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PA Well Pad Violations map

Well Pad Violations in Pennsylvania

Emerging Trends

We are always learning new things at FracTracker. While we have been analyzing and mapping oil and gas (O&G) violations issued by the Department of Environmental Protection (DEP) in Pennsylvania since 2010, we have apparently been under-representing the total amount of issues associated with unconventional drilling in the state.

The reason for the missing violations is that there are inconsistencies with how well pads are classified in the compliance report. Many of these well pads – full of unconventional permits and drilled wells – are indeed categorized as “unconventional” in the DEP compliance data. Others, equally full of unconventional permits and wells, simply leave that field blank.

Therefore, any analysis for unconventional violations is likely to miss some of the incidents that are attributed to the well pad itself, as opposed to any of the wells that are found upon that well pad.

Midas Well Pad unearths issue

While we have heard about missing violation data in the past, I discovered the nature of the issue while researching the Midas Well Pad in Plum Borough, Allegheny County on the DEP resource site eFACTS, noting the presence of multiple violations at the nascent well site. However, when attempting to download the relevant data on the compliance report, the results were missing. I had entered search parameters that made sense to me, limiting results to violations in the proper county and municipality, and including an inspection date range that was broader than what was showing up on eFACTS. I had also limited results to unconventional wells, because while this is Plum’s first unconventional well pad, the back roads are dotted with dozens – if not hundreds – of conventional O&G sites.

The Midas Well Pad, as seem from Coxcomb Hill Rd. in Plum, PA

After that attempt failed, I downloaded the entire state’s worth of data, whether conventional or not, and I was able to find the 31 violations associated with the well pad.

I contacted DEP about this, wondering whether there was some data irregularity that prevented my search in Plum from finding all of the incidents that occurred there. The reply was somewhat helpful, noting that there was no county, municipality, or unconventional value associated with that well pad in the compliance report, explaining why the search result came up negative.

It is worth noting that the separate well pad report does indeed have values for all of these fields for the Midas Well Pad, so there is a lack of consistency on this issue. Even more importantly, it is worth remembering that any compliance report search that limits results using county, municipality, or unconventional variables are likely to result in incomplete results.

The violations at the Midas Well Pad are focused around erosion and sedimentation issues, wetland impacts, failure to follow approved methodology, and failure to fix some of the problems on subsequent site inspections. The compliance report includes a narrative inspection comment, giving the public a glimpse through the inspector’s eyes. Here is one of several such comments at the site:

Follow up inspection related to wetland impact reported on 2/23/18 and 2/24/18. At the time of inspection, the Operator was actively conducting earth disturbance activity associated with the construction of well pad channel 6. The Department gave verbal permission on 2/27/2018 to deviate from the construction sequence and continue with the construction of PCSM wet pond 1. At the time of inspection wet pond 1 was partially constructed. The outlet structure and emergency spillway associated with wet pond 1. At the time of inspection wet pond 1 was holding water, however the slopes were not temporary stabilized. The Operator indicated that additional work was planned for the wet pond and would be temporary stabilized. The Operator indicated a previously unidentified seep located upgradient and outside of the LOD is contributing additional water to wet pond 1. The Department recommended the Operator identify wet weather springs upgradient from wet pond 1. Additionally, the Department recommends the Operator monitor all additional flow and submit a permit modification outlines changes made to the construction sequence and identifies the location of all toe drains to be constructed on site. The Department and Operator agreed to reschedule an onsite meeting to discuss the remediation of the wetland. Th Department recommends the Operator monitor the vegetative growth in the wetland. The Department recommends that the Operator add additional temporary mulch to the disturbed area and continue to perform routine maintenance to the temporary BMPs.

How pervasive is this problem?

The DEP well pad report contains data on 12,600 wells, situated on 3,715 wells pads. On the compliance side, there are 2,689 violations at 390 different sites that contain the words “Well Pad.” 739 of these violations do not have associated Well API Numbers, and are therefore not shown in our Pennsylvania Shale Viewer map. The number of sites with violations per operator is shown below in Figure 1 (click to expand).

