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Pennsylvania Violation Data

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The Pennsylvania Department of Environmental Protection (DEP) responded to our request for oil and gas violation information with a list of 9,370 violations from January 1, 2007 through September 30, 2010. That works out to almost seven oil and gas violations statewide per day. Certainly, the DEP has been taking its job very seriously in trying to regulate the oil and gas industry within the Commonwealth.

At the same time, it makes one wonder what violations occur that the DEP is not aware of.

A Closer Look at the Numbers

The 9,370 violations came from a total of 3,661 wells. Of that total, 2,075 violations are flagged as Marcellus Shale, from 592 distinct wells. And of the Marcellus wells total, there were 1,497 violations from 399 wells that were flagged as horizontal wells. All horizontal wells in this dataset are also Marcellus Shale wells.

That means that for non-Marcellus Shale wells, there were 7,295 violations from 3,069 wells, for a frequency of just 2.38 violations per well. The highest frequency of violations per well was 37, for API# 131-20020, a horizontally drilled Marcellus Shale well in the town of Washington in Wyoming County, PA.

In terms of average violations per well, the reported data indicates 2.38 violations per non-Marcellus well, and 3.51 violations per Marcellus well, for an overall average of 2.56 violations per well.

This graph shows the mean number of violations per well type in
Pennsylvania.  This is based on a list of 9,370 violations provided by the PA
DEP from 1-1-2007 through 9-30-2010.  Please note that this reflects only wells
where violations occurred,not every well of this type within Pennsylvania.

Please keep in mind that all of these values only represent wells that have violations, and therefore it should not be construed that the average Marcellus well will have three and a half DEP violations. This certainly does, however, raise the question of why an offending horizontal Marcellus Shale well would have an average of 1.37 more violations per well than its non-Marcellus counterpart, but it does not provide the answer. Perhaps it reflects that more can go wrong on horizontal Marcellus Shale wells, or that they are more tightly regulated. Perhaps a handful of individual sites like the one in Washington have so many violations that they skew the data in some way. There could be numerous scenarios to explain the discrepancy.

Obtaining Geographic Location Information

To date, the primary means of linking oil and gas data to a geographic location has been using the dataset compiled by PASDA, which includes the information of over 123,000 oil and gas locations within the state. Unfortunately, the PASDA data was insufficient for the violation data, as there were thousands of records that did not match. I have reduced that number significantly to by adding the list of known permits since 2007 (which also includes geographic information) to the PASDA list. This process created duplicate entries, which was worked around by obtaining the average longitude and average latitude of each API number.

This process does not eliminate any errors inherent in the data. In one example that I looked at, there were three listings for one unique well number, one of which was off by 0.3 degrees of latitude, or about 20 miles. In this scenario, it would be tempting to correct the one to conform to the other two, but in reality, it isn’t clear which one is correct. And for that reason, auditing the dataset—which is now over 128,000—for errors is not especially productive. For the moment, it is sufficient to say that there are some errors present in the location data, which are hopefully minimal in scope.

Forced Pooling FAQs

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FracTracker’s blog and DataTool are at their strongest when people contribute to them and comment on the content. In line with that mission, Leslie Avakian of ProtectMyRightsPA has provided the following frequently asked questions on the issue of forced pooling. (Please keep in mind that these are the opinions of ProtectMyRights, not CHEC.) If there are topics or events you would like to see posted on this blog or if you want to share a great snapshot you created on the DataTool, just send us an email with the details.

Q&A — Forced Pooling – Forced Drilling & Use by Right – Zoning Exemptions

ProtectMyRightsPA – September 27, 2010

Why are so many people upset about forced pooling?

Forced pooling would allow natural gas companies to take gas from underneath landowners who have not agreed to it. It would apply in situations where enough of the land around a property is leased. The definition of “enough” is being negotiated. For landowners who choose not to sign a lease, rights to control their property would, in effect, be turned over to their leased neighbors, the State and the gas company. Forced pooling violates the PA Constitution which protects PA citizens’ private property rights. It would be a state law taking control of private property and offering it for sale to a selected industry. Is this not Socialism? These important concerns, coupled with the possibility of legislation being developed without reasonable opportunity for proper public input, gives citizens good reason to be upset.

Is forced pooling necessary?

