2017 Oil and Gas Annual Report

Of the 3,273 violations for conventional wells, 1,470 were administrative-related violations and 1,803 were environmental health and safety-related violations.

• Of the 1,470 administrative violations, 454 of these violations were signage-related violations for “failure to post the operators name, contact information, permit number and registration number at the well site”, 516 violations were for “failure to submit an annual production report”, and 391 violations were for “failure to conduct quarterly well integrity inspections or submit an annual report to DEP identifying the compliance status of each well with the mechanical integrity requirements.” The remaining administrative-related violations were distributed among 20 additional violation categories.


• Of the 1,803 environmental health and safety-related violations, 745 of these violations were for “failure to plug the well upon abandoning it”, 145 violations were for “failure to properly store, transport, process or dispose of a residual waste”, 134 were for “failure to control well drilling fluids…in a manner to prevent pollution of waters of the Commonwealth”, 146 were for “failure to collect brine and drilling fluids in an approved tank or for discharge onto the ground or into the waters of the commonwealth.” The remaining environmental health and safety-related violations were distributed among 63 additional violation categories.

Of the 821 violations at unconventional wells, 67 were administrative-related violations and 754 were environmental health and safety-related violations.

• Of the 754 environmental health and safety-related violations 65 were for “failure to properly store, transport, process or dispose of a residual waste”, 56 were for “conducting an activity…without a permit or contrary to a permit issued by DEP”, 56 were for “failure to prevent gas flow in the well annulus…”, 49 were for “failure to plug a well upon abandoning it”, 42 were for “conducting casing and cementing activities that failed to prevent pollution or diminution of fresh groundwater”. The remaining violations were distributed among 66 other violation categories.


• Of the 67 administrative violations, 23 were for “failure to comply with the terms of a permit while drilling, altering or operating an oil or gas well.” The remaining violations were distributed among 20 violation categories.

Equipment Fire at Unconventional Well Site, Somerset Township, Washington County:   On January 1, a fire erupted at an unconventional well site. The Southwest District Oil and Gas Office dispatched an inspector and supervisor to the scene. The initial investigation indicated that a pump used in the hydraulic fracturing process failed, resulting in a piece of the engine disrupting the fuel system. The fire was brought under control, and no injuries occurred as a result of this incident.

Review of Eligibility Standards for Expedited Review of Erosion and Sediment Control General Permits (ESCGP-2):   On January 4, DEP issued a press release announcing the planned revision of the eligibility standards for expedited review of ESCGP-2 applications related to oil and gas drilling. ESCGP-2 applications are for earth disturbance of more than five acres for oil and gas projects. Under the general permit, projects that meet objective criteria are eligible for a 14-day permit review. The revisions follow an internal review that analyzed the program’s consistency and effectiveness from its launch in February 2014 through January 2016. The review revealed that the expedited process has limited application because almost 60 percent of the permit applications submitted to DEP had technical deficiencies. The review can be found here.

Legacy Well Integrity and Emissions Study Update:   The Well Plugging and Subsurface Activities Division of the Oil and Gas Program started evaluating data collected as part of DEP’s legacy well field study. The study was designed to assess DEP’s plugging liability and explore opportunities to advance the program’s mission. It is anticipated that the results of this study will make it possible to better quantify the department’s plugging liability, allow DEP to explore different funding models to address the state's legacy well problem, and inform regulatory program activities considerate of environmental risk.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On January 11, DEP’s Office of Oil and Gas Management met with DEP’s mining program, federal Mine Safety and Health Administration technical staff, and coal and gas industry representatives as part of the Oil and Gas Technical Advisory Board’s Coal/Gas Committee to discuss matters relating to coordination between the two industries. The meeting entailed the first detailed discussion of the coal pillar permit process since the committee was formed in March 2016.

Inter-Agency Coordination with DCNR - Seismic Monitoring Protocol:    The Oil and Gas Program met with Department of Conservation and Natural Resources (DCNR) staff and a representative of the Pennsylvania Seismic Network on February 6 to discuss development of Standard Operating Procedures related to seismic responses for Underground Injection Control wells and Utica Shale gas well development in the commonwealth.

Inter-Agency Coordination with DCNR – Chapter 78, Subchapter C Implementation:    DEP oil and gas staff met with DCNR staff, on February 7, to discuss implementation matters relating to the Area of Review (AOR) provisions of 25 Pa. Code Chapter 78a. As one of the largest land managers in the state, DCNR receives landowner questionnaires as per Pa. Code § 78a.52a(b)(3) from unconventional operators intending to drill wells on state-held lands. DEP provided a training session on the landowner questionnaire process and reviewed a hydraulic fracturing communication risk model.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On February 14, the Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff and coal and gas industry representatives as part of the Oil and Gas Technical Advisory Board’s Coal/Gas Committee to discuss matters relating to coordination between the two industries. The group reviewed an updated process map detailing matters relating to coal pillar permitting and inactivation/temporary abandonment of gas wells in advance of mining.