Figure 1: Number of well pads appearing on compliance report by operator, through 5/15/2018. Click on the image to see the full-sized version.

There are four things to note about about Figure 1. 

First, this table is not the number of violations on well pads, but merely the count of well pads with violations appearing on the compliance report.

Second, this does not contain any data on wells on those pads that were issued violations – only instances where the well pads themselves were cited are shown.

PA Well Pad Violations: 

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This map shows oil and gas (O&G) violations in Pennsylvania that are assessed to well pads, as opposed to individual wells. To access the map’s legend and other details, click the double-arrow icon at the top-left corner of the map.

The third thing to note about Figure 1 is that there are instances where the same pad falls into more than one category. Hilcorp Energy, for example, has 10 wells in the unconventional category, 11 wells that are not defined, but only 13 total wells, indicating significant overlap between the categories.

And fourth, there are 31 instances where the phrase “well pad” occurs in the compliance report where the unique Site ID# does not appear on the well pad report. In some cases, the name of the facility indicates that it might be for another facility that is related to the well pad, such as “Southwest System – Well Pad 36 to Bluestone Pipeline.” For other entries, such as “Yarasavage Well Pad”, it remains unclear why the Site ID# does not yield a matching entry from the well pad report.


By Matt Kelso, Manager of Data and Technology, FracTracker Alliance

 

PA Oil & Gas Fines feature image

Pennsylvania Oil & Gas Fines Analysis

In March 2017, FracTracker Alliance conducted a review of the available Pennsylvania oil and gas fine data released publicly by the PA Department of Environmental Protection (DEP) to identify trends in industry-related fines over time and by particular operators. In total, the DEP has assessed nearly $36 million in fines to oil and gas extraction and pipeline operators since January 1, 2000. Such fines are associated with over 42,000 violations issued1 by DEP in that time frame, covering 204,000 known oil and gas locations,2 as well as 91,000 miles of pipelines3 within the Commonwealth.

Understanding the Data Structure

The amount of money that the Pennsylvania Department of Environmental Protection (DEP) fines oil and gas (O&G) operations is included in the DEP’s compliance report published on their website. Even though fines data are made available, they are not necessarily straight-forward, and caution must be taken not to over-estimate the total number of assessed fines.

Records of fines are associated with enforcement identification codes on the compliance report. A single fine is often applied to numerous violations, and the full amount of the fine is listed on every record in this subset. Therefore, the total dollar amount of fines assessed to O&G companies appears overstated. For example, if a $400,000 fine were assessed to settle a group of 10 violations, that figure will appear on the report 10 times, for an apparent aggregate of $4,000,000 in fines. To get an accurate representation of fines assessed, we need to isolate fines associated with particular enforcement ID numbers, which are used administratively to resolve the fines.

This process is further complicated by the fact that, on occasion, such enforcement ID numbers are associated with more than one operator. This issue could result from a change in the well’s operator (or a change of the operator’s name), a group of wells in close proximity that are run by different operators, or it might point to an energy extraction company and a midstream company sharing responsibility for an incident. Sometimes, the second operator listed under an enforcement ID is in fact “not assigned.” The result is that we cannot first summarize by operator and then aggregate those subtotals without overstating the total amount of the assessed fines. In all, 62 of the enforcement ID numbers apply to more than one operator, but this figure amounts to less than one percent of the nearly 15,000 distinct enforcement ID numbers issued by DEP.

Conventional & Unconventional Violations & Fines

Oil and gas wells in Pennsylvania are categorized as either conventional or unconventional, with the latter category intended to represent the modern, industrial-scaled operations that are commonly referred to as “fracking wells.” Contrastingly, conventional wells are supposed to be the more traditional O&G wells that have been present in Pennsylvania since 1859. The actual definition of these wells leaves some blurring of this distinction, however, as almost all O&G wells now drilled in Pennsylvania are stimulated with hydraulic fracturing to some degree, and some of the conventional wells are even drilled horizontally – just not into formations that are technically defined as unconventional. For the most part, however, unconventional remains a useful distinction indicating the significant scale of operations.

