Articles

Problems with Abandoned and Orphaned Wells

June 3, 2011/by Matt Kelso, BA

Left: Cabin Run orphaned oil well, Morgan County, Ohio. Many of the older oil and gas wells were either perfunctorily plugged, or else not at all. Right: The Pennsylvania DEP thinks this Bradford Township explosion in McKean County, PA might have been due to a nearby abandoned gas well that was drilled in 1881.

In April of 2000, the Pennsylvania Department of Environmental Protection (DEP) released a plan for dealing with the approximately 8,000 abandoned and orphaned oil and gas wells throughout the Commonwealth. This report singled out 550 wells that were especially problematic, and of those, 129 were flagged as the highest priority, with a point score of 30 or greater on their internal scale.

Eleven years later, there are over 8,500 abandoned and orphaned wells, and 186 with a point score of 30 or greater. Most likely, this increase doesn’t suggest newly abandoned wells so much as the discovery of additional old ones. After all, according to Independant Petroleum Association of America estimates, over 325,000 oil and gas wells were drilled statewide between 1859 and 2000. The DEP has no information on more than half of those wells–about 184,000. Therefore, the actual number of abandoned and orphaned wells in Pennsylvania could be much higher than the estimates provided above.

Abandoned wells are those that have been out of production for a year or more, and orphaned wells are wells that were abandoned prior to 1985, and from which the current landholder or operator didn’t receive any economic benefits. When wells are designated as orphaned, the DEP is responsible for plugging them. As of February, there are 6,251 wells classified as orphaned and 2,272 abandoned wells.

Reasons for Concern

Obviously, the prospects of houses suddenly exploding, as in the picture above, is reason enough to be concerned, and yet there are a variety of ways in which abandoned oil and gas wells can impact Pennsylvania’s environment and the health and well being of our residents. Most unplugged wells release some amount of oil, gas, condensate, or brine, which can kill vegetation, damage fragile riparian ecosystems, and contaminate aquifers. There is also the possibility of injury due to the sudden release of pressure. Some abandoned wells are 30 inch diameter open holes that are obviously a danger for children to fall into.

May 30, 2011 sinkhole in Allentown, PA
There is also the possibility that the presence of wells, whether active or or not, will aggravate unstable geologic formations, which are fairly common in Pennsylvania, due to mining activities in the west and soluble limestone formations in the east. This recent Allentown sinkhole was reportedly caused by a water leak, and caused significant property damage.

To give an example of the potential impact of abandoned oil and gas wells, here are some of the comments from the Abandoned and Orphaned Wells Program, with corresponding point scores:

Comments on abandoned wells and their corresponding point scores.

It is not always clear why a well was given a particular priority rating. Indeed, there are many instances where ratings are zero, but the comments give reason for concern, such as “Oil in water supply” and “Well intact, near implement dealer facility, is a fire hazard.” Additionally, less than 15 percent of the abandoned wells listed give any comment at all.

Incidents in McKean County

Recent explosion incidents in McKean County, PA. Please click on the gray compass rose and double chevron to hide those menus.

The Bradford Township fire mentioned above (the more southern of the two), is about half a mile from the nearest abandoned well on the list. However, the suspected well, Rogers 9, was apparently only 300 feet away. Presumably, this well was not known about until the incident occurred. Rogers 9 was drilled in 1881.

The other incident, in Foster Township, is at the northern edge of a tight cluster of recent drilling activity. It is entirely possible that there are abandoned wells in that region too, but again, nothing is on our list in the immediate vicinity.

This information leads one to suspect that one of the fires was probably due to recent activity, while the other was caused by a long-forgotten well. Whether or not that was the case, it is clear that drilling holes in the earth near where people live can have an adverse effect for a very long time.

