Ohio Hydrocarbon Production Well Inspections and Violations

Inspections and Violations in Ohio

Only a few states in the U.S. currently release free violations data related to unconventional oil and gas drilling. The Ohio Department of Natural Resources (ODNR) maintains an inventory of well inspections and violations within its RBDMS database. We examined and mapped their data with a focus on hydrocarbon (oil and natural gas) production wells and relevant Class II Injection1 wells – where the high volumes of liquid wastes produced during hydrocarbon extraction are often disposed of, deep within the earth.

By the Numbers

As of January 2013 there were a total of 5,954 hydrocarbon well inspections and 956 “True” violations. “True” violations refer to those inspections that were deemed to be in violation of the Ohio Revised Code (OAC) Chapter 1501:9-3 Saltwater Operation or Chapter 1501:9-1 Oil Well Drilling.  Violations and/or inspections tend to fall under a couple of categories including compliance notices, neighbor phone call, or routine field visits or inspections. There have been 470 and 430 “Complaint” and “Request” based inspections to date, respectively (Table 1).

This graph depicts monthly and cumulative Ohio hydrocarbon production well inspections and ODNR deemed "True" violations between September 2010 and January 2013.

Figure 1. Cumulative OH hydrocarbon production well inspections & ODNR determined true violations (Sept 2010 – Jan 2013)

The ratio of inspections to violations issued over time in Ohio has been somewhat variable, but a trend does seem to be slowly emerging. At the present time average hydrocarbon well inspections are increasing by 7 per month, while true violations are only increasing by 0.5 per month (Figure 1)2. Thus, the ratio of inspections-to-violations declined from its September 2010 high of 13.2 to 3.1 in February 2011. This ratio, however, began to rise shortly thereafter.

Assuming the current trajectory holds, the next ODNR RBDMS update should report approximately 11,696 inspections as of the end of January 2014 and more than 48,000 total inspections by January 2018. This trajectory dictates that we will see roughly 1,500-1,600 true violations by January 2014 and approximately 4,500 by January 2018.

Map Description

The map below displays a monthly updated inventory of Ohio’s hydrocarbon and relevant injection well-related violations. This map will be updated monthly around the 25th of each month. We have established fixed search criteria for the RBDMS Microsoft Access database, which is updated weekly. Inspection purposes include general complaints, civil action, compliance agreement, and criminal actions, while there are myriad inspection descriptions (Table 2).

To view the legend, metadata, and map fullscreen click on the arrows in the top right hand corner of the map.

Inspection Data Availability and Analysis

Significant data gaps exist with respect to latitude-longitude across Ohio’s current inventory of Class II and hydrocarbon well inspections (Note: Data is only available up to February 2013). Below we have analyzed the current gap between “Total” inspections and those “w/Latitude-Longitude” data. We are currently working to close these gaps. The largest gap exists for the “Salt Water Injection Wells All Time” (i.e., Hydraulic Fracturing Waste Class II’s) data with only 3.5% of all inspections accompanied by latitude-longitude coordinates.

Production Wells

  • Pre 9/1/2010 (i.e., First Ohio Utica Permits)
    • Total: 63,707
    • w/Latitude-Longitude: 24,912
    • 39% coverage
  • Post 9/1/2010 (i.e., First Ohio Utica Permits)
    • Total:  13,735
    • w/Latitude-Longitude: 5,917
    • 43% coverage

Salt Water Injection Wells All Time

  • Total: 11,939
  • w/Latitude-Longitude: 413
  • 3.5% coverage

Annular Disposal + Enhanced Oil Recovery + Orphan + Solution Mining Project + Storage Well

  • Total: 15,694
  • w/Latitude-Longitude: 5,300
  • 33.8% coverage 

Tables

The primary columns of importance to the public in the tables below are “Inspection Purpose”, “Inspection Description”, and “Notification Type.” Eighty-three percent (83%) of the state’s production well inspections were for what seem to be routine “Status Checks.” With respect to notification type, most were categorized as “Unknown” (Tables 1 and 3).
Table 1. Ohio production and Class II injection well Inspection Purposes

Code

Definition

Number of Inspections

C

Complaint

470

CAF

Civil Action Follow-up

4

CMF

Compliance Agreement Follow-up

4

NMF

Notice of Material or Substantial Follow-Up

2

NVF

Notice of Violation Follow-Up

99

OF

Order Follow-Up

4

R

Request

430

SC

Status Check

4,802

Unknown

3

Table 2. Ohio production and Class II injection well inspection descriptions

Description

Failure to maintain record of pipeline location

Inadequate pipeline strength

Failure to properly bury pipeline

Well operation causing pollution and contamination

General Safety

Well insufficiently equipped to prevent escape of oil and gas

Failure to legibly identify well

Violation of tank spacing requirements

Violation of tank fire heater spacing requirements

Unattended portable heater less than 50 feet from  tank

Violation of separator spacing requirements

Operating tank heater while oil is being produced

Improperly located oil tank

Equipment pressure rated below operating pressure

No SPCC dike/or failure to keep dike free of water or oil

Unlawful venting or flaring of gas

Failure to have required locks, bull plugs

Well incapable of production

Illegal/Unauthorized annular disposal of brine

Unlawful method of storage or disposal of brine

Dike or pit not able to prevent brine escape

Unlawful use of pit for temporary brine storage

Use of pit of dike for ultimate disposal of brine

Disposal of muds or cuttings in violation of a rule

Failure to keep dike or pit free of brine / other wastes

Illegal/Unauthorized annular disposal of brine

Non registered operator/ Bond/ Insurance

Table 3. Ohio production and Class II injection well notification types

Code

Definition

Number of Inspections

CN

Compliance Notice

470

FVI

Field Visit or Inspection

225

LET

Informal Letter

2

NOV

Notice of Violation

74

OTH

Other Notification

8

PHN

Phone Call

225

Unknown

4,810

 


Endnotes

1. Relevant Class II wells include Salt Water Injection, Annular Disposal, Enhanced Oil Recovery, Orphan, Solution Mining Projects, and Storage Wells

2. If we remove the first month of 2013, the former increases to 9 per month and the latter 0.8 per month.

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