Table 1. Summary of oil and gas wells, violations, and fines in Pennsylvania

Category Conventional Unconventional (blank) Total
Wells 193,655 10,291 0 203,946
Violations 27,223 6,126 9,026 42,375
Fines $7,000,203 $13,689,032 $21,563,722 $35,949,495*
Fines per Violation 257 2,235 2,389 848
Fines per Well 36 1330  – 176.27
Violations per Well 0.14 0.60  – 0.21
Wells per Violation 7.11 1.68  – 4.81
* The total fine amount issued is not a summary of the three preceding categories, as some of the fines appear in multiple categories

Ninety-five (95)% of the state’s 204,000 O&G wells are classified as conventional, so it should not be surprising to see that this category of wells accounts for a majority of violations issued by the department. However, fines associated with these violations are less frequent, and often less harsh; the $7 million in fines for this category accounts for only 19% of the total assessed penalties. In contrast, the total penalties that have been assessed to unconventional wells in the state are nearly twice that of conventional wells, despite accounting for just 5% of the state’s well inventory

On the 54,412 records on the compliance report, 10,518 (19%) do not indicate whether or not it is an unconventional well. The list of operators includes some well-known conventional and unconventional drilling operators, and hundreds of names of individuals or organizations where O&G drilling is not their primary mode of business (such as municipal authorities and funeral homes). This category also contains violations for midstream operations, such as pipelines and compressor stations. Altogether, 3,795 operators have entries that were not categorized as either conventional or unconventional on the compliance report, and 124 of these operators were issued fines. One additional complication is that some of the violations and fines that fall into this category are cross-referenced in the conventional and unconventional categories, as well.

The resulting impact of these factors is that the blank category obscures the trends for violations and fines in the other two categories. While tempting to reclassify well data in this category as either conventional or unconventional, this would be a tall task due to the sheer number of records involved, and would likely result in a significant amount of errors. Therefore, the FracTracker Alliance has decided to present the data as is, along with an understanding of the complexities involved.

Most Heavily Fined Operators

Despite the numerous caveats listed above, we can get a clear look at the aggregated fines issued to the various O&G operators in the state by constructing our queries carefully. Table 2 shows the top 12 recipients of O&G-related fines assessed by DEP since 2000. Ten of these companies are on the extraction side of the business, and the total number of well permits issued4 to these companies since 2000 are included on the table. By looking at the permits instead of the drilled wells, we discover the operator that was originally associated with the drilling location, whereas the report of drilled wells associates the current operator associated with the site, or most recent operator in the event that the location is plugged and abandoned.

Stonehenge Appalachia and Williams Field Services operate in the midstream sector. Combining the various business name iterations and subsidiaries would be an enormous task, which we did not undertake here, with the exception of those near the top of the list. This includes Vantage Energy Appalachia, which was combined with records from Vantage Energy Appalachia II, and the compliance history of Rice Energy is the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.

Table 2. Top 12 operators that have been assessed oil and gas-related fines by DEP since 2000

Operator Total Fines Conventional Permits Unconventional Permits Violations Fines / Violation Fines / Permit
Range Resources Appalachia LLC $5,717,994 2,104 2,206 819 $6,982 $1,327
Chesapeake Appalachia LLC $3,120,123 18 3,072 754 $4,138 $1,010
Rice Energy* $2,336,552 442 165 $14,161 $5,286
Alpha Shale Res LP $1,681,725 3 62 31 $54,249 $25,873
Stonehenge Appalachia LLC $1,500,000  – 294 $5,102
Cabot Oil & Gas Corp $1,407,275 19 902 726 $1,938 $1,528
CNX Gas Co LLC $1,274,330 1,613 677 387 $3,293 $556
WPX Energy Appalachia LLC $1,232,500 347 159 $7,752 $3,552
Chevron Appalachia LLC $1,077,553 2 604 113 $9,536 $1,778
Vantage Energy Appalachia LLC** $1,059,766 3 300 35 $30,279 $3,498
Williams Field Services Co, LLC $872,404  – 158 $5,522
XTO Energy Inc $739,712 1,962 461 383 $1,931 305
* Fines for Rice Energy here represent the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.