Well Plugging

While well plugging technology has obviously improved over the years, that doesn’t necessarily mean that it is always done right. A single $25,000 bond currently is the only insurance that an operator will plug all of their wells statewide, once they are no longer in production. In most cases, that is probably adequate, since there are non-monetary incentives for the operator to stay in good graces with the DEP. However, there are numerous smaller operators with wells still in production, including some residents who have their own private wells.

In these cases, the carrot of getting the bond money returned may not match the cost of plugging the well properly, especially if multiple wells are involved. In this 1998 document, the DEP put the average cost of plugging a well between $6,000 and $22,000. Last year, the DEP plugged 11 wells in Erie County for a cost of $137,348, or a cost of about $12,500 each.

According to the Bradford Era, over 2,700 wells have already been plugged statewide under the program. In McKean County, more than 950 wells have been plugged since 1989, at a cost of over $6.5 million.

As mentioned above, the DEP assumes responsibility for plugging the orphaned wells. The money for this comes from $150 fees added to oil permit applications, and $250 fees for gas permits. Money is clearly a limiting factor in how many wells the DEP can to plug. Those 11 Erie County wells required funds from 550 new gas permits. If those wells represent the average current price for plugging a well, then the 6,251 orphaned wells still on the list would cost over $78 million to plug, requiring the permit fees from 312,550 new wells. And that is still not including the approximately 184,000 abandoned wells that the DEP doesn’t even know about.

Maybe it is time for a new strategy.

Marcellus Shale Violations per Inspection and Enforcements per Violation

May 31, 2011/by Matt Kelso, BA

Please Note

This post is provided for archival purposes only

Marcellus Shale violations issued by the Pennsylvania DEP from January through April, 2011.

Violation information from April was recently posted on the Department of Environmental Protection (DEP) website, and two new violations datasets have been posted on our DataTool as well, including:

As the titles indicate, these datasets contain inspection and enforcement data in addition to violations, which allow us to take a closer look at both violations per inspection and enforcements actions per violation.

Violations per Inspection

Marcellus Shale violations per inspection, 2010. For a dynamic, zoomable view, please click the map.

[map archived]
Marcellus Shale violations per inspection, January through April 2011

In 2010, Marcellus Shale wells in the northeastern portion of the state had a noticeably higher number of violations per inspection than the southwest. This trend is less pronounced so far in 2011. I should point out that since each inspection on this report lead to at least one violation, it is more accurate to think of this category as “violations per inspection yielding violations”, a cumbersome but significant distinction.

Enforcements per Violation

Marcellus Shale enforcement actions per violation, 2010

[map archived]

Marcellus Shale enforcement actions per violation, January through April, 2011

While the northeastern portion of Pennsylvania has a higher number of violations issued per inspection, the southwest has a higher number of enforcement actions, a category which includes fines and other restrictions imposed on drilling operators by the DEP. This trend seems to continue into 2011, with relatively minor changes in distribution.

Data Transparency Bill Will Aid Emergency Response

May 25, 2011/by FracTracker Alliance

Fire in Hopewell Township PA,
Southwestern PA on 3-31-10

Earlier this week, a Pennsylvania Senate committee approved a bill that would require natural gas drilling companies to provide emergency response information to local authorities. Here are the key requirements of drilling companies that are being proposed:

Post emergency response information at each well site
Register distinct geographic coordinates for each drilling site with the PA Department of Environmental Protection and local authorities
File response plans with the local authorities, local 911 center, PA DEP, and PA Emergency Management Agency

Inadequate data transparency of this type has been a significant public health concern ever since natural gas drilling first began in the Marcellus Shale region in PA.Marcellus Shale sites are often drilled in rural, remote areas without exact location information or clear emergency plans. If passed into law, this legislation stands to decrease the response time in the event of an emergency at a well site, reducing the impact that drilling incidents may have on public health and the environment.