Release of Report on Induced Seismicity DEP Lawrence County Report:    On February 17, DEP conducted a media webinar and released findings relating to a series of low-magnitude earthquakes detected on April 25, 2016, in North Beaver, Union, and Mahoning Townships. The earthquakes, which were near 2 on the Richter Scale, are classified as microseismic events - likely to go unnoticed by humans and typically only recorded by sensitive seismic monitors. An unconventional gas operator was in the process of stimulating Utica Shale wells using a technique known as “zipper fracturing,” or hydraulic fracturing operations that are carried out concurrently at two parallel and adjacent horizontal wellbores. DEP conducted an analysis and published the results of its findings on the day of the webinar. DEP investigators found a marked temporal/spatial relationship to hydraulic fracturing activities at the operator’s well pad and concluded the seismic events were likely related to the natural gas hydraulic fracturing by the operator. As a result, DEP developed recommendations to mitigate risks associated with induced seismicity that have been adopted by the operator and will appear as permit conditions in future drilling permits issued in the Utica Shale region of the state. The Office of Oil and Gas Management announced plans to develop a rulemaking to address induced seismicity for Utica Shale development as an “area of alternative methods” in accordance with 25 Pa. Code § 78a.75a to develop area-specific rules in parts of the state where conditions warrant.

Public Oil and Gas eSubmission Viewer:    The Office of Oil and Gas Management released an application to enable the public to view electronic submissions made by operators through the eSubmission application. This application is accessible on the “Oil and Gas Reports” web page, under the heading “Interactive Applications” and can be viewed at this link. Users can search for submissions based on various criteria, including but not limited to: submission type, submitter (operator), county, municipality, and date range. Currently, all eSubmission types, except pre-drill data, are available via this tool.

Trade Secret/Confidential Proprietary Information (CPI) Chemical Code List:    The Office of Oil and Gas Management released a list of chemical codes that relate to trade secret/CPI that are registered with DEP. This report does not contain any trade secret/CPI information; rather it lists a unique code that is assigned to the chemical which is on file at DEP. The list includes the name of the organization that registered the chemical/code, its eFACTS client ID number, and the code assigned to each respective chemical. The list is available on the “Oil and Gas Reports” web page, under the heading “Non-Interactive Reports” and can be viewed here. The list will be updated as additional submissions are received.

Well Bore Deviation Workgroup:    On March 15, the Office of Oil and Gas Management completed a preliminary discussion about the development of a joint DEP/oil and gas industry workgroup to better understand well bore deviations from the well bore path depicted in the well permit. This issue arose when an unconventional gas operator voluntarily disclosed that wells it had acquired were drilled with varying degrees of deviations compared to what was authorized on the well permit. The workgroup plans to address the frequency of well bore deviation and how operators may report information to DEP relating to the “as drilled” location of well bores in a manner that lends itself to digital mapping.

Emergency Well Plugging Response:    An abandoned gas well located in a mobile home park in Canton Township, Washington County, was found to be leaking natural gas and required DEP to enter into an emergency contract to plug the well. DEP emergency response and oil and gas program staff responded to the situation and conducted continuous monitoring. Residents within 100 feet of the well were evacuated before the response commenced. The well was successfully plugged and the site was restored on March 17.

Allegheny County Legacy Wells Story Map:    DEP oil and gas staff met with members of other state agencies, federal government colleagues, private sector consultants, and representatives from academia at the Geological Society of America Northeastern/North-Central Joint Section Meeting on March 20. DEP unveiled a “story map” depicting historical oil and gas development in Allegheny County. This web-based tool depicts aerial imagery for Allegheny County overlying a historical oil and gas legacy development map. Users can access the tool to explore historical oil and gas development activity in the area. Known locations of conventional and unconventional wells from the DEP database and historic wells digitized from mine maps are also depicted. The goal of this project is to make the public aware of the extensive oil and gas development that occurred in Allegheny county and educate interested individuals about potential environmental issues associated with legacy wells. DEP estimates that somewhere between $150 million and $3.7 billion is needed to address this environmental challenge. DEP’s Legacy Well Integrity and Emissions Study and the story map represent a significant step that DEP has taken to inform the public and scientific community; and to educate the public about legacy oil and gas development in Pennsylvania.

Tri-State Well Plugging Summit:    Oil and Gas Program staff met with regulatory officials from Ohio and West Virginia and plugging contractors to discuss matters relating to legacy well management. The meeting was coordinated by the DEP Well Plugging and Subsurface Activities Division on March 30. Meeting participants discussed neighboring state’s plugging programs, regulations, staff/structure, funding, contracting processes, and costs. Meeting topics also included alternative funding sources, studies, improving visibility, and showcasing some of Pennsylvania’s regulatory and statutory provisions related to legacy wells, including Area of Review, Good Samaritan Law, and the well adoption permit process.

Pennsylvania Seismic Network Training:    The Office of Oil and Gas Management met with DCNR and representatives of the Pennsylvania Seismic Network on March 28. Both agencies received training on seismic analysis, including details on the Pennsylvania Seismic Network, location detection of earthquakes, how to differentiate mine blasting events and/or false readings from tectonic seismic events.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On March 23, the Office of Oil and Gas Management met with DEP’s mining program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives as part of the Oil and Gas TAB’s Coal/Gas Committee to discuss matters relating to coordination between the two industries. The committee focused on procedural matters regarding the safe “mining through” of wells by coal mine operators. The primary objective of the committee is to memorialize a written policy that is acceptable to all affected agencies.