No. These shale gas plays aren’t free-flowing “pools.” The gas is in the pores of the shale, that’s why it needs to be fractured. Forced pooling in PA’s unconventional shales is a way for gas companies to acquire acreage without landowner consent and without having to make upfront lease payments in areas where they intend to drill, and to expand the acreage they can drill under. It is a way to get around negotiating price with landowners, a way to acquire gas rights at below-market rates, and a way to force people into leases or lease terms they don’t want.

Can property owners be protected from gas theft without forced pooling?

Certainly. The right answer to the risk of having gas taken from property owners without consent or compensation is not to strip property owner rights and force them to accept drilling under their property and the extraction of all their gas. The right answer is to enact legislation to protect the private property rights expressly granted by the PA Constitution.

There are many possible ideas. For example, legislators could develop protections such as fracturing setback requirements, monitoring and stiff penalties to assist landowners beyond the existing legal remedies for subsurface trespass, property damage and theft of gas through fracturing across mineral rights boundaries. If needed, legislators could protect the mineral rights of neighboring landowners through pro-rata compensation formulas based on the permeability of the shale and the location of the nearest operating gas wells. These formulas could be used to pay landowners who have chosen not to lease, but are having some of their gas drawn out unavoidably by a well in the area. Legislators should open these issues to public dialog for ideas on how to best address these concerns, not simply implement forced pooling.

Why doesn’t forced pooling protect the environment?

Forced pooling is not the same as gas well spacing requirements. Gas well spacing requirements can exist completely independent of forced pooling, and vice-versa. Forced pooling does not protect the environment. And the only spacing requirements publicly suggested so far have been arbitrary distances. They do not help determine appropriate places for gas drilling. They simply spread gas wells evenly throughout all land areas in the state – through neighborhoods, cities, next to schools and shopping centers – as long as they are spaced a minimum distance apart.

Is there precedent for forced pooling in PA?

Not really. The Conservation Law includes forced pooling below the geologic strata called the Onondaga Horizon — this is beneath the Marcellus, Utica and Newark Basin shales. Forced pooling as per the Conservation Law has never been applied and has never been challenged in court, and it expressly excludes all strata above the Onondaga. It also differs in many ways from the forced pooling currently proposed. Furthermore, a key purpose of the Conservation Law is to protect correlative rights when gas or oil is extracted from a common pool. The notion of a common pool does not similarly apply to the Marcellus. Correlative rights can be protected in other ways without violating private property rights.

Why would forced pooling be an illegal taking of property?

The PA Constitution contains no provision that allows for a forced pooling law. Further, Article I, Section 1 of the Constitution states that PA citizens have certain indefeasible rights, including the rights to acquire, possess, and protect property. Forced pooling would be an illegal legislative taking of private property.

Is gas drilling already a “use by right” and exempt from local zoning?

No. Gas drilling is not a “use by right” or exempt from local zoning in PA. This was affirmed in Feb. 2009 by the PA Supreme Court in two landmark decisions (Huntley vs. Oakmont and Range Resources vs. Salem). These rulings clearly articulate that the traditional land use and community planning functions of zoning ordinances are not pre-empted by the Oil and Gas Act and are governed by the PA Municipal Planning Code. Only gas drilling processes and practices are governed by the Oil and Gas Act.

But Beware – industry material widely circulated in Harrisburg and elsewhere has repeatedly and incorrectly stated that drilling is already a use by right and pre-empts all local zoning. This is false – the Gas Act does not supersede local zoning for municipal planning purposes, only for drilling processes and techniques. One industry strategy has been to seek a language adjustment to “clarify” legislative intent – but this is really an attempt to fundamentally change the legislative intent – and should not be implemented.

Why are PA citizens upset about use by right (zoning exemptions) for oil and gas?

Taxpayers in local communities have invested significant time and money developing community plans and zoning ordinances to provide for the orderly growth and development of their communities. Use by right for gas drilling would override local government and make gas drilling a “principal permitted use” in every zoning district in the State of PA. Gas wells are noisy, brightly lit, operate 24/7/365, and require thousands of truck trips for each multi-well pad. It is not an insignificant land use. Municipal planning was developed to manage land use, is not superseded by the Gas Act and should not be compromised.

If use by right (zoning exemption) legislation is passed, or the Gas Act language modified to effectively strip communities of their local powers, it will spur litigation by citizens, this time in the Federal court system on the grounds that it is an abuse of the State’s “police powers” in that it fails to promote/protect the health, safety and welfare of PA citizens and directly interferes with and substantially disturbs PA citizens’ use and enjoyment of their property.

