In 2010 The Pennsylvania Department of Environmental Protection (PADEP) volunteered to have its hydraulic fracturing program reviewed by The State Review of Oil and Natural Gas Environmental Regulations, Inc (STRONGER).
STRONGER reviews regulations, identifies issues and makes recommendations to the state to address identified issues. The review team was comprised of three team members and four official observers. The three team members were: Lori Wrotenbery, Oil and Gas Conservation Division of the Oklahoma Corporation Commission; Wilma Subra, Subra Co., New Iberia, Louisiana; and Jim Collins, Independent Petroleum Association of America. The official observers were: Tom Au, Pennsylvania Chapter of the Sierra Club; Steve Rhoads, East Resources; Brad Field, Division of Mineral Resources of the New York Department of Environmental Conservation; and Dave Rectenwald, U.S. Environmental Protection Agency.
According to STRONGER, the review began with a questionnaire that was prepared by the STRONGER Board which was intended to capture the status of Pennsylvania's Hydraulic Fracturing Guidelines. Following the review, STRONGER compiled a review report which made recommendations for improvements in the regulations which govern hydraulic fracturing. One of recommendations STRONGER made to the Pennsylvania Department of Environmental Protection was the following:
The review team recommends that DEP consider whether there are areas or situations in which wells (active and abandoned) in the vicinity of hydraulic fracturing operations provide pathways for fluid movement into groundwater. In such areas or situations, DEP should require operators to identify and eliminate these potential pathways for fluid movement into groundwater before conducting hydraulic fracturing operations.
August of 2102 The Office of Oil and Gas Management (OOGM) Technical Advisory board's 'Summary of Proposed Conceptual Changes (with brief justifications)' Draft report recommended the following changes to Title 25 Pa. Code Chapter 78:
Propose adding a requirement that a well operator identify on the well permit application the location of abandoned gas or oil wells within 1000 feet of the entire well bore length. This requirement comports with a recommendation made by STRONGER to prevent communication between wells.
On March 8, 2011, Tom Corbett, established the Governor's Marcellus Shale Advisory Commission. The purpose of the Commission was to develop a comprehensive, proposal for the responsible and environmentally sound development of Marcellus Shale. This commission was comprised of industry stakeholders, members from the environmental community, natural gas industry, local government representatives and state government officials.
One of the responsibilities of the commission was to review the existing and proposed statutes, legislation, regulation and policies that regulate or affect Marcellus Shale natural gas development and to provide "analysis and recommendations." and to submit a final report on before July 22, 2011. The commission's final report recognized abandoned wells provide pathways for contamination stating:
New wells drilled through a formation that has previously been drilled and fractured present a potential pathway for groundwater contamination. This potential pathway for contamination must be addressed through the application of well casing and construction standards.
Continue reading...