Underground Injection Control Permit Issued:    On March 27, DEP issued an injection disposal permit to Seneca Resources. The disposal well located in Highland Township, Elk County will be used to inject fluids produced solely from Seneca Resources’ oil and gas production activities. The U.S. Environmental Protection Agency issued a Class II disposal underground injection control permit for this activity on January 28, 2014.

Oil and Gas Technical Advisory Board:    At a regularly scheduled meeting on April 13, TAB discussed the draft “Pressure Barrier Technical Guidance for Unconventional Operations,” “Guidelines for the Development and Implementation of Oil and Gas Well Site Integrated Contingency Plans for Unconventional Well Sites,” “Area of Review Technical Guidance Document,” and “Water Supply Technical Guidance Document.” The board also discussed the General Permit-5, a report from a member of the “Coal-Gas Coordination Workgroup,” and a discussion about the formation of various technical workgroups. A recording of this meeting is available on the DEP website.

Mobile Inspection Platform Development:   DEP’s Mobile Inspection Platform Team met with GIS developers on April 3 to discuss future enhancements to the inspection/investigation process for specialists and inspectors in DEP’s oil and gas program. The group agreed to start development of a smaller, pilot project for GIS enhancements. The Mobile Inspection Platform Team has predominantly focused on the development/rollout of the surface and subsurface inspection applications through coordination with PennDOT’s IT experts. For future integration that will enhance DEP’s mobile capabilities, the team discussed tools such as the complaint tracking system, sample information system, mechanical integrity assessment, storage field data, and other components.

eWell, Online Oil and Gas Well Permitting Application:   On April 18, as part of a commonwealth-wide project being managed by the Office of Administration, DEP’s eWell permit application was transitioned to a new online payment processing gateway. The new “Payeezy” gateway allows well permit applicants to pay by electronic check, in addition to the existing credit card payment option.

Well Plugging Response Action:   DEP’s oil and gas program successfully completed oversight of the permanent plugging of an abandoned well located in Glen Osborne Borough, Allegheny County. The well situated adjacent to Glen Mitchell Road on a steep hillside, was observed to be leaking oil to the surrounding soil. Due to landslide concerns identified at the well site, an engineering consultant was contracted to provide geotechnical support and expertise.

Citizen’s Advisory Council Meeting Presentation:   On April 18, Office of Oil and Gas Management staff updated the council on the investigation surrounding the induced seismic events that occurred in Lawrence County. DEP also discussed modifications to the Underground Injection Control program permitting process that is aimed at mitigating induced seismicity and ensuring containment of the injection zone and the injection well.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On April 19, the Office of Oil and Gas Management met with the DEP mining program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. DEP staff clarified the agency’s role in reviewing permits aimed at safely taking active natural gas wells out of production in advance of mining operations. Committee members also discussed technical matters relating to development mining and mine floor stability analysis.

Outreach to Oil and Gas GreenPort Users:    GreenPort users were informed that DEP developed an “Oil and Gas Operator Email Registration” form. This form is intended to allow an operator to provide an Email address that will enable DEP to deliver electronically generated records and communications to the operator. Initially, this will include inspection reports generated using DEP’s inspection mobile app and general notifications/updates. Eventually, this may include additional records and/or communications as DEP develops additional electronic data management systems. Also, oil and gas operators may submit well logs to DEP in an electronic format through the eSubmission application rather than mailing them. Although operators may still submit well logs in paper format, this tool allows operators to submit well log information in a more efficient and timely manner. Well Logs have been added to the list of values under “Select Type of Submission”. With the exception of confidential and proprietary information, any records submitted via eSubmission are available to the public.

Legacy Well Study, Interactive Mapping Tool, and Plugging Program Video:    On May 9, the Office of Oil and Gas Management worked with the DEP Office of Communications to release several new technical and public outreach media tools. This event was part of a larger effort to inform stakeholders about the full scope of the environmental and public safety challenges posed by legacy oil and gas development in Pennsylvania. The tools include the Legacy Well Integrity and Emissions Study , an interactive mapping application that reveals patterns of historical drilling in portions of Allegheny County, and a DEP YouTube Channel video discussing some of the challenges DEP faces with the management of the commonwealth’s growing legacy well population.

eSubmission Application Enhancements:    The Office of Oil and Gas Management worked with the DEP Bureau of Information Technology to develop enhancements to the eSubmission application. Operators now have the option to submit a select number of forms and requests associated with conventional well operations using the eSubmission applications.

Submissions includes:

• Well Record
• Completion Report
• Pre-Drill Survey Sample Results
• Request Alternate Waste Management Practice
• Well Logs
• Well Site Restoration Period Extension Request
• Well Site Restoration Report

The eSubmission User Guide was also updated to reflect these enhancements and provides step-by-step instructions on how operators can use this tool. This user guide is located at the Oil and Gas Electronic Submission Guides webpage .

Pennsylvania Groundwater Symposium:   Oil and Gas Program staff met with members of other state agencies, oil and gas operators, industry consultants, industry trade organization representatives, and academia at the Pennsylvania Groundwater Symposium on May 3 for the educational event hosted by the Pennsylvania State College of Agricultural Sciences. The symposium content focused on groundwater and shale gas drilling, as well as groundwater monitoring and aquifer studies. The symposium included approximately 150 participants and included presentations and poster sessions on topics including groundwater monitoring, groundwater law and policy, baseline groundwater quality, methane monitoring in groundwater and existing groundwater database usage.