Drilled Oil and Gas Locations in Utah

By Matt Kelso – Data Manager, Center for Healthy Environments & Communities (CHEC), University of Pittsburgh Graduate School of Public Health

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A new dataset of drilled oil and gas locations in Utah has been added to FracTracker’s DataTool (click on the snapshot of that dataset to the left to see more detail). This dataset was pursued in order to obtain more data from other shale gas fields throughout the United States. However, despite the fact that there are shale gas fields in the state, a correspondence with Utah’s Oil and Gas Permitting Manager/Petroleum Geologist Brad Hill has led to the revelation that there are currently no shale gas wells in the state. On the other hand, he indicated that most vertical and horizontal wells in Utah undergo some amount of hydrofracturing process, making the data relevant to our pursuits here at FracTracker.

Dissemination of Information

From the perspective of trying to obtain meaningful data about oil and gas operations, the Utah Division of Oil, Gas and Mining is wonderful resource. Just to give an indication of the breadth of the scope of what they have to offer, go to the Oil and Gas Well Log Search, set the three boxes to “API Well Number”, “LIKE”, and “43” (which is Utah’s state code), and you get a list of wells in the state, complete with associated well logs that can be viewed and downloaded. In Pennsylvania, you would have to file a Right to Know claim to get access to some of these documents. The small sample of scanned source documents that I have looked at in Utah has included typewritten notices from the 1960’s. One of the files had over 30 pages of documents.
In addition to having an abundance of information on their site, the workers that I have dealt with at the Division of Oil, Mining, and Gas have been extremely useful in obtaining additional information. My initial query to Don Staley of that department was replied to within 20 minutes, and he contacted the Petroleum Geologist of his own volition to make sure that the information that was given to me was clear. They have set the standard for public service by a governmental regulatory agency, as far as I am concerned. Texas was also helpful, but only some of their information is available free of charge.

Geocoding Issues

Most people are familiar to some extent with the basic longitude and latitude system. The grid that the two values combine to make, known as a graticule, allows for the identification of unique locations on the planet. It is not, however, the only means of identifying unique locations.

A system used by Utah and by many of the other western states is known as the Public Land Survey System, or PLSS. This system was conceptualized by Thomas Jefferson and dates to the Land Ordinace Act of 1785. In essence, it creates a series of six-mile wide horizontal bands known as Townships, and six-mile vertical bands called Ranges. These intersect to create a six-by-six mile box (see image right), with a name of something like “Township 5 North”, “Range 8 West.”  This is further divided into 36 sections, each one-mile square. This can be further subdivided into quarters, and then quarters of that, so that a location could be recorded as the northeast quarter of the southeast quarter of Township 5 North, Range 8 West, Section 5 (or NE1/4 of SE1/4 of T5N, R8W, Sec. 5 for short).

This discussion is relevant here because in parts of the Utah Oil and Gas website, location information comes up in this format. To obtain the locations for the drilled wells in the state, it required a convoluted process of finding a map of the 1-by-1 mile section boxes, then finding the midpoint of those boxes with GIS tools, and finally correlating those points to the original dataset. Since the midpoint of a 1-by-1 mile box is about 0.70 miles to each corner, that is the margin of error for the location of these datapoints. For most uses, that shouldn’t matter.

After completing these conversions, I have found elsewhere on the site latitude and longitude data, as well as Universal Transverse Mercator (UTM) values, which is yet another means of finding unique places on Earth. I have not yet determined whether that has all of the information from the dataset that has been posted, but if so, then more accurate location information will follow shortly.

Is a Severance Tax in the Future for Pennsylvania?

By Samantha Malone, MPH, CPH – Communications Specialist and DrPH student, Center for Healthy Environments & Communities (CHEC), University of Pittsburgh Graduate School of Public Health

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Last week the PA House of Representatives voted in support of a severance tax of 39 cents for every thousand cubic feet of natural gas extracted. This proposed bill now awaits its fate in the Senate. Governor Edward Rendell recently sent a letter to Senate leaders urging them to move forward on the bill.

“A week ago the Pennsylvania House of Representatives voted to impose a severance tax on natural gas drilling in Pennsylvania. Since that time, in spite of the expressed commitment made by the you in the fiscal code, your comments, and those made by your staff, do not offer a shred of evidence that you have any intention of living up to this commitment you made to put the severance tax to a vote in the Senate before you adjourn the session.” Read more.