To demonstrate why improving the quality and expediency of emergency response to shale gas drilling incidents is an important endeavor, below is a map created on FracTracker’s DataTool showing only the location of violations issued by the PA DEP in 2010 to companies that were drilling into the Marcellus Shale layer. If you press “Click to see more details on this map,” you can use the DataTool to filter the dataset even further in order to see which of these violations was an environmental health and safety violation, not just administrative in nature:

(Darker diamonds indicate there was more than one violation issued in that area. Zoom in to learn more.)

Year to Date Drilling Activity in Pennsylvania

May 18, 2011/by Matt Kelso, BA

Year to date drilled wells in Pennsylvania. Click the map for a larger, dynamic view.

I have updated the 2011 drilled wells information on FracTracker’s DataTool. There are several interesting trends to point out, including:

Percentage of wells from the Marcellus Shale formation
Drilling operator trends
Non Marcellus horizontal well data

Marcellus Shale and Other Formations

So far in 2011, 587 Marcellus Shale wells have been drilled in Pennsylvania, compared to only 281 from other formations. This means that for the first time, Marcellus wells account for over two thirds of the drilling activity statewide.

In less than three and a half years, the Marcellus Shale went from representing 5% of all oil and gas wells drilled in Pennsylvania to 68%.

Drilling trends over time in Pennsylvania.

While part of the reason for the Marcellus Shale’s increased prominence in the oil and gas industry in Pennsylvania is that activity in the formation is rapidly increasing, it is also true that activities in other formations are decreasing rather dramatically.

We can also take a look at drilling activity by county for both Marcellus Shale and other oil and gas wells.

Marcellus Shale and other wells drilled to date in 2011 by county.

Much of the above chart has to do with where the hydrocarbon resources are. It is interesting to note though, that the county with the most Marcellus wells (Bradford) has no wells in other formations, and that the county with the most non Marcellus wells (Forest) has no Marcellus wells at all.

Drilling Operators and the Marcellus Shale

Of the 91 operators that have drilled oil and gas wells so far this year in Pennsylvania, 60 had no Marcellus Shale wells, 25 had only Marcellus Shale wells, and seven had wells in both categories.

Most operators drill in either the Marcellus Shale or other formations, but not both.

There is surprisingly little overlap in this chart. But what about the operators with wells in both categories?

Marcellus and non Marcellus wells for operators with both categories in 2011.

Even still, most of the operators specialize in one kind or the other. Taken together, these two charts show that operators which drill in the Marcellus Shale are specialists, with very few wells drilled in other formations.

Non Marcellus Horizontal Wells

It is well known that the combination of hydraulic fracturing and horizontal drilling techniques allowed for the profitable extraction of natural gas from the Marcellus Shale. For that reason, it isn’t surprising that most of the Marcellus wells are drilled horizontally. What is interesting is that the technique is now being used in other formations as well.

Five Non Marcellus Shale wells have been horizontally drilled so far in 2011.

Non Marcellus horizontal wells so far in 2011.

There isn’t much of a trend in which companies drilled these five wells, with two of the companies active in the Marcellus Shale and two of them not. Spatially, all four of the counties are in the western portion of the state, with Clarion County somewhat to the north of the other three.

2010 Fines for Marcellus Shale Violations

May 16, 2011/by Matt Kelso, BA

In yesterday’s Post-Gazette, Don Hopey discussed an analysis by PennFuture which saw a notable decline in fines in the first quarter of 2011, as compared to the same period last year. The implication is that the DEP is not backing up violations with fines under Governor Corbett’s administration to the same degree that it did under former Governor Rendell. In the former administration, PennFuture calculated an enforcement action was handed out for every 1.7 violations, and now the rate is one per every 8.7 violations.

I think this is a worthwhile trend to keep an eye on, with the caveat that it is still early in Governor Corbett’s tenure, and that violation data varies widely from month to month.

It is also possible that the DEP under the Corbett administration will still issue fines for significant events. In fairness, I came across this article of fines issued over eight months after an incident by the DEP under Rendell. I think we need more time to see if the new administration’s patterns of reduced fines per violation hold.