Interstate Oil and Gas Compact Commission (IOGCC) - State Oil and Gas Field Inspector Forum:    On May 7, the Office of Oil and Gas Management participated in the commission’s annual meeting along with representatives from 27 other oil and gas producing states. The purpose of this forum was to facilitate timely discussions and the sharing of information between members of the nation’s oil and gas producing states. This meeting provided a platform for inspection and compliance experts to share current issues from their state perspective and to discuss significant challenges that field inspectors face. Over 40 topics were discussed in five categories: General Well Inspection, Mechanical Integrity Testing, Waste Disposal, Public Relations and Reclamation.

Crude Development Advisory Council Produced Water and Legacy Well Committee Meeting:    The Oil and Gas Program met with council members and other stakeholders on May 4 to conduct committee work involving issues relating to produced water and legacy well management. Attendees reviewed current regulatory provisions relating to discharges to waters of the commonwealth, innovative brine treatment strategies, treatment costs, statewide produced water trends for conventional wells, and the current state of Pennsylvania’s Underground Injection Control Program. The council discussed ongoing research relating to plugging materials and legacy well-finding efforts, statewide production trends, abandoned well plugging activities and costs, and funding associated with the DEP Well Plugging Program. The group also reviewed provisions of the Good Samaritan Law and DCED’s Commonwealth Financing Authority’s Orphan and Abandoned Well Plugging Program.

DEP Oil and Gas Manager’s Meeting:   On May 16-17, Oil and Gas Program managers and legal counsel met to discuss operational and legal issues associated with the management of the DEP Office of Oil and Gas Management.

2017 Shale Network Workshop:   DEP Oil and Gas Program staff met with researchers, volunteer groups, and industry affiliates May 18 - 19 during the annual Shale Network Workshop. DEP staff, in collaboration with the Shale Network team and the Consortium of Universities for the Advancement of Hydrologic Science, Inc. (CUAHSI), led a classroom computer exercise where participants used a web-based database tool (compiled and managed by CUAHSI) to review stream impairments potentially resulting from the treatment of produced fluid at publicly operated treatment works, seismic event data compiled by the Pennsylvania Seismic Network and how the PA Oil and Gas Mapping tool can be used to identify areas where potential underground injection control wells could be sited. DEP presented a poster identifying the challenges related to the management of Pennsylvania’s legacy wells. DEP oil and gas staff also participated in a panel discussion with industry representatives and concerned citizens regarding the development of underground injection control well. Other presenters at the Shale Network Workshop discussed a variety of waste management topics, developments in the mitigation of risks associated with induced seismicity, stray gas migration and atmospheric methane flux, technologically enhanced naturally occurring radioactive material, and the regulatory framework related to blasting operations.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On May 24, the Office of Oil and Gas Management met with the DEP mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. An important milestone was reached in terms of assembling the pertinent data relevant for DEP to evaluate the issuance of a “Conditional” Coal Pillar Permit. The data submitted was partitioned into three components: Conditional Coal Pillar Permit, Inactive Status and Re-entry with long term monitoring. These data will be technically reviewed and utilized in the development of a first draft technical guidance document.

DEP Approves Permit for Underground Injection Control Well in Clearfield County:    On May 30, DEP approved an underground injection control Class II well permit for disposal of wastewater associated with oil and natural gas production. The disposal well is operated by Sammy-Mar, LLC, in Huston Township. The U.S Environmental Protection Agency issued an underground injection control permit for this well on March 16, 2016, to allow the company to inject wastewater into the well pending DEP approval of a drilling permit.

Air and Waste Management Association - Annual Conference and Exhibition:    On June 7, the DEP Southwest Oil and Gas District Manager participated in a panel discussion focused on regional oil and gas issues and the pending Air Quality General Permit for well sites, the new regulatory requirements resulting from the Chapter 78a rulemaking, and general discussion about the growth and environmental issues/impacts observed in southwestern Pennsylvania.

Technical Presentation at Marcellus Shale Coalition Stray Gas Committee Meeting:    On June 7, the program manager for the Well Plugging and Subsurface Activities Division gave a technical presentation to the Marcellus Shale Coalition Stray Gas Committee. The presentation included a summary of statistics on stray gas migration cases relating to unconventional oil and gas development, DEP research on stray gas migration, GIS tool development and a technical case study covering the analysis of time-series methane data and geologic controls on methane migration and the latest research being executed by academia.

Post Construction Stormwater Management Training:    The Bureau of Clean Water and DEP Southeast Regional Office, and Bureau of Waterways Engineering and Wetlands staff provided post construction stormwater management training on June 14 - 15. The primary audience included DEP’s oil and gas permitting staff who are responsible for review and issuance of Erosion and Sediment Control General Permits for oil and gas activities (i.e., ESCGP-2). The training goal was to improve consistency among district oil and gas offices and increase overall program efficiency related to stormwater permitting.