Industry representatives have stated that the proposed tax is too high and would hinder the extraction process in the Commonwealth. Supporters of this tax, however, feel it is necessary to counter the costs to local infrastructure and protect the environment and public health.

Public Health Conference on the Health Effects of Shale Gas Extraction – November 19, 2010

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The University of Pittsburgh Graduate School of Public Health cordially invites you to the following exclusive conference:

HEALTH EFFECTS OF SHALE GAS EXTRACTION: WHAT IS KNOWN AND WHAT CAN WE PREDICT?

This free conference will explore the science and methodological approaches behind understanding environmental health impacts associated with increasing development of natural gas extraction from shale deposits found under wide geographical areas of the United States.

University Club, Pittsburgh, PA 15260
November 19, 2010
8 AM – 6 PM
Download event flyer (PDF).

This conference is limited to 240 participants. Registration is required.
Click here [link removed] to learn more and register.

A Look Back at the Clearfield Blowout – Public Health Preparedness Considerations

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Clearfield Blowout, June 2010
Photo credit: PA DEP

By Samantha Malone, MPH, CPH – CHEC Communications Specialist and DrPH Student, University of Pittsburgh Graduate School of Public Health

It came at a conspicuous time; on June 3, 2010 a Marcellus gas well blew out in Clearfield County, PA – less than two months after the BP Oil Spill in the Gulf (and before that spill was capped).

Luckily, the Clearfield blowout did not kill or injure workers or spill five million gallons into the ocean, but it does raise significant public health preparedness and environmental health questions.

The Pennsylvania Department of Environmental Protection (PA DEP) released a report stating that untrained EOG Resources personnel and improper control of the well were the cause of the blowout that released wastewater and methane gas into the atmosphere for 16 hours. EOG also failed to notify the DEP about the incident until several hours after it began.

The Clearfield well site in question is located in the center of PA off of I-80 (see map below).
[image removed]
Figure 1. The red square indicates multiple violations that occurred in one geographic location, the Clearfield blowout. Click on “i” to learn more about each square (record). (The map used to be private and visible on the DataTool only to members of CHEC, but it can now be seen by anyone.)

Many concerns and questions are associated with a blowout of this type:

  1. Not including the danger to workers from the initial blowout, what if the gas being released had ignited?
  2. What if the site had not been in the State Game Lands and been in a more populated or possibly urban area like Lawrenceville, a neighborhood in the city of Pittsburgh?
  3. What if an explosion had occurred that caused the wastewater and gas to be released for much longer?
  4. How can emergency responders be better prepared to handle issues of this magnitude?
  5. How can communication channels be improved to reduce the amount of time between incident and proper response?

On the part of emergency responders, some progress is being made. CHEC continues to receive reports that more and more local first responders, including volunteer firefighters, are being trained in PA and WV to deal with potential accidents and blowouts on well sites. Additionally, the PA DEP has hired a team of responders throughout the state who are no more than five hours away from any drill pad.

Read the DEP’s full report on the Clearfield gas well blowout. [link removed]

Water Contamination Studies

By Samantha Malone, MPH, CPH – CHEC Communications Specialist and BCHS Doctoral Student, University of Pittsburgh, Graduate School of Public Health

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Water Contamination Potential

When the ‘new’ methods for gas extraction first appeared on the horizon in Pennsylvania, many citizens expressed concern that their water could become contaminated by the hydraulic fracturing process used to obtain natural gas from the Marcellus Shale. At the same time, the natural gas industry’s PR group, the Marcellus Shale coalition, claimed that “hydrofracking has [a] safe record and spurs [the] economy.” Preliminary research conducted by the Agency for Toxic Substances and Disease Registry (ATSDR) and the U.S. EPA in Pavillion, Wyoming suggest that a portion of citizens’ concerns might be warranted. (To learn more, read the PDFs numbered 2, 3, and 4 at the end of this post.)

