Industry Has A Culture Of Noncompliance Not Likely To Change Soon, More Resources, Updated Regulations Needed

-- Bob Donnan’s Blog: UPMC, Allegheny Health Network Promote Natural Gas Despite Known Health Risks 

-- E&E News: Natural Gas Pipelines Explode - How Far Away Is Enough To Survive?  [National Transportation Safety Board Says Current Blast Zone Significantly Underestimates The Danger]

-- TribLive Letter: EPA Must Protect Our Children Against Oil & Gas Facility Methane Emissions - By Moms Clean Air Force

-- Beaver County Marcellus Awareness Community  Feb. 1 Monthly Eyes On Shell Meeting. 7:30 p.m.

Related Articles This Week:

-- Natural Gas Industry, Senate Republicans Launch Effort To Unleash The Industry, Reduce Regulation, Call For Automatic Approval Of Permits, Limit Public Comments  [PaEN] 

-- Center For Coalfield Justice Blog: DEP Reports Conventional Oil & Gas Industry Has A Culture Of Noncompliance Not Likely To Change Soon, More Resources, Updated Regulations Needed

-- FracTracker Alliance Seeking Information On Use Of Drones For Environmental Monitoring Work; Feb. 3 Online Meeting Set On Oil & Gas Facility Monitoring Project  [PaEN]

[Posted: January 24, 2023]  PA Environment Digest

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