DEP and Pennsylvania Emergency Management Agency (PEMA) update to Emergency Response Plan Submissions:   The Office of Oil and Gas Management, with assistance from PEMA, completed a year-long initiative to allow for greater transparency, efficiency and accessibility to unconventional well site Emergency Response Plans (ERPs). Pennsylvania’s oil and gas regulations require unconventional operators to submit ERPs to DEP, PEMA, County Emergency Management Agencies, and the Public Safety Answering Point (PSAP) with jurisdiction over the well site. It also provides DEP with authority to implement the requirements of ERPs in coordination with PEMA. The DEP Oil and Gas Reporting Electronic (OGRE) system was enhanced in 2014 to allow unconventional operators to submit ERPs to DEP electronically. The ERPs are now available on the public Oil and Gas Mapping tool. To further streamline the overall ERP submittal process and to comply with 25 Pa. Code Chapter 78a, a submission through OGRE is now also considered to be a submission to PEMA, County Emergency Management Agencies and PSAP. On June 22, 2017, an email notification for this process improvement was sent to all OGRE registered users who submit ERPs to DEP. In addition, DEP notified oil and gas industry stakeholders of this enhancement.

Emergency Contract - Stay Gas Mitigation System Installation:    On June 26, the DEP Southwest Oil and Gas District Office oversaw the successful installation of a stray gas mitigation system in Franklin Park Borough, Allegheny County. The site is a residential property and the location was discovered by DEP during the process of conducting a legacy well study. The system that was installed successfully captured and vented stray subsurface methane gas, thus stabilizing the site and mitigating the risk to public safety.

New Forms Available in the Oil and Gas eSubmission Application:    Pursuant to 58 Pa.C.S. Section 3216 (g) and 25 Pa. Code § 78a.65(c) (relating to Site Restoration), 78a.59b(g) (relating to Well Development Impoundment) and 78a.67(c)(1) (relating to Borrow Pit), the site restoration period for a well development impoundment and borrow pit may be extended, for an additional period of time not to exceed two years, upon demonstration by the operator when certain conditions apply. On July 5, DEP released another enhancement to the oil and gas eSubmission application by making the following two new forms available on the DEP website:

• Well Development Impoundment Restoration Extension Request ( form and instructions) 8000-PM-OOGM0156U; and
• Borrow Pit Restoration Extension Request ( form and instructions) 8000-PM-OOGM0157U

The Bureau of Oil and Gas Planning and Program Management coordinated with the DEP Office of External Affairs to inform oil and gas industry trade groups about the availability of these new forms. DEP also forwarded a notice to oil and gas operators that are registered users of DEP’s Greenport system.

Good Samaritan Plugging Project Proposal Site Visit:    On July 7, Office of Oil and Gas Management staff met with representatives from the U.S. Forest Service and a conventional oil and gas operator to visit the site of a leaking oil well in the Allegheny National Forest, Warren County. The operator submitted a Good Samaritan Proposal to plug the oil well using its equipment and resources to address ongoing environmental impacts. Access to the densely forested, remote site was limited, and the location of the leaking well on a small island at the confluence of two exceptional-value streams further complicated action. This was the first Good Samaritan project aimed at plugging an abandoned well.

Emergency Well Plugging Contract:   The DEP Southwest District Oil and Gas Office oversaw the successful permanent plugging of an abandoned gas well at a residential property in Pittsburgh. The stray gas was discovered in March by a natural gas supplier while performing a routine leak survey in the neighborhood. The gas was emanating from a crack in the concrete porch floor located against the foundation of the residence, which posed significant challenges during the well plugging process. The plugging project was completed successfully on July 10.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On July 12, the Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. A significant milestone was achieved with the development of a draft technical guidance document intended to direct coordination activities between both industries in situations where a longwall mining company intends to mine around unconventional gas wells.

DEP Approves Permit for Underground Injection Control (UIC) Class II Disposal Well in Columbus Township, Warren County:    On August 3, the DEP Northwest District Oil and Gas Office issued a UIC Class II disposal well permit to Bear Lakes Enterprises. This well served as a former gas production well targeting Grimsby and Whirlpool Sandstones within the Medina Group and will be used to inject fluids related to oil and gas production activities. EPA issued a UIC Class II disposal well permit for this activity on November 10, 2014. This is the third disposal well issued to Bear Lakes in Columbus Township.

DEP Responds to Natural Gas Leak:   On August 4, the DEP Southwest District Oil and Gas Office was notified of a leaking natural gas production pipeline. While conducting excavation work in South Huntingdon Township, Westmoreland County, a local logging company accidentally struck a natural gas line, causing a leak. The line that was struck was a 2-inch low pressure gathering line that fed an 8-inch main line. Upon notification, DEP informed the Pennsylvania Emergency Management Agency and dispatched an inspector to the site. The logging crew was evacuated from this site during the site evaluation and response. The owner of the pipeline shut in the affected well, which stopped gas flow. As a precautionary measure, the company also shut in several other wells in the general vicinity. The operator repaired the gas line and placed it back into service within 24 hours.

EPA Bioremediation Webinar/Workshop:    The Oil and Gas Program, the U.S. Forest Service and industry partners hosted a technical webinar/workshop on August 3 relating to the application of bioremediation of crude oil releases in the context of well plugging and well site cleanup activities. EPA Region 3 presented to DEP District Oil and Gas Operations staff and operators from throughout the state, providing information on various bioremediation projects conducted using the Oil Spill Liability Trust Fund. Multiple case studies in Pennsylvania were discussed during the session, and topics included the fundamentals of bioremediation, mechanisms that have proven most successful for addressing oil releases and sampling procedures for evaluating the effectiveness of this remediation strategy. This effort is part of a broader partnership between the Crude Development Advisory Council legacy well subcommittee and oil and gas staff.