Some researchers believe that gas extraction cannot be done without negatively impacting water quality due to the likelihood of well casings leaking over time (Dusseault, 2000). See excerpt below:

The consequences of cement shrinkage are non-trivial: in North America, there are literally tens of thousands of abandoned, inactive, or active oil and gas wells, including gas storage wells, that currently leak gas to surface. Much of this enters the atmosphere directly, contributing slightly to greenhouse effects. Some of the gas enters shallow aquifers, where traces of sulfurous compounds can render the water nonpotable, or where the methane itself can generate unpleasant effects such as gas locking of household wells, or gas entering household systems to come out when taps are turned on. Methane from leaking wells is widely known in aquifers in Peace River and Lloydminster areas (Alberta), where there are anecdotes of the gas in kitchen tap water being ignited. Because of the nature of the mechanism, the problem is unlikely to attenuate, and the concentration of the gases in the shallow aquifers will increase with time. (Dusseault, 2000)

Updating PA’s 1989 Cement Regulations

In an attempt to reduce the risk that the increased drilling in PA would negatively impact groundwater and drinking water supplies, the PA Environmental Quality Board published its proposed rulemaking measures to update existing state requirements for many of the processes involved in natural gas drilling, including: casing and cementing the well, monitoring and inspections, and plugging of oil and gas wells. (A significant portion of the existing regulations in PA that dictate water supply replacement and how gas wells are constructed were created in 1989.)

Whether natural gas drilling – when done properly – can contaminate well water or the acquifer from which well water is obtained is a significant research question. Public health would suggest that this is an imperative issue considering the number of violations sited against companies drilling in Pennsylvania by the PA DEP. (See map below that shows Marcellus Shale wells drilled since 2007 and violations as of September 22, 2010. To view an individual record, click the “i” in the toolbar below the map and then click on the record about which you would like to obtain more information.)

[image removed]

The potential impacts that the natural gas industry could have on water quality and public health are some of the major reasons that the U.S. EPA is conducting a $1.9 million study on hydraulic fracturing, including a life-cycle analysis of the process. In order to better understand the relationship between drilling products and water resources, the EPA recently sent a letter to select hydraulic fracturing service providers that requests they release the constituents of their fracturing fluid, as well as specific information about other industry processes.

References and Additional Publications

  1. Dusseault MB. 2000. Why Oilwells Leak: Cement Behavior and Long-Term Consequences. Society of Petroleum Engineers Inc.
  2. ATSDR Health Consultation, Pavillion, WY – Evaluation of Contaminants in Private Residential Well Water
  3. EPA, Pavillion, WY – Expanded Site Evaluation – Analytical Results Report
  4. EPA, Pavillion, WY – Conceptual Site Model

Do the natural gas industry’s surface water withdrawals pose a health risk?

By Kyle Ferrar, MPH – EOH Doctoral Student, University of Pittsburgh GSPH

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Wastewater discharges are regulated through national pollutant discharge elimination system (NPDES) permits, and are based on the concept “the solution to pollution is dilution.” However, what happens when the diluting capacity of a river diminishes? If the natural gas industry will be producing 20 million gallons per day (MGD) of wastewater in 2011, but only retrieves 20% to 70% of the water used to drill and hydrofracture a well, over 28.5 to 100 MGD must be withdrawn from water resources1.
Water withdrawals for the natural gas industry are permitted through the Pennsylvania Department of Environmental Protection (PA DEP) with the approval of the Department of Conservation and Natural Resources (DCNR). As water is withdrawn, the volumes of stream flow decrease. Water withdrawals must be conducted responsibly, so that the volumes of stream flow are not impacted. Decreasing flow decreases the assimilative capacity of waterways to dilute pollution, such as TDS. In the late summer and fall, lack of precipitation causes drought conditions, and accounts for the lowest flow periods each year. But in 2008 through 2010, flow in parts of the Monongahela River have been less than half than what they are typically, at this time of the year, according to the Army Corps of Engineers2.

[image removed]
Figure 1. Permitted surface water withdrawals in Pennsylvania are shown on the map, active as of April 2, 2010.

Figure 1 shows the permitted water withdrawals in Pennsylvania for commercial, industrial, and agricultural use, as well as the permitted water withdrawals for the oil and natural gas industry. There is a multitude of groups that rely on water withdrawals for their livelihood, including the oil and gas industry, labeled as red stars. The capacity of river flow to dilute pollutants to safe levels also depends on river flow, and has precise limits. The current assimilative capacity for pollution and TDS in the Monongahela River is showing signs of saturation, and is characteristically oversaturated during the dry season. Monongahela River communities are already urged to rely on bottled water rather than their own municipal tap water, for certain periods of the year. Therefore, at the current rate of natural gas industry water withdrawals, there is no longer any room left for further economic development of water resources in other sectors of industry within the Monongahela River basin, if public health is to be conserved.