That said, Marcellus Shale fines and enforcements under the Rendell administration is hardly a sensible target for comparison. The fines issued in 2010 were at once paltry and erratic.

Industry sources indicate that Marcellus Shale wells cost between $5 million to $6.4 million to drill. Last year in Pennsylvania, there were 1,454 Marcellus Wells drilled in the Commonwealth, meaning that the total cost of operations for the year for the industry is somewhere in the mind-boggling range of $7.2 billion to $9.3 billion. How much of that cost was fines issued by the DEP? $775,650.22. Even using the conservative figure of $5 million per well, DEP fines only account for 0.01 percent of operating costs–hardly any impediment at all. In essence, with the change in administration the DEP went from collecting fines in Monopoly money to asking drilling operators to sit down for a while and think about what they’ve done.

Over 45 percent of the fines issued for the Marcellus Shale in 2010 went to EOG Resources, the operator for a major blowout in Clearfield County. That was far from the only major incident in 2010, but the DEP was clearly mad about the incident, posting an entire section about the incident on their website. The $353,400 fined to EOG for this incident went to cover the DEP’s cost of response and investigation.

The two operators with the highest fines issued for Marcellus Shale operation in 2010 are toward the top of companies with the largest number of violations per year. That said, those companies at the very top were fined a significantly lower amount.

When we look at fines per violation, in addition to the same two operators that stood out in the last graph, we see several companies with relatively few violations having a significant number of fines per violation.

From an outside perspective, it is difficult to determine what sorts of factors go into whether or not a fine is issued, and if so, for how much. If the goal is simply to recoup costs of the DEP response and investigation, one wonders why there isn’t a fine more often, since every violation issued costs the DEP some resources to evaluate, process, and issue. And if fines are to act as a deterrent, they should include punitive damages, not just actual costs.

Keep in mind that the $7.2 billion to $9.3 billion range is just for Marcellus Shale wells, which last year represented about half of all oil and gas wells drilled in Pennsylvania. The industry is huge. One way we could have the oil and gas industry benefit all Pennsylvanians is by paying for the expenses of their DEP oversight, through permit fees and fines. That taxpayer savings could then be applied to other programs to help address the overall budget issue. Such an arrangement would be a huge boon to Pennsylvania, and while they might complain, the industry would barely notice if their cost per well went up by a few thousand dollars. Such an arrangement would also allow for the DEP to keep up with a rapidly expanding industry in a time of fiscal austerity that is sweeping the Commonwealth, and the nation as a whole.

Other sources, such as the Marcellus Drilling News report higher fine totals, but that includes a broader time frame. See Sean Hamill’s Post-Gazette article.

New Report: In the Shadow of the Marcellus Boom

May 10, 2011/by FracTracker Alliance

Just last week, PennEnvironment released a new study, In the Shadow of the Marcellus Boom, at press conferences in Scranton and Pittsburgh, plus a national teleconference. The report looks at the proximity of schools, hospitals and day care facilities to permitted Marcellus Shale gas wells. Their aim was to demonstrate the risks of shale gas extraction to vulnerable populations. Press release.

Below is a map of the day care, school and hospital facilities located within 2 miles of a permitted Marcellus well site:

Instructions:

Use the legend to toggle the information displayed on the map on or off.
Select an area of interest using the zoom bar in the lower-left corner plus the hand tool to pan, or use the zoom selection tool.
To obtain information about any point on the map, select the “i” tool in the gray toolbar and click on a point of interest. Click again within the dialog box to drill down and see more details for each point.
You can toggle between terrain, satellite, and street view with the buttons on the lower right of the map.