** Fines for Vantage Energy Appalachia were combined with records from Vantage Energy Appalachia II.

Predictably, many of the entries on this list are among the most active drillers in the state, including Range Resources and Chesapeake Appalachia. However, Alpha Shale Resources has the dubious distinction of leading the pack with the highest amount of fines per violation, as well as the highest amount of fines per permit. Fitting in with the theme, the story here is complicated by the fact that Alpha had a joint venture with Rice, before selling them their stake in a group of wells and midstream operations that were fined $3.5 million by DEP.5 On this compliance report, the fines from this incident are split between the two companies.

Fines Issued Over Time

It is worth taking a look at how O&G related fines have varied over time, as well (Figure 1, shown in millions of dollars). Numerous factors could contribute to changes in trends, such as the number of available DEP inspectors,6 the amount of attention being paid to the industry in the media, differing compliance strategies employed by various political administrations, or changes in practices in the field, which could in turn be impacted by significant fines issued in the past.

PA Oil & Gas Fines Analysis chart

Figure 1. O&G Fines Issued by DEP, 2000 through 2016

The notable spike in fines issued from 2010 to 2012 corresponds with the peak of unconventional drilling in the state – 4,908 of these industrial scaled wells were drilled during those three years, amounting to 48% of all unconventional wells in PA. In contrast, only 504 unconventional wells were drilled in 2016, or around a quarter of the total for 2011. In this context, the reduction in fines since the early part of the decade seems reasonable.

The association with the number of unconventional wells falls apart a bit in the years 2013 to 2014, however. These two years saw an average of 1,293 unconventional wells drilled, but the fines issued amounted to only 35% of the 2011 total.

Considerable strides have been made in the public accessibility of oil and gas data available from the PA DEP since FracTracker started requesting and reviewing this information in 2009. Still, there are many gaps in the datasets, such as geolocation details for 10 of the 20 largest fines issued by the department. FracTracker hopes external analyses like this one will help to close such gaps and identify operators who, too, need to improve their compliance records.

References & Footnotes

  1. Pennsylvania Department of Environmental Protection (PA DEP) Oil and Gas (O&G) Compliance Database.
  2. PA DEP O&G Spud Database. Note: Starting date 1/1/1800 captures unknown spud (wells drilled) dates.
  3. Pipeline Hazardous Materials and Safety Administration (PHMSA) Pipeline Data Mart Reports.
  4. PA DEP Permits Issued Database.
  5. State Impact PA. (2016). Rice Energy fined $3.5 million for wellsite and pipeline violations.
  6. PennEnvironment Research & Policy Center. (2017). Fracking Failures 2017, Oil and Gas Industry Environmental Violations in Pennsylvania.

Oil & Gas Fines White Paper

This analysis is also available for download in a printer-friendly, white paper format:


Cover Photo by Pete Stern, Loyalsock, PA

Approaching 10K Unconventional Wells in PA

Approaching 10K Unconventional Wells in PA

By Matt Kelso, Manager of Data & Technology

Each state has its own definition of what it means for an oil or gas well to be “fracked.” In Pennsylvania, these wells are known as “unconventional,” a definition mostly based 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.

The count of these unconventional wells in PA stands at 9,760 as of June 14, 2016. Their distribution is widespread across the state, but is particularly focused in the northeast and southwest corners of Pennsylvania.

Unconventional oil and gas wells in Pennsylvania:

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Wells Drilled

The industry is not drilling at the same torrid pace as it was between 2010 and 2012, however. The busiest month for drill rigs in the Keystone State was August 2011, with 210 unconventional wells drilled. Last month, there were just 32 such wells.

