Marcellus Shale Advisory Commission Report Released

Yesterday, the Governor’s Marcellus Shale Advisory Commission, lead by Lieutenant Governor Jim Cawley, released a 137 report of their recommendations, which is available at the Post-Gazette website. The Commission, composed of industry and state government officials, came up with almost a hundred recommendations, including some controversial items such as a drilling “impact fee”, as well as forced pooling.

Take a look at the document linked above, and let us know what you think about it.

Paid Marcellus Programming to Play in West Virginia

Who doesn’t love a good half hour commercial? But it’s not just for OxiClean and musical compilations of 70’s disco tunes anymore–the West Virginia Oil and Natural Gas Association is getting in on the act too.

In addition to the half hour weekly episode of “Inside Shale”, in which callers ask questions of industry insiders, there will be a “Marcellus Minute” that airs 10 to 20 times per day. Both programs are scheduled to launch on 49 radio stations throughout West Virginia.

Talking about the Marcellus Shale on the radio is certainly not off limits, but the industry sponsored call in show does sound questionable, in that the format mimics a news format, and it could be confused as such.  It’s a shame that the industry didn’t push for actual moderated discussions, with guests arguing from a variety of perspectives.  That is something that there’s a real need for, not just in West Virginia, but wherever shale gas extraction is occurring.

There are real impacts of drilling.  Some people are giddy with prospective royalty checks.  Others are bitter with the presence of compressors, condensers, and fouled water wells on property that they own, but not the mineral rights for.  There’s a lot to talk about, and communities that might be affected by the industry deserve to hear both sides.

2000 to 2010 Non Marcellus Waste Data

Yesterday, I provided our readers with a summary of long term non Marcellus Shale production data, which is self reported by the industry to the Pennsylvania Department of Environmental Protection (DEP). The DEP has recently made this information available retroactive to 2000, at least for oil and gas wells not drilled into the Marcellus Shale.

The following charts show the total reported waste for non Marcellus Shale wells over time, from 2000 to 2010.

Non Marcellus Shale brine production in Pennsylvania: 2000 to 2010
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Historical Production and Waste Data Added to DEP Site

Recently, the Pennsylvania Department of Environmental Protection Bureau of Oil and Gas Management has added historical oil and gas production and waste data for non Marcellus Shale wells. This data is now available as far back as 2000.

I’ve made a couple of charts to illustrate production values for these wells over time.

Gas production per year, in billions of cubic feet (Bcf)
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Five Month Oil and Gas Inspection Data

Between January and May 2011, the Pennsylvania DEP conducted 977 inspections on oil and gas operations, issuing 1,751 violations to drilling and pipeline operators, and 311 enforcement actions. These totals are for all oil and gas operations, including the Marcellus Shale.

Most inspections by operator, January – May 2011

Two of these entries are similar:  “Incomplete Data” and “Unknown Operator”.  All but one entry listed as having an unknown operator involved failing to plug and abandoned well, and was issued either on the 17th or 18th of February.  Everything else where the operator is unknown is listed as “Incomplete Data”.

Most violations by operator, January – May 2011

Although this particular analysis does not include details about the wells which were flagged for violations, many of the operators on this list are focused on Marcellus Shale operations in Pennsylvania, including Cabot, Chief, Chesapeake, Anadarko, Range, and XTO.  In May, I discussed how there was little overlap between Marcellus and non Marcellus drillers. At that point, the distribution of the only seven companies that drilled one or more of each kind of well in Pennsylvania was as follows:

Operators with at least one Marcellus Shale and non Marcellus Shale well between January 1 and May 18, 2011.

Most enforcement actions by operator, January – May 2011

I’m not sure what the point of issuing an enforcement action is when the well operator is not known.  There are 187 rows of incomplete data, detailing 178 violations, and 55 enforcement actions.  The following columns are missing data for every single row:  operator, permit number, county, municipality.  It does, however, include penalty amounts issued and total amounts collected, which means that the DEP does have information about at least some of these wells, they just neglected to share it with the rest of us.

Most violations per inspection by operator, January – May 2011

The list of most violations per inspection is dominated by small, non Marcellus Shale operators, with relatively few inspections.