Issuance of PA Marcellus Shale Violations Over Time and by DEP Region

May 4, 2011/by Matt Kelso, BA

Changes Over TimeEvery time I think about the number of violations issued by the Pennsylvania Department of Environmental Protection (DEP) Bureau of Oil and Gas Management, I am struck on the one hand by the sheer magnitude of them–last year, the DEP issued 2,704 violations(1), a number that everyone would like to see go way down in the years ahead. On the other hand, at least that means the DEP is paying attention. It is with this spirit that I delved into the numbers, hoping to find patterns either in time or space.

The DEP has only occasionally issued more Marcellus Shale violations per month than for other combined oil and gas formations.

The monthly issuance of violations is surprisingly erratic in a industry that is accelerating drilling activity steadily, especially for the Marcellus Shale. Once we look at the data on an annual basis, though, a clearer picture begins to emerge.

Based on a projection from the first quarter of 2011, this year will be the first year with more new Marcellus Shale wells drilled than DEP violations issued.

The number of drilled Marcellus Shale wells in Pennsylvania has been growing rapidly since the first well was drilled in 2006. Violations have been on the rise as well, but if the projections for 2010 hold true, there will actually be fewer violations this year than last year, despite the fact that there will be more Marcellus wells drilled. Again, due to the erratic nature of violations issued per month, such a projection should be taken with a grain of salt. On the other hand, it does fit with the long term trend of Marcellus Shale violations issued per wells drilled for the same calendar year.

The number of Marcellus Shale violations per well has been decreasing over time, as has the budget of the Pennsylvania Department of Environmental Protection.

This graph is an attempt to look into the issue of whether the trend of decreasing violations per well might be due to DEP budget(2) issues rather than an overall increase in compliance by the industry. While this graph does not answer the question, it does lend the notion credibility.

Variance by DEP Region

Although there are six DEP regions, the Bureau of Oil and Gas is active out of three of them: the Northwest Regional Office (NWRO), the Southwest Regional Office (SWRO), and the North Central Regional Office (NCRO). All oil and gas activity in other portions of the state are included with the NCRO, giving them by far the largest territory to cover.

Violations per Well

Marcellus Shale violations per well by issuing DEP region. Click on the map for a larger, dynamic view.

The NCRO issued more than three times as many violations per Marcellus Shale well in 2010 than either of the other two regional offices. This is despite having the largest territory, and, as it turns out, the heaviest Marcellus Shale workload (3).

Violations per Inspection

DEP workload by region.

Number of Marcellus Shale inspections and wells drilled in 2010 by DEP Region.

Each DEP Oil and Gas Region had at least twice as many inspections as new drilled wells for the Marcellus Shale in 2010.

Marcellus Shale violations per inspection by issuing DEP region. Click the image for a larger, dynamic view.

The North Central Regional Office issued over eight times as many violations per inspection for Marcellus Shale wells as either of the other two DEP offices in 2010, despite the heaviest Marcellus Shale inspection workload.

Enforcement

The NCRO issued more than twice as many enforcement actions per inspection for Marcellus Shale wells than either the SWRO or NWRO in 2010.

As a quick review of the numbers for the Marcellus Shale from 2010, the NCRO compares to the other regions by issuing more than:

Three times as many violations per well
Eight times as many violations per inspection
Two times as many enforcement actions per inspection

The DEP briefly entertained the notion of centralizing violations and enforcement actions of Marcellus Shale wells. One wonders whether the end result would have been to reduce the vigilance of the NCRO, or whether the SWRO and NWRO would be instructed to catch up with their sibling. Indeed, either course of action could occur, even without Secretary Krancer’s direct approval of such actions.

Operators Active in Multiple Regions

Although the violation and enforcement numbers of the NCRO above are already convincing, there is another variability that could potentially skew the data: drilling operators. Some of the better operators in terms of violations per well such as Consol and Range Resources are active primarily in the SWRO’s jurisdiciton. Could it be that the NCRO just has more bad apples than the other two regions?

To answer this, I narrowed the list of Marcellus Shale operators from wells drilled in 2010 to those active in more than one region, the results of which are below.

