Conventional, Non-Vertical Wells in PA

Like most states, the data from the Pennsylvania Department of Environmental Protection do not explicitly tell you which wells have been hydraulically fractured. They do, however, designate some wells as unconventional, a definition based largely on the depth of the target formation:

An unconventional gas well is a well that is drilled into an Unconventional formation, which is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.


Naturally occurring karst in Cumberland County, PA. Photo by Randy Conger, via USGS.

While Pennsylvania has been producing oil and gas since before the Civil War, the arrival of unconventional techniques has brought greater media scrutiny, and at length, tougher regulations for Marcellus Shale and other deep wells. We know, however, that some companies are increasingly looking at using the combination of horizontal drilling and hydraulic fracturing in much shallower formations, which could be of greater concern to those reliant upon well water than wells drilled into deeper unconventional formations, such as the Marcellus Shale. The chance of methane or fluid migration through karst or other natural fissures in the underground rock formations increase as the distance between the hydraulic fracturing activity and groundwater sources decrease, but the new standards for unconventional wells in the state don’t apply.

The following chart summarizes data for wells through May 16, 2014 that are not drilled vertically, but that are considered to be conventional, based on depth:

These wells are listed as conventional, but are not drilled vertically.

These wells are listed as conventional, but are not drilled vertically.

Note that there have already been more horizontal wells in this group drilled in 2014 than any previous year, showing that the trend is increasing sharply.

Of the 26 horizontal wells, 12 are considered oil wells, five are gas wells, five are storage wells, three are combination oil and gas, and one is an injection well.  These 177 wells have been issued a total of 97 violations, which is a violation per well ratio of 62 percent.  429 permits in have been issued in Pennsylvania to date for non-vertical wells classified as conventional.  Greene county has the largest number of horizontal conventional wells, with eight, followed by Bradford (5) and Butler (4) counties.

We can also take a look at this data in a map view:


Conventional, non-vertical wells in Pennsylvania. Please click the expanding arrows icon at the top-right corner to access the legend and other map controls.  Please zoom in to access data for each location.

Violations per Well Among PA Operators

Note

This post has been archived. It is provided here for informational purposes only.

People often want to know which operators perform the best (or worst) among their peers in terms of adhering to the laws set forth in a given state. In principle, the easiest metric for determining this is to look at the ratio of violations issued per well, or VpW.

However, in order to make that analysis, we would obviously need to have violations data. Unfortunately, out of the twenty states that we have shale viewers for on FracMapper, we only have violations data for Arkansas, Colorado, and Pennsylvania, with the latter being far and away more robust and complete when compared to the other two. We have been told that the data is also available for North Dakota as well, if we are willing to pay for it, so we might be able to perform a VpW analysis for the Peace Garden State in the near future.

Then, of course, there is the realization that, “What is a violation?” is actually somewhat of a philosophical question in Pennsylvania.  In the past, I’ve determined that the Pennsylvania Department of Environmental Protection (PADEP) uses the number of unique violation ID numbers issued to calculate their totals. However, historically, the department would often lump several issues that showed up on the Compliance Report together under the same violation ID.  Others have taken to looking at Notices of Violations (NOV’s), which are more limited in number.  Still others exclude any violations marked as being administrative in nature, an idea that makes sense superficially, but a closer look at the data shows that the label is extremely misleading.  For example, “Pits and tanks not constructed with sufficient capacity to contain pollutional substances” is an administrative violation, as is, “Improper casing to protect fresh groundwater”.

In addition to all of that, the cast of operators is constantly shifting as new operators come on board, old ones get bought out by rivals, joint ventures are formed between them, and the like.  Sometimes a parent company will shift the active operator status to one of its subsidiaries, so wells that were originally Consol will then be listed under CNX, for example.

In terms of violations per well, there is a further complication, in that all of the drilled wells data reflect the current custodians of the wells, whereas the violations data reflect those that received the violations.  The result is that there are records issued for Turm Oil (really!) for wells where Chesapeake is now listed as the operator.  In some respects, this makes sense:  why should Chesapeake carry the burden of the legacy mistakes of Turm in their compliance record?

But it does make analysis somewhat tricky.  My approach has been to combine operators that are obviously the same parent company, and to do the analysis in several different ways, and over different time frames.  Who’s ready for some numbers?

Violations per Well (VpW) for operators of unconventional wells in Pennsylvania with 50 or more wells. Those operators with scores higher than the average of their peers are highlighted in pink.

Violations per Well (VpW) for operators of unconventional wells in Pennsylvania with 50 or more wells. Those operators with scores higher than the average of their peers are highlighted in pink.