The current water management practices of the natural gas industry during the regional dry season are likely to have contributed to higher TDS concentration in the Monongahela River. New regulations for treatment and discharge of wastewater are designed so that the wastewater does not result in a severe impact, but the issue of mediating sustainable withdrawals has not been addressed. The majority of the pollution in the Monongahela River is still suspected to be caused by issues of legacy pollution, such as extensive acid mine drainage within the watershed3. On the other hand, the water withdrawals in the Monongahela River watershed are potentially causing a cumulative impact on flow volume in the river that magnifies all forms of pollution by increasing the pollutant concentrations. Much more research needs to be conducted on this issue, to ensure safe and sustainable permitting practices for water withdrawals.

References

  1. Penn State University, College of Agricultural Sciences, Agricultural Research and Cooperative Extension. 2010. Shaping proposed changes to Pennsylvania’s total dissolved solids standard, a guide to the proposal and the commenting process.
  2. Puko, Tim. Silty Salty Monongahela River at risk from pollutants. Tuesday August 24, 2010. Pittsburgh Tribune Review.
  3. Anderson, Robert M. Beer, Kevin M. Buckwalter, Theodore F. Clark, Mary E. McAuley Steven D. Sams, James I. Williams, Donald R. 2000. Water Quality in the Allegheny and Monongahela River Basins. USGS circular 1202.

Marcellus Shale Production Data – The Good, The Bad, The Ugly

By Matt Kelso – CHEC Data Manager

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As of September 7th, 55 of 73 drilling companies that operate in the Marcellus Shale field in Pennsylvania have reported their production data, which has been compiled into a single Excel spreadsheet by the Pennsylvania Department of Environmental Protection (PA DEP). Click here to see the list. This dataset is quite raw, and far from complete. Even so, a review of the preliminary data is a worthwhile exercise, as it gives us some insight into the industry that we were unaware of before.

Production Overview

Before getting into the specifics of production, a few overall numbers for the state would be appropriate. Altogether, there were 5,678 rows of data, representing 3,954 distinct wells. Only 3,076 of the rows have production data.

Production refers not only to oil and gas, but to waste products, as well. The spreadsheet tracks production data in the following categories: Basic Sediment, Brine, Condensate, Drill Cuttings, Drilling, Frac Fluid, Gas, and Oil. It is not known whether the final release of the data, which is scheduled for November 2010, will have a greater or fewer number of categories. The data comes unsorted and without explanation, so the units of measure for all categories are not entirely certain at this time.

Basic Sediment

The first category, Basic Sediment, is a solitary occurrence, and the volume of production is listed as 1,179. Whether this reported amount is miscategorized, irrelevant, or just exceedingly rare is not known at this time. The exact nature of what Basic Sediments refers to is not clear at this time, either.

Brine

Eight hundred-one (801) of the reported Marcellus wells produced brine, with volumes ranging from 2 to 24,165. For the moment, there is no choice but to assume that all of this is reported in the same unit, which will be assumed to be gallons. To give an idea of distribution, some arbitrary comparisons have been made here as well: 149 of the 800 wells have brine production of 100 or less, and 12 of them have production of 10,000 or more. The total brine production reported statewide was 1,196,001.19.

Condensate

Condensate is presumed to be waste water from the process of removing gas that comes to the surface embedded in water, which must then be extracted in condensate tanks. Of all of the wells in the state, 124 reported on Condensate, but the vast majority of those came back with a volume of zero. There are eight wells that reported non-zero volumes, and those range from 18.08 to 113,096.34 for a total of 187,855.85 units.

Drill Cuttings

Drill Cuttings is the term used to describe the rocks and sediments that are removed in order to make the original well. There are ten items in this category, which range in value from 250 units to 8,527, for a statewide total of 15,594.07 units. The measure of unit is again unknown.

Drilling

The distinction between Drilling and Drill Cuttings is not clear at this time. Four hundred ninety-seven (497) wells reported production in this category, yielding between 0 and 27,200 units of product for a statewide total of 898117.53. As a point of comparison, 291 of the 497 wells produced 1,000 units or less, while 15 wells produced 10,000 units or more. Uncertainties about the unit of measure that were expressed in the Drill Cuttings section apply here, as well.

