PennEnvironment Marcellus Shale Violations Report Half-Baked

February 11, 2012

Open up most papers this week and you will find a rather startling headline.  In all of its forms, it reads along the lines of: natural gas developers cited for 3,355 violations in four years.  Unfortunately, that is where the story ends in most media accounts.  It’s far from the worst reporting we’ve seen, but it certainly lacks context.  Here we provide that context so folks who live in the heart of the Marcellus Shale can understand exactly what is happening.  It’s nothing like the simplistic story told by the report.

Penn Environment  authored the report.  It seems it was prepared to generate just the splash it received.  With that,  let’s take a closer look at the numbers.  3,355 violations breaks down, on average, to about 835 per year.  Stopping here would still leave half the story untold. To gain full understanding it’s important to understand the number of Marcellus wells developed over the same period.  That number, according to the Pennsylvania Department of Environmental Protection, is approximately 4,671 (slightly higher than the 4,596 PennEnvironment reports).  Dividing the violations by the number of wells results in a total of 0.72 violations per well.  Let me repeat that, we get a total of 0.72 violations per well!  Interestingly, PennEnvironment left that part out.  The below graphic provides a good understanding of  how it all  stacks up:

Pennsylvania Marcellus Shale Wells vs. Violations, 2008-2011

Pennsylvania Marcellus Shale Wells vs. Violations, 2008-2011

More importantly, these violations have been decreasing while natural gas development in the Commonwealth has spiked.  For example,  the number of wells developed last year increased by 426, while the number of violations decreased by 95.  Peeling back another layer, the number of enforcement actions (or significant violations that result in additional action) dropped by a staggering 140.  This trend, combined with the recently announced regulatory compliance tool from IPAA, not to mention FracFocus, clearly highlights the industry-wide commitment to responsible operation and environmental success.  In fact, of these 3,355 violations only 925 have warranted enforcement action.  This lends quite a different story than what PennEnvironment put out for public consumption. This is important information to know when discussing something that is shaping Pennsylvania’s economy, providing hundreds of thousands of jobs, and increasing our energy independence.

Instead of including this needed perspective most reporters bit hook line and sinker at the bait provided by Penn Environment. The same group that  floated a picture of a flooded natural gas rig in Pakistan claiming it was located in Pennsylvania.  Remember?  Like that picture, this report lacks context. Although context, and at times truthfulness, is something PennEnvironment lacks when commenting on natural gas development in the Commonwealth.

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Comments

So a 72% rate of violation is

So a 72% rate of violation is OK really? glad you are dealing with a highly regulated industry say like pharmaceutics where that rate would cause the FDA to shut you down and throw away the key.

If a petroleum refinery had a 72% violation rate it would also be shut down.

Talking about a spin on bad news this is top is almost at the sound barrier!

72%??? Redo that Math, Genius.

A .72 violations per well does not a 72% rate make, unless you call a single violation per well, where thousands of violations are possible, a 100% rate. Have you even bothered to understand exactly what a violation is?

That would be like saying that all drivers are completely unsafe because 98% of them have received parking tickets, speeding tickets, broken taillight warnings, or have crossed a solid yellow line more than once.

Seriously... think before you post.

EID SHILLS

EID half baked and all owned by gas/oil industry

Connecting the Dots: The Marcellus Natural Gas Play Players – Part 3
By Dory Hippauf
Energy-in-Depth (EID): The “GAS”roots
http://commonsense2.com/2012/02/naturalgasdrilling/connecting-the-dots-t...

Violations

A misrepresentation presents itself to viewers in terms of violations as being of a very serious nature. For example, in the trucking industry we have random inspections upon the trucks utilizing the roadways. There is a whole book of regulations that can be used to find a violation during an inspection. Here, though, is a difference; if a truck has a safety issue, such as bad brakes, that truck can be put out of service on the spot. In some areas a violation can be as small as tail light bulb that blew out just minutes before you pulled into a weigh station, hardly a serious safety issue during the daytime.

The same holds true for the O&G industry, for example, a leak can be called a violation but what was the size of the leak in question a Valdez or minor seepage of a packing gland? What about a violation charged against a O&G for a spillage that had resulted from a traffic accident, hardly a oil well incident.

Perhaps there should be a tier approach to the listing of violations that would better describe what the violation consisted of is in order.

Violations

Even more relevant would be the number of inspections performed versus the violations recorded. After all, fewer inspections means fewer violations. Is the industry actually doing better work, or is the DEP just unable to keep up? It would be good information to know just how many times each well and well pad is inspected during its development; according to what I've read, they are to be inspected many times during the process. Having all that information would allow us to know just how well the industry is performing AND how well the DEP is monitoring the process to keep PA's citizens and environment safe.

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