Most enforcement actions per violation by operator, January – May 2011

Similarly, the companies with the most enforcement actions per violation involve those with relatively low sample sizes.

It isn’t clear to me though, what constitutes an enforcement action, and when such an action is deemed appropriate.

Land of Confusion

The last time I checked on Consol, for example, they had no violations.  This time, not only is there a violation, but an enforcement action as well.  That doesn’t mean that they were given a fine, however–their enforcement description reads, “Notice of violation”.  And yet, according to the report, there are 1,751 violations issued but only 311 enforcements, or roughly 18 percent.  So when do they get the enforcement of “Notice of violation”?

Curious.  But it gets more confusing than that.  Although there are only 311 enforcements, there are 729 instances of “notice of violation”, 43 counts of “administrative orders”, 48 instances of “consent assessment of a civil penalty”, and “consent order and agreement” came up four times.  That totals 824 enforcement descriptions for only 311 enforcements.

How can this be?

This is an example of what the violations report looks like.  The report is set up so that a particular inspection is listed just once, even thought there might be multiple violations that occurred as a result, as is the case for rows 1048-1050.  Additionally, multiple violations from different inspections might be covered by the same enforcement ID, as is the case for rows 1058-1065.  Although not shown here, there are also instances where the same Violation ID is used more than once, non consecutively.

PA Oil and Gas Violations:  Jan-May 2011 (large)
Location of oil and gas violations in PA, January to May, 2011. Click the “i” icon then any map feature for more information.

From my perspective, each row of data should be complete, not only because it is needed for our DataTool to associate all of the information with each map feature, but it also allows for looking deeper into the patterns of where the problems are.

For example, how many of the violations were for non Marcellus Shale wells? The report itself doesn’t say, although there is a separate Marcellus-only report, so you could subtract the total of that from the overall list. But what about horizontal wells? What if you want to know which companies have the worst record at certain types of violations? What if you want to compare the number of violations issued on a monthly basis?

Violations issued by month, January – May, 2011. Values are between 4 and 6 percent overstated on average.

If you want to dig deeper, there is no choice but to fill in the blanks. When I did that for this five month period, however, the values for violations were increase by between four and six percent over the totals that the DEP provided, due to the factors stated above.  While that may be a tolerable difference, the same process increases the number of enforcements by 165 percent.  Both of these inflated numbers represent actual events.  The differences arise more from the standpoint of how violations and enforcement actions are applied.

I applaud the DEP for releasing its oil and gas violation and inspection data so willingly and so thoroughly.  At the same time, it could certainly stand to be simplified.  As it stands, it isn’t enough to proclaim that “Operator A has seven violations” without answering whether there are any blanks in the data to be filled in, or whether any of the violations included multiple enforcement actions.

Dr. Christen to serve as Executive Director of PATF

Please join us in congratulating Dr. Charles Christen for his appointment as Executive Director of the Pittsburgh AIDs Task Force (PATF). PATF, the oldest and largest AIDS service organization in Southwestern Pennsylvania, is dedicated to supporting and empowering all individuals living with HIV/AIDS, as well as preventing the spread of infection. PATF is a leader in providing comprehensive support services that improve the health and quality of life for those living with HIV/AIDS in the following counties: Allegheny, Armstrong, Beaver, Butler, Greene, Fayette, Indiana, Washington, and Westmoreland.
Dr. Christen joined the Center for Healthy Environments and Communities (CHEC) as the Director of Operations in 2008. He has a doctoral degree from the Department of Behavioral and Community Health Sciences of the University of Pittsburgh Graduate School of Public Health, and a certificate in LGBT Health Research. Dr. Christen has an extensive background in HIV service, as well as a developing expertise in community based environmental health practice.

The Pittsburgh Aids Task Force is very fortunate to have Dr. Christen as their new leader. During his time at CHEC, Dr. Christen has demonstrated superb skills, most importantly the manner in which he develops close working relationships with community organizations. While it will be difficult to replace Dr. Christen as a dedicated employee, his responsiveness to environmental health issues and passion for fulfilling the University’s role in supporting community needs will be a legacy upon which we will build.

Dr. Christen’s last day with CHEC will be July 15, 2011. An active search for his successor is under way.