Frac Fluid

The following category is Frac Fluid, which should refer to the chemical additives that make up one percent or less of the solution that is injected into the wells to release pockets of gas which are trapped in the shale deposits. According to this data, however, statewide production in this category exceeds the production of Brine, which is the term usually used to describe the salty waste water that comes up from the wells that would include the Frac Fluid as a small component. We must, therefore, question whether there might be some discrepancies in the way in which different companies report their data, or whether the results are due to a simple unit of measure issue. At any rate, there are 383 wells reporting Frac Fluid production statewide for a total of 1,621,721.19 units, with individual values ranging from 0 to 32,778. Of those 383 wells, 157 produced 1,000 units or less, while 54 produced 10,000 units or more, and gallons seems like the most likely unit of measure.

Gas and Oil Production

Production by Reporting Operator

There are 872 wells with production information for gas, of which 240 wells are reporting zero gas production. Of the remaining 632 wells, production values range from 29 to 2,841,152 units for a statewide total of 179,779,048. According to http://geology.com/usgs/marcellus-shale/, production at the wellhead level is commonly recorded in terms of thousands of cubic feet (MCF), which would put the reported production of the Marcellus Shale wells in the state at about 180 billion cubic feet (BCF) for the year. Of the 632 wells with non-zero values, 271 produced 100 million cubic feet (MMCF) or less, while 360 produced more than that amount.

There is also oil production associated with the Marcellus Shale drilling operations, and values in this category have been recorded for 385 wells in the state. Only 155 of these wells have a production value other than zero, however. Values range from 10.76 to 20,741.66 units, which are presumed to be barrels, for a statewide total of 402,253.38 barrels.

In addition to these categories, there are also 2,600 records that are included in the report but don’t have production data for any of the categories. These are distinct from items in the categories listed above with a listed production volume of zero.

A Significant Undertaking and Further Discussion

Credit should be given to the PA DEP for undertaking the project of mandating and publishing production reporting of the Marcellus Shale gas extraction industry in the state. Further credit should be given since this data was provided well ahead of the planned release date of November 1, 2010. And they should be praised for publicly listing companies that were not in compliance with the regulations that demand the production reporting in the first place (click here to see the list of 33 compliant and 40 non-compliant companies).

But when you take the time to look at the data, the thing that stands out more than anything is that it is a disorganized mess. It is clearly incomplete; all forms of production are tossed into the same column, and no units of measure are provided for anything. Compare that with the records kept by Arkansas or Texas.

9/27/10 Updates…

A non-profit stakeholder group called STRONGER, State Review of Oil and Natural Gas Environmental Regulations, Inc., recently assessed the quality of the Pennsylvania’s hydraulic fracturing oversight program and presented the results in a report. In this report, STRONGER praised the strength of the PA DEP’s waste identification tracking and reporting process – In other states, production data are being tracked more extensively, but waste data are limited at best. Along those same lines, legislation is being proposed that will require more extensive reporting obligations on the part of well operators.

Mon River Declared ‘Impaired’

By Tim Puko
Reposted from the Pittsburgh Tribune-Review

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The Monongahela River is at a crossroads. 

Not just at the Point, where the dark, silty Mon — lifeblood to heavy industry — merges with the clearer Allegheny. The Mon might be one of the country’s most endangered rivers, according to scientists studying the river.

Since 2008, the river has filled each summer with levels of contaminants higher than in at least 10 years. What role the region’s gas boom might play in the pollution is unknown. State environmental officials are employing stronger regulations and may ask for federal intervention to save the river from new threats and a legacy of mine pollution…

… This spring, the DEP began the process to have the river designated as “impaired,” which would allow the federal government to set standards for river polluting. The Environmental Protection Agency would commission a study to determine limits for industrial dumping of total dissolved solids in the river.


To give you an idea of some of the water management issues facing the Mon and western PA, below is a snapshot created by Kyle Ferrar of CHEC. Natural gas drilling and hydrofracturing wastewaters are being discharged into surface water locations at the points marked with red stars. Surface water withdrawals classified as agricultural, commercial, industrial, and mineral are identified on surface waters with the diamonds.

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Also, read this Pittsburgh Post-Gazette article about a recent public health presentation conducted by Dan Volz, Chuck Christen, and Samantha Malone of CHEC that discusses the contaminants estimated to be entering the Mon from facilities receiving natural gas drilling waste fluids.

For those who live in the four-state river basin where DRBC controls drilling development [image removed] … the Delaware River Basin Commission issued a moratorium on further Marcellus drilling while they prepare regulations. The DRBC is one of the first regulatory agencies to impose such a restriction.