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Letter of Inquiry from a Public Health Professional

By Mary Ellen Cassidy, Community Outreach Coordinator

I recently came across a letter by Dr. Alan Ducatman, MS, MD, Professor of Public Health and Medicine at WVU in Donald Strimbeck’s updates.  It stuck me by its sincerity, logical tone, and reasonableness.

Drilling Spill SampleDr. Ducatman’s letter begins by commenting on the gas industry’s response to a surface spill in Garfield County.  The industry’s response to this spill, an Energy In Depth Blog (12/20/13), includes the following statement, “We all know spills are bad and can cause problems, so what exactly did they expect to find?”

Dr. Ducatman’s letter looks past the rather snide tone of the response to commend the industry for its honest acknowledgement that spills do occur and bad things can and do happen.  Dr. Ducatman notes that, although the response “lacks consistency with past and present behavior in public forums,” he hopes to see it become a “consistent and reasonable position” in the future.

The letter then calls on industry to be more scientific and open in their communications regarding other issues such as quality assurance, worker safety, well casing failures, leaks, water testing impediments, public protection practices, and reporting, while reminding the industry of the human and economic costs of externalities and the “terrible weight” of these collateral impacts on communities.

It occurred to me, upon reading this letter that more of us need to ask questions of the industry and take action to protect and support our impacted communities. Not only do we need more professional researchers like Dr. Ducatman asking questions, we also need many more people on the ground _DSC4465documenting what is happening around them to hold the industry accountable.

FracTracker Alliance aims to empower and equip volunteers to track and document unconventional gas and oil activities. Options for engagement include:

  • Trail Logbook – addressing trail-based observations about physical and experiential conflicts related to oil and gas development
  • The US Map of Suspected Well Water Impacts – aggregating cases of home drinking water problems that may be associated with oil and gas exploration
  • The new FracTracker mobile app (for iPhones) – making it easy  to take photos and record information on various oil and gas impacts in your neighborhood or afar. We are currently in the pilot testing phase of this app, which can also be used to contribute data to the other two programs described above.

These programs depend on crowdsourced information from you and others to grow a national database on the extensive footprint of the industry.  Check out our website and projects to see where you fit.

In addition, we always welcome your ideas on how our mapping and other services can help your community’s efforts to protect its health and natural resources.

Contact me to learn more about how you can become a part of the FracTracker team, and a special thank you to Dr. Alan Ducatman for his letter reenergizing this important conversation.

If you are one of those people ready to work together in a concerted effort towards a more positive energy future, FracTracker needs you.


Mary Ellen Cassidy, Community Outreach Coordinator
Cassidy@FracTracker.org
304-312-2063

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.

OH Shale Viewer

OH National Response Center Data on Shale Gas Viewer

By Ted Auch, PhD – Ohio Program Coordinator, FracTracker Alliance

Thanks to the Freedom of Information Act (FOIA), we as US citizens have real-time access to “all oil, chemical, radiological, biological, and etiological discharges into the environment anywhere in the United States and its territories” data via the National Response Center (NRC). The NRC is an:

initial report taking agency…[that] does not participate in the investigation or incident response. The NRC receives initial reporting information only and notifies Federal and State On-Scene Coordinators for response…Verification of data and incident response is the sole responsibility of Federal/State On-Scene Coordinators.[1]

We decided that NRC incident data would make for a useful layer in our Ohio Shale Gas Viewer. As of September 1, 2013 it is included and will be updated bi-monthly. Thanks go out to SkyTruth’s generous researchers Paul Woods and Craig Winters. We have converted an inventory of Ohio reports provided by SkyTruth into a GIS layer on our map, consisting of 1,191 events, including date and type, back to January 2012.


The layer is not visible until you zoom in twice from the default view on the map above. It appears as the silhouette of a person lying on the ground with Skull and crossbones next to it. View fullscreen>

Currently, the layer includes 28 hydraulic fracturing-related events, 61 “Big [Oil and Chemical] Spills,” and 1,102 additional events – most of which are concentrated in the urban centers of Cleveland, Toledo, Columbus, and Toledo OH.

