On a trip through Pennsylvania’s Allegheny National Forest (ANF), you’ll of course see trees, streams, and wildlife. But what might come as a surprise is all the industrial equipment along the road and jutting out from weedy clearings. As you hike or drive along, you might notice strong, unnatural odors. If you venture into the deep woods, you’ll stumble upon thousands of older conventional oil and gas sites that dot the half a million acres of the ANF.
Some of these sites are still churning out oil and gas. Others are rusty and silent. But no one –not the companies that own them nor the regulators charged with overseeing them–can say for sure how many of these oil and gas wells are polluting, or how much.
Last month, Earthworks’ staff Pete Dronkers and Melissa Troutman found some dramatic examples of these leaky, poorly maintained wells in the ANF. Equipped with a map of problematic sites identified by partner organization Save Our Streams PA and using one of Earthworks’ infrared optical gas imaging (OGI) cameras, they discovered gas leaks at two of the sites they visited.
Earthworks reported the leaks to the US Forest Service and the PA Department of Environmental Protection (DEP). Fortunately, DEP promptly sent inspectors to the sites, confirmed the leaks, fixed one leak, and told an operator to fix another. During its inspections, DEP also discovered a possible well casing defect and detected gas levels in the air that could have reached explosive levels if not repaired.
But our subsequent investigation of these wells and DEP’s records indicated even bigger problems with these older, conventional wells. The most recent inspections of the two wells we filmed were conducted in 2013 and 2014–meaning the wells could potentially have been leaking unabated for years. Not enough inspections equates unnecessary risk–like the possibility of explosion–and pollution that harms health and impacts the climate.
The rules dictating how often inspections must occur–and how much pollution is permissible– hinge on the status of the well. If DEP deems a well to be “active,” as their records classify these two wells in the ANF, then by law there is no limit to the amount of methane and air toxics the well can emit. Our investigation of the DEP’s most recent production data, however, showed that although DEP has classified these wells in active status, they haven’t reported producing any oil or gas to DEP in at least the last five years.
Put another way, for the same period that these wells may have been leaking air pollution and wasting oil and gas, they have reported no contribution to the state in the form of energy resources or tax revenue.
The operators of these and many other wells across Pennsylvania may have a highly advantageous loophole in the state’s severely outdated and limited regulations for conventional operations. By obtaining and maintaining “active” status for conventional wells that are actually inactive from a production standpoint, operators can allow their wells to vent pollution without any limits on the volume. The only limitation on pollution is for inactive conventional wells (though still considerable at 5,000 cubic feet of gas per day). Conventional well regulations leave it up to operators to apply for “inactive” status, but the lack of emission limits for wells in “active status” creates a disincentive to do so.
Yet, regardless of status, leaks and other emissions at conventional wells may not trigger much enforcement action from DEP because of how the agency interprets the regulations. The conventional well regulations, found in Chapter 78 of the Pennsylvania Code, call upon DEP to address the venting of pollution that causes a threat to “public health and safety,” but do not give inspectors and regulators any guidance on defining those broad terms.
Leaking wells emit both methane that harms the climate and toxic air pollutants that degrade air quality and harm health. Just because wells are in forested areas and distant from homes and people doesn’t make them “safe,” because air pollution travels. Ample research has established that air pollution from Marcellus shale development is not confined to the site of emissions and can cross hundreds of miles.
While we may not know how many older, conventional wells throughout the state are leaking unchecked and potentially misclassified as “active,” we do know that the amount of gas they are losing is significant. In 2016, a peer-reviewed study on methane leaks from oil and gas operations in the Marcellus Shale region concluded that conventional wells have far higher leakage rates than unconventional ones (what are often called hydraulically fractured or “fracked” wells) due to a greater prevalence of equipment maintenance problems. The wells in the study had a median leakage rate of 11% (ranging from 0.35-91%).
According to the DEP oil and gas production reporting database, conventional wells statewide produced nearly 112 million Mcf of gas in 2017. An 11% leakage rate would mean the release of over 12 million Mcf of gas into the atmosphere–more than 5% of Pennsylvania’s residential consumption of natural gas in 2017.
Fixing the problem
All oil and gas operations need more oversight from inspectors enforcing regulations. But those already sparse protections are under threat. Until September, these two oil wells in the Allegheny Forest–and an untold number like them–were subject to federal rules. But this month has seen the Trump administration dismantle the Bureau of Land Management (BLM) rules that limited the waste of natural gas–and the air pollution that comes with it–from oil and gas wells on US Forest Service and other public lands.
The loss of the BLM waste rule makes state-level regulations even more crucial. But in the same month, a handful of Pennsylvania legislators made a second attempt at rolling back existing safeguards on conventional wells with House Bill 2154. Among the many problems with HB 2154, it would allow well permits to last forever as long as the well is called “active.” This misguided proposal–which would revert the rules back to where they stood 34 years ago–would only make it easier for problems like potentially explosive leaks or damaged well casings to go undetected, and for their owners to shirk their obligation to fix them.
Fortunately, Pennsylvanians and environmental groups are speaking out against HB 2154, which is yet another free ride for the conventional oil and gas industry after effectively killing updated regulations in 2016. Governor Wolf has said he plans to veto the bill, should it make it to his desk.
There’s hope, too, in the form of soon-to-be released state rules to help reduce methane and other air pollution from existing oil and gas facilities, which the DEP promises for early 2019. Those rules should include conventional as well as shale operations, unlike the new permits that only address pollution from the latter.
No operators should get a free pass when it comes to controlling the pollution their wells cause. As the leaky wells in the ANF have shown us, conventional wells emit serious pollution and present other problems that demand more–not less–oversight.