Unconventional wells in PA: Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Figure 1. Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Permits

As Figure 1 captures, the number of permits issued per quarter is always greater than the number of wells drilled during the same time period. Even when drilling activity seems to be entering a bust phase, oil and gas operators continue to plan for future development. Altogether, there are 17,492 permitted locations, meaning there are about 7,700 permitted locations where drilling has not yet commenced.

Violations

The number of violations issued by DEP is generally follows the same trends as permits and wells. It is usually the smallest of the three numbers. In the first quarter of 2016, however, is one of a few instances on the chart above where the number of violations issued outpaced wells drilled. There could be any number of reasons for this anomaly; it could have been due to to unusual compliance issued in the field or aggressive regulatory blitzes. It could also be due to some other factor that can’t be determined by the available published data source.

Interestingly, this phenomenon has not occurred since the first quarter of 2010, when the industry was in full swing.

About VpW

One of the best ways to understand the impact of the industry is to look at violations per well (VpW). Unfortunately, there are a number of important caveats to that discussion. First of all, not all items that appear on the compliance report receive their own Violation ID number. It is clear from the DEP workload report that violations are tallied internally by the number of Violation ID numbers. This is as opposed to the number of items on the compliance report. As of June 14, 2016, there were 6,706 rows of data and 5,755 distinct Violation ID numbers that were issued to 2,080 different oil and gas wells. This discrepancy means that about 21% of unconventional wells are issued violations in Pennsylvania. Those that are cited receive an average of 2.8 to 3.2 violations per well, depending on how you count them.

Unconventional Wells in PA: Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Table 1. Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Determining the violations per well by operator comes with additional caveats. The drilled wells data comes from the spud report, which lists the current operator of each of the wells. The compliance report, however, lists the operator that was in charge of the well at the time of the infraction. This poses a problem for analysis, however. The ownership of the wells is quite fluid when taken in aggregate, as companies fold, are bought out, or change their names to something else.

VpW Results

We calculated VpW figures for the 20 operators with the largest inventory of drilled wells wells in Pennsylvania, found in Table 1. In some instances, we were able to reunite operators with violations that were issued under a different name but are in fact the same company. Specifically, we combined Rex Energy’s violations with RE Gas Dev, CONSOL violations with CNX, and Southwestern with SWN Productions, as the company is now known.

SWN’s violation-per-well score appears to be quite low. Their statistic, however, does not take into account wells that it purchased from Chesapeake in 2014, for example. In this transaction, 435 wells changed hands, with an unknown number of those in Pennsylvania. Any violations on these wells that Chesapeake had would stay with that company even as their well count was reduced. Such a change would thereby artificially inflate Chesapeake’s VpW score. On the other hand, SWN is now in possession of a number of wells which might have been problematic during the early stages of operation. Those violations, alternatively, are not associated with SWN, making their inventory of wells appear to be less problematic.

Data Caveats and Takeaways

Alas, we do not live in a world of perfect data. As such, these results must be taken with a grain of salt. Still, we can see that there are some trends that persist among operators that have been active in Pennsylvania for many years. Chief, Cabon, and EXCO, for example, all average more than one violation per well drilled. Chevron, CNX, and RE Gas Development, on the other hand, have much better rates of compliance, on the order of one violation per every five wells drilled.

Updated PA Data and Trends

By Matt Kelso, Manager of Data and Technology

The FracTracker Alliance periodically takes a deeper look into the unconventional oil and gas data in Pennsylvania, in order to provide updates for some frequently requested statistics on the industry. Here we provide updated PA data and trends as of December 4, 2014. Since unconventional drilling began in the Commonwealth permits have been issued to drill 15,573 unconventional wells, according to data from the Pennsylvania DEP. Many – 8,696 (56%) – of those permits have actually been drilled. In terms of violations, there have been 5,983 entries on the statewide Compliance Report for unconventional wells throughout the state, which are attributed to 1,790 distinct wells.

Pennsylvania Shale Viewer Map


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Additional Stats

The number of permits, wells, and violations vary significantly from month to month, but each category is well off of its peak. The largest number of unconventional permits issued in a single month was 402, which was in December 2010, more than twice as many as were issued last month. In that year, there were six months with 300 or more permits issued, whereas there has only been one such month to date in 2014.