There were 17 drilling operators that drilled Marcellus Shale wells in more than one DEP oil and gas region in 2010.

Even when we limit the field to the eleven operators active in the NCRO and one of the other districts, we once again see that the North Central Regional Office issued about three times as many violations per well as did the others.

Drilling operators with at least one 2010 Marcellus Shale well in the NCRO as well as either the SWRO or NWRO. Seneca Resources is the only instance where there were fewer violations issued in the NCRO than elsewhere.

It seems difficult to imagine that the geology in the NCRO jurisdiction is really that much more challenging to work with than the rest of the state. Short of that, I cannot speculate on a reason for the consistently stark contrast in violation and enforcement patterns other than to suggest that the North Central Regional Office is run with a culture of vigilance that is unmatched by their counterparts in the Southwest and Northwest.

The goal should be for the industry to achieve a greater level of compliance with Pennsylvania’s environmental laws, not to see a greater number of violations. At the same time, every person deserves to know that he or she is being aggressively protected from an industry that can be very dangerous and polluting. Undoubtedly, there is a lot that goes into the inspection process beyond the issuance of violations and enforcement actions, and the numbers can only go so far in providing a description of events on the ground. Nonetheless, those numbers are striking and consistent in showing a North Central Regional Office that takes a no-nonsense approach to its efforts of regulating the Marcellus Shale industry, at least as compared to either the Southwest Regional Office and Northwest Regional Office.

The numbers from this summary page do not match exactly with the DEP violations page data for 2010.
I would have rather compared violations to the Bureau of Oil and Gas budget, but it is not separated in that fashion within the budget reports.
The NCRO does have the smallest overall workload, but this blog is focused on the Marcellus Shale.

PASA Marcellus Shale Choices Workshop Series

April 29, 2011/by FracTracker Alliance

Part 1 – Integrative Decision Making for Farmers & Land Owners

May 17: Jefferson County; May 18 McKean County; May 19 Allegheny County; May 20 Greene County – 10:00am – 3:30pm

Farmers and rural landowners are a key group impacted by the Marcellus Shale gas development, as they continue to steward their land in the complicated environment of Marcellus Shale gas play.

PASA, with funding from the Colcom Foundation, has developed a series of action-oriented trainings throughout western Pennsylvania to help farmers, rural land owners, and other citizens make informed, holistic decisions, understand legal issues, and engage in environmental monitoring and local organizing efforts related to Marcellus Shale Gas issues within their communities.

In the first workshop of this series, Byron Shelton, Holistic Management Educator, farmer, rancher and owner of Landmark Decisions in Buena Vista, Colorado, will guide participants in learning a reasoning process that will help them establish a unique farm/rural land steward goal and make decisions to move them toward that goal. This decision-making process integrates the needs of the people that are involved, the economics of the situation, and the environment.

Over the course of the day, participants will develop their own farm or land-based goal. They will then test potential choices and actions to measure how these decisions move them toward their intended goal. While participants may consider the impacts and potentials of Marcellus Shale development in light of their overall goals, these tools are applicable to a much broader scope of decisions and choices – all of which involve ultimate movement toward the unique goal of the farm, landowner, family, or business situation.

Cost:

Registration Fee: $45 per farm/family
PASA Members: Free

For more information and to register online: Click Here

About Byron Shelton: Byron Shelton, a Holistic Management Certified Educator, and rancher in Buena Vista, Colorado, is the owner of Landmark Decisions which provides facilitation and decision-making training in Whole Farm Planning using Holistic Management™ Financial Planning, Ecosystem Processes Management, Grazing Planning and Monitoring, and Land Planning in family, business, agricultural, natural resource, and community settings.

Bradford County Blowout Frustrates Officials

April 26, 2011/by Matt Kelso, BA

Towanda Creek, Bradford County, PA

On April 19, a well being hydraulically fractured by Chesapeake Energy suffered a blowout, or a loss of control of the wellhead, releasing thousands of gallons of hydraulic fracturing fluid onto the ground and into nearby Towanda Creek. Actions by officials at the county, state, and federal levels show some frustration with the drilling operator over this incident.