Emergency Well Plugging and Clean-up Response:    DEP Northwest District oil and gas staff completed the successful oversight of an emergency contract developed to permanently plug a well, complete site restoration and clean up a crude oil release at a site in Conneaut Township, Crawford County, and remove production fluids from a leaking tank at a well site in Canal Township, Venango County. DEP coordinated effectively with the prospective contractors to quickly prepare and execute a contract. Activities at the Venango County site were completed on August 2, and activities at the Crawford County site were completed by August 9.

Oil and Gas Technical Advisory Board Meeting:   At a regularly scheduled meeting on August 23, the board discussed suggested amendments to the current TAB bylaws, an update related to the development of various technical guidance documents and forms, an update on the draft GP5/GP5A permits, and a verbal report from the Coal-Gas Coordination Workgroup liaison. The Director of the DEP Bureau of Radiation Protection provided an update of the status of the Chapter 230 proposed rulemaking package.

DCNR and DEP Coordination of Legacy Well Management on State-Held Lands:   On August 14, staff from the Bureau of Oil and Gas Planning and Program Management met with DEP’s Emergency Response Director, Eastern District Oil and Gas Operations staff, DCNR, and an official from EPA Region 3 to discuss developments relating to the Oil Spill Liability Trust Fund and progress related to a well plugging project being planned within Sproul State Forest in Keating Township, Clinton County. This is an abandoned well leaking oil along Cooks Run. Due to the timing and access road challenges, it is anticipated that plugging activities will commence in mid-2018. The operation is expected to take about one month. Partnership such as this are critical at a time when DEP’s orphan and abandoned well plugging funds are limited.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On August 16, the Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. Committee members reviewed comments related to the first draft of the technical guidance document intended to direct coordination activities between both industries in situations where a longwall mining company intends to mine around unconventional gas wells. The committee discussed how coordination should occur across state borders and included input from an environmental regulator from West Virginia.

Crude Development Advisory Council Produced Water and Legacy Well Committee Meetings:    DEP Oil and Gas Program staff met with council members and other stakeholders on August 31 to continue committee work to explore issues relating to produced water and legacy well management. Attendees reviewed the current orphan and abandoned well database and its associated scoring system, ongoing research associated with the identification of the total number of legacy wells in Pennsylvania, and potential incentives for operators to plug legacy wells. Also, a discussion took place related to the ongoing TAB Coal-Gas Industry-Agency Committee work and how the guidance being developed would apply to conventional well operators. Next, attendees discussed ongoing research relating to current regulatory provisions pertaining to discharges to waters of the commonwealth, innovative brine treatment strategies, treatment costs, and statewide produced water trends for conventional wells. There was also a presentation regarding new reservoir treatment techniques designed to enhance production using acoustic methods. These methods may reduce the amount of produced water associated with water flood wells that are currently used to mobilize and recover hydrocarbons within conventional oil operations.

Subsurface Mobile Inspection Application Updates:    The DEP Office of Oil and Gas Management partnered with PennDOT and DEP Information Technology staff to develop the inspection Mobile App. The Subsurface Activities Inspection Report component of the project is responsible for the development of five different types of inspection forms (routine, drilling/alteration, stimulation, plugging, and storage wells). As of September 12, several inspection types were in production, while others were undergoing pilot testing to solicit feedback to troubleshoot technical hurdles. To optimize use of the mobile inspection platform, training events were held on September 6 and 7 in Williamsport and Knox, respectively. Another training event was held on September 14 in New Stanton. The training events were useful in reviewing functionality of the subsurface inspection application and educating DEP oil and gas inspectors and their supervisors in a consistent manner on a statewide basis. The training also allowed an opportunity for DEP inspection staff to provide helpful feedback on the inspection forms.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On September 13, the Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. A sub-committee discussed technical issues relating to long-term pillar/mine floor stability and the development of mine monitoring plans. The full committee collectively reviewed a draft version of the technical guidance document that was under development. Future action was to include a 45-day public comment period with an anticipated completion date of the document to be the first quarter of 2018. DEP staff worked with Crude Development Advisory Council members to better define how the guidance will interface with conventional oil and gas operations.

Oil and Gas Safety Standard Operating Procedure Training:    On September 25 - 26, staff from the Bureau of Oil and Gas Planning and Program Management provided training to district oil and gas staff, supervisors and management on a new Safety Standard Operating Procedure titled “Health and Safety Program for the Office of Oil and Gas Management.” The four-hour training included an overview of DEP’s safety policies and program-specific safety policies. Staff learned about the PA Worker and Community Right-to-Know Act. The course also covered the use of personal protective equipment and the standards that must be met. The training was offered in the California, Cambria, Meadville and Williamsport offices to provide ample opportunities for staff to attend.

Underground Injection Control (UIC) Well Industry Stakeholder Teleconference:   On September 20, DEP staff participated in a teleconference regarding the current state of UIC well development in Pennsylvania. Participants discussed DEP’s permitting process and timeframes, seismic monitoring and mitigation, opportunities for regulation and technical guidance development, possible program efficiencies that could be gained through DEP-EPA coordination, public meeting improvements, and education/outreach initiatives.