From a Utica Shale corporation perspective, 21 of the 28 reports are attributed to Chesapeake Operating, Inc. (aka, Chesapeake Energy Corporation (CHK)) or 75% of the hydraulic fracturing (HF) events, while CHK only accounts for 48% of all HF drilled, drilling, or producing wells in OH. Anadarko, Devon, Halcon, and Rex are responsible for the remaining 7 reports. They collectively account for 2.7% of the state’s current inventory of unconventional drilled, drilling, or producing wells.


[1] To contact the NRC for legal purposes, email efoia@uscg.mil. The NRC makes this data available back to 1982, but we decided to focus on the period beginning with the first year of Utica permits here in Ohio to the present (i.e., 2010-2013).

Incidents continue to make headlines during drilling slowdown

Although drilling activity in some areas of PA seems to have slowed due to the lower price of natural gas ($2.82 per MMBtu), the decline in violations cited by the PA DEP have not followed that trend as quickly as one would hope. There have still been plenty of incidents over the last few months that keep the safety of drilling at the forefront of the media and in residents’ minds. Just last night there was a confirmed report about a gas well explosion (or possibly fire) in Susquehanna County. West Virginia is not exempt from these problems, either, after three rig workers were injured in an explosion at an Antero well pad on August 17th.

Check out the timeline below of  a selection of significant gas drilling incidents in PA that have surfaced since January 2012.

 

Violations Jan-Sept 2011 PA (EHS highlighted with red dots)

A discussion on regulation and safety

By Samantha Malone, MPH, CPH – DrPH Student in Environmental & Occupational Health; Communications Specialist for FracTracker.org

As natural gas drilling in the Marcellus Shale region of our country moves forward, people in many states are debating over the best ways to regulate the natural gas industry. I’m not going to get into the impact fee discussion in this piece, although it is an obvious point of contention that needs addressed in PA immediately. Rather, I’d like to propose a way to manage the permitting and future development of the companies operating in this field.

Pipeline Safety

There are 2.5 million miles of pipelines in the U.S., the majority of which are for gas transmission and distribution. A recent 4-part series by the Philadelphia Inquirer brought to light the real and potential dangers of the gas pipeline system, which is being expanded in PA to handle the Marcellus gas destined for the market. The biggest concern highlighted in these articles in my opinion is the lack of oversight anywhere in the process – especially when our regulatory officials cannot even locate the pipelines. (Specific geographic locations of pipelines are often held close to the chest due to the perception that this information poses a risk to national security and infrastructure.)

Pipelines do fail, as demonstrated by the toxic liquid spills map below. This graphic was created by the New York Times, who in a earlier article discussed the lack of human and fiscal resources available to the Pipeline and Hazardous Materials Safety Administration – noting that although the number of spills have declined, pipelines are still responsible for approximately 100 significant spills per year.

NYTs: U.S. Pipeline Incidents 1990 - June 2011

NEW YORK TIMES | Source: Department of Transportation, Pipeline and Hazardous Materials Safety Administration

If you’d like to be able to find where pipelines are located (approximately) in your county, visit the U.S. DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) website for Pipeline Safety Awareness. The site also provides you with data about pipeline incidents. In case you would rather not go diving through the raw data, below are some U.S. pipeline incident datasets and example maps from 2010 – Nov 2011 data that  Matt Kelso obtained from PHMSA:

  • PHMSA Hazardous Liquids Pipeline Incidents: Dataset | Map
  • PHMSA Gas Distribution Pipeline Incidents: Dataset | Map
  • PHMSA Gas Transmission Pipeline Incidents: Dataset | Map
(You can do a lot more with this data, such as filtering it by whether surface water remediation was necessary or by the type of contaminant that was released.)