Here, violations per well are based on the number of violation ID’s issued, where as NOVpW is based on the number of Notices of Violations.  The date range for this table is from January 1, 2000 through October 21, 2013, and please note that the totals represent those that are included on the chart, not statewide totals.  A lot of violations are lost of the shuffle when we look at only the largest current operators, but it also helps eliminate some of the noise that can be generated with small sample sizes, as well as with the inconsistencies described above.  Here’s a look at data from this year:

Violations per Well (VpW) for operators with unconventional wells in Pennsylvania in 2013, through October 21. Those operators with scores higher than the average of their peers are highlighted in pink.

Violations per Well (VpW) for operators with unconventional wells in Pennsylvania in 2013, through October 21. Those operators with scores higher than on violation per well or NOV per well are highlighted in pink.

Notice that the highest violations per well and notices of violations per well scores are much higher than the data aggregated since 2000, whereas the statewide averages of the two scores are actually much lower.  The former is almost certainly attributable to having a smaller sample size, but there is something else at play with the latter:

Violations per well of Pennsylvania's unconventional wells. 2013 data through 10/21/2013.

Violations per well of Pennsylvania’s unconventional wells. 2013 data through 10/21/2013.

The number of violations per well drilled has been steadily decreasing since 2009, and it is now down to an average of less than one violation issued per every two wells.  There is nothing in the data that indicates why this is the case, however.

Note:  This post was edited on 12/18/2013.  The table showing operators violations per well and NOV’s per well in 2013 originally stated that that values higher than the average of their peers are highlighted in pink.  In fact, only those with values of 1.00 or higher are highlighted in that fashion.

West Virginia Map Updated

At FracTracker, we are constantly adding new content to our maps page. In recent weeks, we have added new content for Michigan, Pennsylvania, and Arkansas. Now, we have updated our West Virginia Shale Viewer as well.


West Virginia Shale Viewer. Please click the expanding arrows in the top right corner to access the legend and other map tools.

The map above shows some detail about Marcellus Shale operations in the Mountain State, including:

  • Permits issued (purple).  To date, there have been 3,079 permits issued statewide since 2000 where the Marcellus Shale is the target formation.
  • Completed wells (orange).  Of the permits that have been issued, the West Virginia Department of Environmental Protection (WVDEP) has received a completion form for 1,840 wells, or just under 60 percent.
  • Wells in noncompliance (yellow).  196 Marcellus wells were given the noncompliance flag in the dataset.  There are no details on what might have led to this status, however.
  • Public comment wells (blue).  35 Marcellus Shale wells in West Virginia are flagged as having received a public comment of one sort or another.  As with the wells in noncompliance, this dataset offers no details on these wells.

Here’s a look at the number of completion reports received by WVDEP by month:

Marcellus Shale completions by month in West Virginia

Marcellus Shale completions by month in West Virginia

The largest number of completions per month for Marcellus Shale wells is 97 in April 2009.  The next highest total was the following month, with 81 completions.  From January through August of this year, there are an average of 40.5 completions per month in West Virginia.

The information that is distributed in this West Virginia data is typical, however, a good deal of data are being collected by WVDEP.  To see the kinds of things that the state knows about completed wells, take a look at what is required for submission on form WR-35.

PA Unconventional Drilling Activity Trends

The Pennsylvania Department of Environmental Protection (PADEP) publishes data on unconventional oil and gas permits, drilled wells, and violations. The FracTracker Alliance has taken this data, and summarized it by month:

Permits issued, wells drilled, and violations issued for unconventional oil and gas wells in Pennsylvania from January 2005 through May 2013.

Permits issued, wells drilled, and violations issued for unconventional oil and gas wells in Pennsylvania from January 2005 through May 2013.

There are numerous ways to interpret the raw data, to the point where it is easy to get bogged down in the specifics. Still, a certain amount of discussion is merited to understand that answers to questions like, “How many unconventional oil and gas violations are there in Pennsylvania?” are fundamentally interpretive in nature, based on the available data. For example, there are often multiple actions for a single well API number that appear in the permits report, and likewise multiple actions for a single violation ID number that has been issued. In this analysis, we have counted only the first action for each of these.

Here are some more summary details about the data:

This table shows a summary of unconventional oil and gas data in PA by month.

This table shows a summary of unconventional oil and gas data in PA by month.

The top section shows summaries of monthly counts of permits, drilled wells, and violations, while the second section shows the frequency of the monthly totals reaching specified targets, and the third section shows the total numbers that were used for the analysis.  For example, we can see in the top section that the maximum number of violations issued in a month is 160, so there are zero instances where the monthly total of violations reached the target of being greater than 200.  And while there have been four months since January 2005 where there have been no unconventional permits issued in the state (the most recent being in September 2005, incidentally), this has happened 21 times on the violations report.

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