Chairman of the Bradford County Commissioners Mark W. Smith wrote an open letter to Governor Tom Corbett, in which he addresses the perfunctory well permitting process, well water spoilage and declining property values. He also points out the strains that the industry places on the local communities:

I continue to see our county, townships, and boroughs struggle with complex issues of development with no financial or logistical support from the Commonwealth. Emergency responders, volunteers, state and local police and dispatchers are working at a break neck pace to respond to immense traffic accident increases, well site accidents, and other related issues.

At the state level, the Pennsylvania Department of Environmental Protection (DEP) has already issued violations for the incident, as well as demanding explanations of certain aspects of the massive leak and spill. Chief among those is why Chesapeake elected to bring in well control specialists Boots and Coots, which took 12 hours to arrive on the scene, when there were other well control specialists available much closer. (For some dramatic well disaster footage, see Boots and Coots’ promotional video.)

The US Environmental Protection Agency is also getting involved, demanding complete information about the incident in this open letter to Chesapeake CEO Aubrey McClendon. EPA Regional Administrator Shawn M. Garvin explains the twofold nature of request:

We want a complete accounting of operations at the site to determine our next steps in this incident and to help prevent future releases of this kind.

Chesapeake Energy officials are also concerned, suspending all post-drilling activities in the Marcellus, including hydraulic fracturing, until the nature of the spill is fully undestood. The linked article gives no indication of a time frame for that review.

In 2010, Bradford County had 280 Marcellus Shale violations issued, with 386 Marcellus wells drilled in the same period. That works out to an average of three violations issued for every four wells drilled in the county.

Oil and gas violations in Bradford County, PA in 2010. Please click the gray compass rose and double carat (^) to hide those menus.

PA Marcellus Shale Violations by Operator and County

April 21, 2011/by Matt Kelso, BA

Archived

This post has been archived.

Earlier this month, I examined 2010 oil and gas violation data for Pennsylvania on a summary level. Now I’m going to focus just on Marcellus Shale wells, and from the perspective of trying to determine the extent that drilling operators and location have on the likelihood of increased violations for any given well.

There are a number of ways in which this could be done. Although I am interested to see if the number of wells drilled in an area or by a drilling operator has a noticeable effect on violations, I have limited both investigations to 10 or more Marcellus Shale wells, both to avoid the erratic results of small sample sizes, and because the large number of results tends to make for crowded data displays.

Violations are only for 2010, both because it is current, and with 1,544 records, it is sufficiently large to make some generalizations about. As for wells, I decided to go for all drilled Marcellus Shale wells rather than just the 2010 wells, because wells that were spudded between 2006 and 2009 might well be included on the violations list. Also, the overall number of wells is a handy way to gauge the relative weight of a given operator or county on the industry as a whole.

2010 Marcellus Shale (MS) violations per total MS well, for counties with 10 or more MS wells.

2010 MS violations per total MS well, for operators with 10 or more MS wells.

There are, of course, a number of issues once we start looking at the data in detail. One of the biggest challenges is that many of these wells change hands, or else the companies that drill them change hands or are no longer active in the Marcellus Shale drilling industry in Pennsylvania. For example, in a previous analysis, I noted that Turm Oil had a large number of violations per well, and now they had none at all. I checked to see when their most recent well was drilled, and found my answer:

List of operators with 10 or more MS wells, with 2010 violations, frequencies per well, and the date of the most recent well drilled

Turm Oil hasn’t drilled a Marcellus well in almost two years. Looking at the chart above, Turm and Dominion don’t really belong in this analysis, and Eastern American and Fortuna may not for 2011. These four operators account for everyone with 10 or more total Marcellus Shale wells and no violations in 2010 except for Consol—kudos to Consol!