PA unconventional O&G activity per month from Jan. 2009 to Nov. 2014.  Source:  PADEP

PA unconventional O&G activity per month from Jan. 2009 to Nov. 2014. Source: PADEP

The 210 wells spudded (drilled) in August 2011 represents the high water mark, and is more than two times the amount of wells drilled last month. In the 28 months between March 2010 and June 2012, the industry failed to spud 100 wells only once, reaching 98 in April 2011. In the first 11 months of 2014, that plateau was missed three times, with a low of 58 spuds in February.

There was a significant spike in violations appearing on the compliance report from December 2009 through August 2011. More than 100 violations were issued in 17 out of 21 months, including 196 in March 2010. The number of violations issued has slowed down considerably since then, with November 2014 being the 34th straight month with fewer than 100 violations. Only 14 violations were issued in June 2014.

Violations per Well (VpW)

Unconventional violations per well by county in PA, showing the 10 counties with the largest number of violations.  Counties with an above average Violations per Well (VpW) score are highlighted in red.

Unconventional violations per well by county in PA, showing the 10 counties with the largest number of violations. Counties with an above average Violations per Well (VpW) score are highlighted in red.

We often ask whether drilling is more problematic in some areas than others. Since the number of wells varies depending upon the location, we must approach this question by looking at the number of violations issued per well drilled (VpW). However, there is an important caveat to consider. Put simply, what is a violation? The Pennsylvania DEP publishes a Compliance Report for unconventional wells, which has 5,983 incidents listed from 2000 through December 4, 2014. However, it used to be common for the DEP to lump several incidents into the same Violation ID number, although this is not the case for more recent infractions. When the DEP counts violations issued, they look at the total number of unique Violation ID numbers that have been issued, not the total number of incidents on the report. Here, we include the more inclusive list of items on the compliance report.

Of the 10 counties with the largest number of violations issued, only 3 counties have a violations per well mark below the statewide average. Notably, each of those three counties are located in Southwestern Pennsylvania. It is unclear from these numbers what is going on in Potter County, but clearly there is a significant problem in that location – with almost three violations issued per well drilled, Potter County has a VpW score 4.3 times the statewide average.

Operator Trends

Before we look at the operators with the most violations, there is an additional caveat to consider: It is relatively common for wells to change hands over their operational lifetimes. This characteristic could be due to one company buying another out, or simply transferring some of their assets. Still, wells changing from one operator to another is a normal aspect of the oil and gas industry. Such a fact matters for this analysis because while violations issued always stick with the responsible party in the DEP data, the name of the operator changes on the Spud Report to the current operator.

Unconventional violations per well by operator in PA, showing the 10 operators with the largest number of violations.  Operators with an above average Violations per Well (VpW) score are highlighted in red.

Unconventional violations per well by operator in PA, showing the 10 operators with the largest number of violations. Operators with an above average Violations per Well (VpW) score are highlighted in red.

Because of how these datasets are maintained, we see that East Resources has 261 violations for zero wells, which is of course an impossibly large ratio. That is because East sold off its stake in the Marcellus to Royal Dutch Shell, which does business as SWEPI in Pennsylvania. SWEPI, by the way, is 13th on the list of violations in its own right, with 154 violations for 675 wells, resulting in a 0.23 VpW. If the legacy violations for the old East wells were included, the result would be a 0.61 ViW score, which is almost three times as high, but still below the statewide average. FracTracker doesn’t do the analysis that way, both because it is unfair to the new operator to charge them with violations that they had nothing to do with, as well as being nearly impossible to keep track of the various transactions that result in wells changing hands over the years.


Cover image by Pete Stern, 2013.

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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Long Term Trends in PA’s Marcellus: Violations per Well

Ever since the DEP responded to FracTracker’s request for oil and gas violation data in October 2010, I have been providing periodic updates of the data in a variety of meaningful ways, such as raw violations totals and violations per amount of gas produced. But for most purposes, the best analysis has always been in terms of violations per well.