Pennsylvania Geologic Mapping Advisory Committee:    On September 27, the DEP Office of Oil and Gas Management participated in the Pennsylvania Geologic Mapping Advisory Committee (GMAC) meeting at the Pennsylvania Bureau of Topographic and Geologic Survey office in Middletown, Dauphin County. GMAC membership consists of representatives from academia, federal, state and local government agencies, regional associations and consulting industries. The purpose was to seek the benefits of collaboration and work experience to identify geologic mapping priorities for the state of Pennsylvania and the federal STATEMAP program. The GMAC advisors provided updates on current mapping projects throughout the state. Included in this update was mapping of the Catskill Formation in portions of Susquehanna County that was completed during the summer of 2017. This project will help provide a better understanding of depositional, burial and structural geologic episodes, as well as the hydrogeology of the Catskill Formation. Also discussed were future mapping projects, which include mapping of the Broad Top Area in central Pennsylvania. This project will provide comprehensive geologic analyses of Bituminous Coal Seams and other regional geologic structures.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:    On October 12, the DEP Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. Committee members reviewed the most recent changes to the draft technical guidance document and the process for publishing the document as interim final in early December 2017. The remainder of the meeting was dedicated to developing future topics for discussion: (1) regulatory and technical processes for drilling in active longwall mining districts after panel extraction; (2) regulatory and technical processes for converting historical plugged wells to gob vent boreholes; (3) developing guidance on plugging wells in anticipation of mine-through activities; and (4) improving procedures for archiving information on previously uncharted legacy wells that are inadvertently mined through.

Pennsylvania Independent Oil and Gas Association of Pennsylvania:    On October 24, the DEP Oil and Gas Program staff met with association members to discuss a variety of technical and policy-related matters and review ways to improve communication between operators and DEP staff. The group considered ways to better define the future utility of assets when operators are applying for inactive status. In certain cases, wells on inactive status may eventually become a plugging liability to the commonwealth. Additionally, discussion explored the definition of attainable bottom of abandoned wells and the interpretation of this plugging concept in situations when a well cannot be successfully cleaned out to total depth.

Oil and Gas Technical Advisory Board:   The board met for a regularly scheduled meeting on November 1, in Harrisburg. Discussion covered Class II underground injection control disposal wells and how they are permitted and regulated in Pennsylvania. Also, the DEP Policy Office gave a presentation on the draft guidance on DEP’s regulatory process, technical guidance and advisory committees that are currently open for public comment. Finally, DEP Oil and Gas Program staff explained recent edits to the “Area of Review Technical Guidance Document,” “Guidelines for Chain Pillar Development and Longwall Mining Adjacent to Unconventional Wells” and “Water Supply Replacement Technical Guidance Document.”

Commonwealth Financing Authority, Marcellus Legacy Fund Grants:   On November 14 the Department of Community and Economic Development (DCED) Commonwealth Financing Authority (CFA) announced grant recipients for the 2017 Marcellus Legacy Fund grant program established under the Oil and Gas Act of 2012. One of the grant programs, the Orphan and Abandoned Well Plugging (OAWP) program, targets projects inclusive of well plugging or venting, and the installation of gas migration mitigation systems. Over the past two years, the DEP Office of Oil and Gas Management has taken steps to enhance its grant review process, provide significant outreach relating to the CFA OAWP program, and work directly with DCED and grant applicants to ensure that the application packages submitted are high quality and meet all the criteria demanded by CFA reviewers. A total of $657,503 in grant funding was awarded for three projects in the northwest and southwest regions of the state. Recipients include Venango County Conservation District, Clarion County Conservation District, and Richland Township, Allegheny County. The total grants awarded represent over half of the grant applications submitted in 2017 and eclipse the $495,000 awarded for all prior grant years dating to 2013. The projects are in Oil Creek State Park, the Farmington area of Clarion County, and Richland Township and will address 20 wells characterized by various concerning issues including significant wellbore subsidence, ongoing stray gas migration, leaking wells close to occupied residential structures, and a legacy well occupying the footprint of an ongoing senior citizen community development project. The CFA OAWP program represents a critical source of funding for well plugging projects at a time when DEP well plugging funds are limited. Since 2015, the DEP the Plugging Program has been unable to develop any projects aside from emergency contracts.

Oil and Gas Technical Advisory Board – Coal/Gas Industry-Agency Committee Meeting:   On November 9, the Office of Oil and Gas Management met with the DEP Mining Program, U.S. Mine Safety and Health Administration technical staff, and coal and gas industry representatives to discuss matters relating to coordination between the two industries. The first item of business was to brief the committee on the approval of the Technical Guidance Document (TGD) relating to mining around existing gas well clusters located in longwall chain pillars by TAB. Future plans include publishing the TGD in the Pennsylvania Bulletin as an interim-final document. Participants also discussed the possibility of developing a process for safely drilling unconventional gas wells in a sealed gob area of an active coal mine. Oil and gas industry committee members provided a presentation explaining typical unconventional well drilling, casing and cementing methods used in southwest Pennsylvania.