Does the number of wells impact violations?

Clearly, there is a tremendous range of violations per well, both in regards to who the operator is, as well as where the well is located. My hypothesis going into this analysis was that the more wells an operator drilled or the more wells drilled in a county, the fewer violations per well there would be.

I had several reasons for suspecting this to be the case. First of all, think of what must be done for a drilling operation without violations being issued. The site must be carefully placed, in accordance with all applicable regulations. The site must be prepared, taking into account all ground disturbing regulations. Then you have to drill through thousands of feet of rock, making sure that there is a structurally sound casing and cementing job to prevent gas migrations. Then there is the horizontal drilling, and the hydraulic fracturing. All along the way, not a drop of fracing fluid, diesel fuel, brine, or really anything else can touch the ground or enter Pennsylvania’s waters in any way. And when the drilling is done, the site must be restored in a timely fashion. And those are just a few of the regulations that the drilling operators agree to when they undertake drilling operations in Pennsylvania.

Let’s face it—that’s a lot to achieve. In order to consistently come in and out of a site with a clean record has got to take some practice. I’ve heard from industry sources that Marcellus Shale wells cost about $5 million to drill, so to do it right without cutting corners clearly takes significant resources as well.

In addition to all of that, a county level map of Marcellus Shale violations per well shows that the counties which produce the most Marcellus Shale gas wells are not the ones with the highest number of violations per well.

Map showing Marcellus Shale violations per county. Counties outlined in red have 100 or more Marcellus Shale wells. Click the gray compass rose and double carat (^) to hide those menus.

So is there then any correlation between the number of wells drilled and the violations issued? Let’s take a look (1).

The equations for the trendlines were calculated by Excel, and I selected the ones with the highest R-squared values. I was surprised that the best fit for operators was a convex polynomial. In the graph above, there is indeed a cluster of operators with between 300 and 400 wells, and with about 0.5 violations per well or less, but on the other end of the spectrum, the violations per well are spread far apart. There are so many operators big and small with around 0.5 violations per well or less that it seems some other factors must be at play for all of the operators that exceed that value by a significant margin. Perhaps not everyone will achieve zero violations like Consol did in 2010, but it doesn’t seem reasonable that Williams Production Appalachia should have more than twice the amount of violations as Range Resources Appalachia, despite having only 8 percent of the number of wells as the gas extraction giant.

The correlation was a bit stronger for the counties than for the operators. I’m not entirely sure what factors are at play here, other than perhaps having a crew that is well familiar with the geology of the region and all the specific challenges associated with that. Again though, that doesn’t seem to explain why Wyoming County would have 3.44 violations for every Marcellus Shale well, while those in Washington county can only expect a violation for less than one well out of eight drilled.

[photo removed]

Again, I’m sure that the way this analysis was set up had an effect on some of these numbers, and Wyoming is certainly a smaller sample size than Washington. I also don’t want to infer that there aren’t problems when large operators drill in well established portions of the Marcellus Shale. What’s more, while over 1,500 Marcellus Shale violations in a year is a huge number, it likely doesn’t account for all of the actual incidents, just the ones that the DEP can demonstrate, apparently beyond a shadow of a doubt (2). And even in the best scenario, there are significant impacts upon the land and neighboring residents near the well site.

I am suggesting, however, that there are companies that need to do better in their efforts to comply with laws designed to protect Pennsylvanians from pollution and other deleterious effects of oil and gas drilling. Excuses that environmental regulations are too strict don’t hold water, as their competitors are closer to compliance, sometimes dramatically so.

In order for Excel to be able to calculate all of the various regression lines, counties and operators with zero violations per well had to be excluded from this analysis.
I have personally talked to numerous residents who feel that their well water was spoiled by gas operations on neighboring lands. A common theme in their complaints is that the DEP places the burden of proof on residents that their wells were not spoiled before drilling operations began–an almost impossible situation for the residents to predict and be proactive about.