Since that time, the data have improved considerably. Not only have significant issues been addressed with both datasets, but the violations and drilled wells are now both relatively easy to access online directly from the DEP. That does not mean, however, that the available datasets are perfect or straightforward. For example, the DEP seems to count violations by the number of violation ID numbers issued, but upon closer inspection, that’s not the full story, and as a result, I prefer to use the total number of entries on the compliance report instead. The situation for permits and wells used to be almost exactly the opposite, as those reports often list multiple actions for the same well.

I have not checked the permits report lately but as I began this analysis, I was surprised to discover that the drilled wells list has been cleaned up considerably, as each unique eight digit well API number appears on the list exactly once. Now I may be the only one excited about this, but it is a notable milestone in the evolution of the data in my humble opinion,  because it removes an element of interpretation which can have a significant impact on the result of the analysis.  And as an added bonus, it makes the analysis much easier, too.

So let’s take a look at violations per well (VpW) from January 1, 2005 through June 12, 2012:


Violations per well by year in Pennsylvania’s Marcellus Shale.

Keep in mind that if we were talking about raw totals of violations and wells, it would of course be significant that we are less than half way through the year. As a ratio, however, that’s not the case, and there is no reason to expect the VpW for 2012 to change substantially up or down based on seasonality. Looking at the the trend, however, there is plenty of reason to expect the final score to be lower, as the rate of violations per well has been declining sharply in recent years. In fact, the current 2012 rate of 0.51 violations per year is less than half of the 1.14 violations per Marcellus well that we saw in 2009. Certainly, that’s an encouraging trend, if it can be attributed to changes in practices in the field, and not just changes how violations are administered, coinciding with changes in the executive branch of the state government.

One of those changes made by the new administration was an effort to route the violations process through Harrisburg. It was a move that raised considerable suspicion among some people, as it had the appearance of moving the oversight process a good bit closer to elected and appointed officials. But on the other hand, it was clear that the three DEP offices which handled oil and gas violations were not on the same page:


2010 Violations per Well by DEP issuing region.

Violations issued from the North Central Regional Office (NCRO) were roughly three times that coming from either the North West Regional Office (NWRO) or the South West Regional Office (SWRO). As the role of the regional office is supposedly diminished in determining what is and is not a violation, we will take a look at the 2012 data on a county by county basis:


Marcellus Shale violations per well (VpW) by county from 1-1-12 through 6-12-12. Counties outlined in yellow contained at least one drilled well during the period.

Compared to the map above, it seems like the strong association with VpW score and regional office affiliation is starting to break down. For those who are are curious, you can see all of the data for each county dating back to 2005 by clicking on the blue “i” tool, then any map outline.

But because the VpW scores can be so exaggerated for counties with just a handful of Marcellus Shale wells, let’s take a look at the five counties with the most wells, all of which were in the North Central Regional Office jurisdiction except for Washington, which was in the South West Regional Office:


Violations per Well for the 5 counties in PA with the most Marcellus Shale wells, as of 6-12-2012.

Last year was the first time since 2007 that Washington County did not have the lowest VpW score out of the five counties with the most wells. In this subset, trends are down across the board since 2009, and now the counties that are major players in the Marcellus are all much closer together.

When it was learned that the plan at the DEP was to have Secretary Krancer approve each Marcellus violation, the prediction that the number of violations relative to the activity of the industry would decrease was widespread. Even though the specific plan was scuttled, the expected result came to pass anyway. And yet, the validated hypothesis does not amount to proof of political meddling; the possibility that the data reflect improved practices in the field would also net the same result.

Violations per Well by Operator, Part 2: Bad Actors

Recently, I conducted an analysis of the legacy of each Marcellus Shale operator’s violations over time, normalized by the number of wells each company has drilled, in a metric that I call Violations per Well, or VpW. While that analysis was cumulative, I’ve had FracTracker readers ask if the VpW from one year predicts the VpW for the following year, particularly among the bad actors. To help answer that question, I’ve taken the same raw data from the previous post, and recompiled it to help address that.

