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.

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.

One of the biggest concerns about the Marcellus Shale industry in Pennsylvania is how to deal with all of the waste products that are created in the drilling, stimulation, and production of the wells. There are also more than 40,000 oil and gas wells from other formations in the Commonwealth that reported waste production to the Pennsylvania Department of Environmental Protection (DEP) last year. Whether this waste ultimately found itself into publicly owned treatment works, industrial waste treatment facilities, injection wells, or spread on roadways, it almost always has to be shipped to a different location, sometimes hundreds of miles away.

For more information on specific facilities that accepted non Marcellus waste in 2010, click on one of the maps below, then use our information tool (“i” icon) and click on any map icon.

Brine

Yellow dots indicate wells that reported brine production, and red squares are receiving facilities. The green lines are the paths that the waste takes, as the crow flies. Darker lines indicate larger quantities of brine, which are measured in barrels. For more information on specific features, please click the map for a zoomable, dynamic view.

Statewide, almost 4.5 million barrels of brine was produced by non Marcellus Shale wells in 2010, which was transported over 900,000 miles as the crow flies(1) from the various wells to the facility locations, with an average one way trip of about 30 miles.

Facilities accepting the most brine from non Marcellus wells in PA in 2010

Drill Cuttings

Only one operator reported drill cutting waste from a total of three wells. All of this type of waste went to the same facility. Geographic coordinates were not included for the receiving facility in the data, so mapping and distance measurements were not performed for this analysis. Suffice it to say, however, that the amounts discussed are relatively small compared to brine and other types of waste.

Facility accepting drill cutting waste from non Marcellus wells in PA in 2010

Drilling Fluid

The color scheme for this map similar to that of brine, above, but in this view, yellow dots indicate wells producing drilling fluid waste.

More than 300,000 barrels of drilling fluid was produced last year from non Marcellus Shale wells in Pennsylvania. That waste traveled over 18,500 miles as the crow flies en route to its receiving facilities.

Facilities accepting the most drilling fluid from non Marcellus wells in PA in 2010

Frac Fluid

The color scheme for this map similar to that of brine, above, but in this view, yellow dots indicate wells producing frac fluid waste.

While the term “frac fluid” is often used to refer to the chemical additives that are used along with water and sand to hydraulically fracture a well, in terms of the waste report, it refers to the flowback water. This type of waste contains the other type of frac fluid, but at significantly reduced quantities.

Last year, non Marcellus Shale wells reported producing over 499,000 barrels of frac fluid waste, which traveled almost 82,000 linear miles to receiving facilities, with the average one way trip being about 40 miles in length.

Facilities accepting the most frac fluid waste from non Marcellus wells ion PA in 2010

1. Please note, for each distance analysis, only wells from the waste production report which included decimal degree data for both the wells and receiving facilities were included. Therefore, the distances are being understated. For example, only about 29,500 of the more than 40,500 non Marcellus wells that produced brine last year are included in this figure, or about 73 percent.