On January 5, the Department of Environmental Protection reported their inspections found 4,386 violations of environmental regulations at conventional oil and gas operations during 2021-- nearly two and a half times the violations reported just two years ago in 2019 and 337 more than in 2020.

The number of conventional violations is the largest on record-- at least since 2013.

Attempting To Abandon Unplugged Wells

Of significant concern is the fact that conventional oil and gas drillers were hit with 813 notices of violation over two years for failing to plug an oil or gas well before they abandon them-- 360 in 2019 and 453 in 2020.

Pennsylvania already has hundreds of thousands of conventional oil and gas wells that were abandoned or orphaned and left to taxpayers to clean up.

Plugging wells to stop the vertical flow of fluids and gas is critical to preventing ground and surface water contamination and the release of climate-changing methane gas into the atmosphere.

Some examples of the companies receiving notices of violation for failing to plug wells before the abandon them are--

-- Cameron Energy:  2 violations- one in 2020, another in 2016;

-- Energy Resources Of America: 22 notices of violation since 2015;

-- Pennfield Energy: 6 notices of violation in 2021, 1 in 2018;

-- LT Oil Company: There were 6 violations in 2020;

-- Stedman Energy: There were 2 violations in 2021, and one in 2017.

-- Vista OPR Inc.: There were 2 violations in 2017;

-- Howard Drilling: There was 1 violation in 2015;

These companies also reported road spreading their oil and gas well wastewater.  [Read more here.]

Inadequate Bonding To Begin With

The bonding requirements in DEP’s regulations covering conventional oil and gas operations are also out-of-step with the actual taxpayer cost of plugging wells. 

The Pittsburgh Post-Gazette reported DEP has less than $15 per well available to plug the over 100,500 active conventional oil and gas wells in Pennsylvania.

And current state law doesn’t require any oil and gas wells drilled prior to April 18, 1985 to have any plugging bonds-- which is the overwhelming majority of the 190,828 conventional permitted wells in the Commonwealth.

In November, the Environmental Quality Board accepted a petition to increase the bonding amounts for both conventional and unconventional oil and gas wells to the cost taxpayers would have to pay to plug them if abandoned by drilling companies.  [Read more here.]

Failure To Report Waste Generated

Conventional oil and gas drillers were also given 836 notices of violation for failing to submit annual production and waste reports for the last two years-- 134 in 2019 and 702 in 2020. 

The production reports include critical information on the type and amount of solid waste and wastewater they produce and how it is being disposed of, treated or recycled, from each well they own.

Examples of production/waste reporting issues include--

-- Cameron Energy: While DEP did not report notices of violation for waste reporting, the odd thing about the company’s waste reports in 2020 was regardless of location of the 381 wells, the company reported road spreading either 0.87 barrels or 0.41 barrels of wastewater per well. There was the same sort of “uniformity” among reporting how waste was disposed in other disposal categories as well.  [Read more here.]

-- Pennfield Energy: Did not submit any waste reports for 2017, 2018, 2019, 2020, although DEP did issue 2 notices of violation for 2 wells in 2021.  [Read more here.]

-- River Ridge Gravel Company: 10 notices of violation in 2021;

-- Stedman Energy: 6 notices of violation in 2017;

-- LT Oil: 6 notices of violation in 2020;

-- L & B Energy: 5 notices of violation in 2017; and

-- Elder Oil & Gas: 1 notice of violation in 2015.

These companies also reported road spreading their oil and gas well wastewater.  [Read more here.]

While this waste reporting requirement is very weak, without even this information DEP has no idea how much waste is being produced and how it is being managed in thousands of wells.

A recent report by the Better Path Coalition documented the many weaknesses in DEP’s waste reporting system for conventional oil and gas operators and the fact it does not track waste “cradle to grave.”  [Read more here.]

Other Violations

While the breakdown of the specific kinds of violations is not available yet for 2021, DEP’s 2020 Oil and Gas Program annual report found these other major violations at conventional oil and gas operations--

-- 667 violations in 2020 for not submitting annual oil and gas well mechanical integrity reports to determine whether a well is leaking or not (70 violations in 2019);

-- 75 violations for failing to operate a well to ensure its integrity;

-- 90 violations for managing residual waste without a permit or approval;

-- 77 violations for failing to collect wastewater and prevent discharges into ground or surface waters; and

-- 56 violations for failing to dispose of liquid and solid waste in a manner that prevents pollution.

Compliance information for these and other violations can be found on DEP’s Oil and Gas Compliance webpage.  Copies of inspection reports and related information is available on DEP’s Oil & Gas Report Viewer webpage.

Compliance information across DEP programs is available for companies by name or facility on DEP’s eFACTS Compliance Tracking System webpage.

Violation Trends

Note the general trend in the number of violations by conventional oil and gas drillers has been generally going up the last few years.

Click Here for a copy of the 2021 report.  Click Here for a copy of the 2020 report.  Click Here for the 2019 report.

For much more information, visit DEP’s Office Of Oil & Gas Management webpage.

Related Article This Week:

-- DEP Proposes New, Limited General Permit For Processing, Beneficial Use Of Oil & Gas Liquid Wastes; No Chemical Concentration Limits Or Public Review Of Individual Permit Uses Are Included

-- PA Professional Geologists: Feb. 16 Webinar: Dust Suppression With Oil & Gas Produced Water Featuring Author Of Penn State Study Finding Increased Cancer Risks With Road Spreading.  1:00 to 2:00 p.m.

-- DEP Opportunity To Bid On Plugging 7 Orphan Oil & Gas Wells In Warren County

Related Articles - Last Week:

-- Sign Better Path Coalition Petition: DEP - Keep ALL Oil & Gas Wastewater Off Our Roads!

-- Better Path Coalition Presents Jan. 12 Webinar On Road Spreading Drilling Wastewater, Why Hasn't It Stopped?

-- DEP Draft Rule Does Not Ban Road Spreading Of Conventional Oil & Gas Wastewater; Industry Objects To Waste Reporting Provisions

-- Conventional Oil & Gas Well Drillers Press DEP To Reduce Environmental Safeguards For Drilling And Treat Them The Same As Wind, Solar Energy Facilities

Related Articles:

-- Millions Of Gallons Of Conventional Oil & Gas Wastewater Spread Illegally On Dirt Roads, Companies Fail To Comply With DEP Waste Regulations

-- Better Path Coalition Report: How To Close The Loophole Allowing Uncontrolled Road Spreading Of Conventional Oil & Gas Wastewater & Fix Oil and Gas Waste Reporting System

-- DEP Lists 84 Townships As ‘Waste Facilities’ Where Conventional Oil & Gas Wastewater Has Been Disposed Of By Road Spreading; Municipalities Need To Do Their Due Diligence

Road Spreading Archive:

-- PA Environment Digest: All Road Spreading Conventional Oil & Gas Wastewater Articles

[Posted: January 10, 2022]

1/17/2022