I’ve been looking at violations per well for some time, on the theory that it can be used to help score a company’s compliance history with regards to the Pennsylvania Department of Environmental Protection, which issues them. All of these wells and violations are Marcellus Shale specific, and come from sources posted on the DEP website.

For ease of use, I’ve color coded the results, with bright green being the best scores, and bright red being the worst. Companies without wells for a given year are indicated in pale blue. They may either indicate drilling operators that were inactive in a given year, or midstream companies that haven’t drilled any well. Here’s the color coded key:

And here are the results:

To look at the bad actors from 2010, I selected all of the entries that were colored burgundy or bright red for that year’s VpW score. How have they fared so far in 2011?

To be fair, I should point out that operators with very few wells can get obnoxious VpW scores in a hurry. On the other hand, there were 14 Marcellus Shale operators with at least one well drilled in 2010 that didn’t get any violations that year. Therefore, in this instance, I’ve included all operators with a VpW of 1.00 or greater, and will leave questions about sample size up to the reader.

Five of the operators with VpW scores of 1.00 or higher haven’t drilled any wells at all in 2011 so far. In fact, all of them had VpW scores of at least 2.50. There may be a variety of reason for their absence in 2011, but honestly, their lack of compliance isn’t missed.

Nine operators improved from 2010 to 2011, four of which improved all the way into green categories. This is the result that we want to see, where companies appear to be responsive to violations issued by the DEP. Notable among this group is Citrus Energy, which had a huge amount of violations compared to one drilled well in 2010, to a VpW score under 0.50 so far in 2011. Also, PA Gen Energy is an operator with a significant number of wells that went from a red to a green category, which is encouraging to see. Cabot, on the other hand, barely budged, and remains over 2.00 violations per well.

There are also three operators from 2010 with VpW scores of 1.00 or greater that actually got worse in 2011. And keep in mind, the data used includes almost two more months of drilled wells than violations, so inclusion in this group is especially dubious. They include Rice Drilling B, whose VpW more than duobled to 2.13; XTO, which went from awful to horrific since becoming a subsidiary of ExxonMobil; and Ultra Resources, whose performance has been nothing short of ghastly in 2011. Luckily, Ultra has been leaving the Keystone State alone since January–let’s hope it stays that way.

I maintain that since so many operators–big and small–are able to keep their violations to wells ratio at less than 1:2, all of the operators that operate in Pennsylvania’s Marcellus Shale should try to reach that standard.  Those that show a continued disregard for our laws protecting our environment should face stiff fines for their complacency, while those operators that average more than two violations per well drilled over a prolonged period of time need to be banned.

Violations per Well by Operator Over Time

The following chart contains all operators that have either drilled a Marcellus Shale well in Pennsylvania from March 6, 2006 to November 27, 2011, or have been issued a Marcellus Shale related violation by the Pennsylvania Department of Environmental Protection between January 1, 2008 and September 30, 2011. Results are cumulative, thereby reflecting each company’s legacy with the Marcellus Shale, rather than their performances for any given year. The Violations per Well (VpW) score has been color coded for easy reference, with the following scale:

Most companies that are issued violations are well operators, although there do seem to be some midstream companies on the violation list. This might account for some of the blue “No wells” below, but mostly they reflect operators that were not yet active. For example, Antero Resource’s first well was in 2010, so entries for 2008 and 2009 read as “No wells”.

Whenever we look at Marcellus operators over time, the changes in companies has to be dealt with in some way. In this case, I took a minimalist approach: while East Resources, Inc. and East Resources, Llc. were combined, I did not merge name changes that were more substantial than that. For example, even though CNX Gas and Consol Gas are both owned by Consol, I did not merge the two. Another example is St. Mary Land and Exploration changed its name to SM Energy, and those two entries were left unchanged. Because of all of the changes within the industry, I have included the most recent drill date, so that viewers can determine if the drillers are still active.