Violations in PA

Violations Jan-Sept 2011 PA (EHS highlighted with red dots)

Violations Jan-Sept 2011 PA (EHS violations in red)

Another concern about natural gas drilling is the risk of environmental health and safety incidents occurring throughout the rest of the drilling process.1

The map to the left created using Data.FracTracker.org shows all of the violations that were issued to drillers from Jan-Sept. 2011 in Pennsylvania. The red dots are the violations that fall under the DEP’s loose category of Environmental Health and Safety (EHS).2

As you can see, EHS incidents do occur, but is that the whole story? Perhaps we should be asking ourselves, who exactly is responsible for these incidents – pipelines and the like? When you look more closely at the data the industry’s safety record becomes less monolithic than at first glance.

Focusing on the Bad Actors

The PR surrounding natural gas drilling is controversial at best. We have seen blanket statements about how safe – and dangerous – natural gas drilling and pipelines can be. We all must recognize that the answer lies somewhere in between. However, where is the perfect medium located, and how do we address the root of the problems that do arise?

One approach that is taken by some regulatory bodies such as OSHA is to focus on the bad actors. In two of his more recent posts, FracTracker’s Matt Kelso analyzed the ‘bad actors’ that exist within the violations issued in PA. While this is certainly not an easy or straightforward task, he was able to identify operators with the highest and lowest violations per well drilled, as well as trends between 2010 and 2011. Check out these analyses here: Part 1 |  Part 2.

Bad actors are not good for the industry’s PR or the Commonwealth’s residents. If the agencies responsible for issuing drilling permits quantitatively began to take violation trends into account, this would allow the safer drillers to continue operating, while limiting those with a less than appealing track record.


1 One of the great changes made by the PA Department of Environmental Protection in the last 2 years has been the transfer from the paper record system for keeping track of the violations they issue to a digital version that allows people access to the comprehensive, raw data. This is certainly also something that should be on NY’s Department of Environmental Conservation radar prior to issuing its first permit for high volume hydraulic fracturing.

2 EHS violations are a loose category because often times when we sift through the data we will find administrative oversights like paperwork mislabeled as EHS, and more serious spills and fires mislabeled as administrative.

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.

January to August Marcellus Shale Violations by Operator

The Pennsylvania Department of Environmental Protection’s Bureau of Oil and Gas maintains violation data on their website (download the Excel file). The following is a summary of Marcellus Shale violations issued in the first eight months of this year, including the number of wells that were flagged for violations.


Marcellus Shale violations and offending wells in Pennsylvania: January – August, 2011

West Virginia Marcellus Shale Data Updated

Three new West Virginia datasets have been added to the DataTool to keep up to date with Marcellus Shale activities in that state. The West Virginia DEP is the source for all three datasets. Included are:

West Virginia Marcellus Shale Permits (large)
Marcellus Shale permits in West Virginia through September 6, 2011. Please click the image for a dynamic view.

The permits list was filtered online to include only Marcellus Shale permits, then filtered on the desktop to reflect only “Permit Issued” actions, thereby ignoring applications, renewals, and other actions for the same well. I also converted the coordinate system from UTM’s to the more familiar system decimal degree latitude and longitude. There are 1,868 records in the dataset. One well apparently was given the wrong coordinates, and appears to be in Pennsylvania instead of West Virginia.

West Virginia Marcellus Shale Drilled Wells (large)
Marcellus Shale drilled wells in West Virginia through September 6, 2011. Please click the image for a dynamic view.

Each triangle in the map above represents a Marcellus Shale gas well that was listed as an active well. Location data was determined by matching the unique well numbers to the permits list, above.

Marcellus Shale Violations in West Virginia (large)
Marcellus Shale violations in West Virginia through September 6, 2011. Please click the image for a dynamic view.

The violations list did not mention whether or not the well was a Marcellus Shale well, nor did it give location information. Both of these categories were determined by matching the well number to the permits list.

Marcellus Shale Violations per Inspection and Enforcements per Violation

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.