Crude Development Advisory Council Meeting:   The Office of Oil and Gas Management met with the council on November 16 in Harrisburg to update members on committee work. Presentations were provided by the Legacy Well, Produced Water, and Economic Committees. DEP staff unveiled the results of a new GIS analysis aimed at grouping orphan and abandoned wells into a series of projects that identify costs along with surrounding natural and public resources that can be protected from potential legacy well impacts by initiating plugging projects proactively. The project profiles are important for communicating information with key stakeholders who may be interested in funding well plugging projects for a variety of reasons.

Erosion and Sediment Control General Permit Industry Training:   On December 13, the Bureau of Oil and Gas Planning and Program Management and the Eastern Oil and Gas District Office conducted an industry training session near Pittsburgh. The Office of Oil and Gas Management provided training and updates on the transition from Erosion and Sediment Pollution Control General Permit-2 (ESCGP-2) to ESCGP-3 that will occur in 2018. DEP staff provided suggestions for improving permit submissions by discussing frequent permit application deficiencies as well as the need for applicants to provide more information in permit applications.

In 2017, DEP developed an initiative to encourage private-sector partners to become “Good Samaritans”, by participating in a program that helps to plug dangerous abandoned oil and gas wells statewide. The program protects third-parties from liability for their role in helping to reduce the health, safety, and environmental hazards associated with the plugging of orphan and abandoned wells.

The Environmental Good Samaritan Act of 1999 (Act) protects groups and individuals who volunteer to implement qualifying environmental remediation projects from civil and environmental liability. The Act doesn’t provide immunity for injury or damage that may result from reckless, unlawful, or grossly negligent acts or omissions.

While the Act has been used in the past to encourage mine reclamation projects, DEP applied the provisions of the Act to two oil and gas well plugging projects for the first time in 2017. A conventional well operator volunteered to plug a well in Warren County that was discharging crude oil to the ground and nearby streams.
An industrial chemical supplier and service company volunteered to plug a leaking natural gas well in Elk County. These projects are estimated to have saved DEP $60,000 to $85,000, in addition to administrative cost savings related to contract development and management.

Additional project proposals are currently under review and DEP welcomes other third parties to step forward to take advantage of the benefits of participating in the Good Samaritan Legacy Well Cleanup initiative. Volunteers enjoy reduced liability, and can often develop the land at or near the well site much more quickly than waiting for state funding to become available to complete the project.

The agency has developed online training training to educate volunteers about the process of submitting a project proposal and applying for the liability protection under the Good Samaritan Legacy Well Cleanup initiative. For more information about this initiative and to obtain a “Project Proposal Application”, click here:

Questions about well plugging through the Environmental Good Samaritan Act can be addressed by contacting DEP’s Bureau of Oil and Gas Planning and Program Management or the district office where the project is located.

Cameron Energy Company partnered with DEP and the U.S. Forest Service (Allegheny National Forest) to use its equipment and resources to address ongoing environmental impacts. Access to the densely forested, remote site was limited, and the location of the leaking well on a small island at the confluence of two exceptional-value streams further complicated the response action. Although the company did not own the well, it took steps to proactively assist with the remediation of this well site.

Chemtrade Logistics, a global chemical company with a plant in Johnsonburg, planned to implement facility renovations and submitted an application to plug an abandoned well that was leaking natural gas adjacent to an above ground storage tank containing sulfuric acid. Evidence of failed well integrity raised concerns about the potential that natural gas could migrate from the well into enclosed spaces or other occupied structures. Company officials secured the services of a qualified contractor to complete this well plugging operation.

Using the new departmentwide electronic permitting system, DEP began developing two new e-permits for oil and gas operations in 2017. One will replace the existing “eWell” online well permit application, and the other will replace the Erosion and Sediment Control General Permit paper form and instructions used for non-transmission projects which are reviewed by the Bureau of District Oil and Gas Operations.

The new e-permits will bring an end to the need for operators to duplicate data entry and provide prompt feedback on permit completion, enabling faster application review and response.

The new e-permits are expected to launch in fall 2018, with outreach to operators by the Office of Oil and Gas Management.

DEP launched a mobile app to enable inspectors to conduct electronic inspections at oil and gas sites using tablet computers, replacing a paper-based process.

Customizing PennDOT technology, DEP developed the app for inspections of all surface and subsurface activities, including erosion and sedimentation control, waterways encroachment, waste management, well construction, operation, plugging and spill cleanup activities.

With increased efficiency resulting from elimination of duplicate data entry, the number of oil and gas inspections is expected to increase. Because the app improves data quality and enables photographic documentation, accuracy increased also.

The public has access to inspection results sooner, since results are automatically saved to DEP’s permitting and compliance database (eFACTS) and are posted on the Oil and Gas mapping website within days, rather than weeks.

The e-inspection mobile app supports the Governor’s Office of Transformation, Innovation, Management and Efficiency (GO-TIME) initiative, which works with state agencies to modernize government operations to reduce costs and improve services. The app earned a GO-TIME award and recognition from the National Association of State Chief Information Officers.

DEP streamlined the approval process for the use of modular aboveground storage structures when the Environmental Quality Board promulgated 25 Pa. Code Chapter 78a56 as part of the Final “Environmental Performance Standards at Oil and Gas Well Sites” published in the Pennsylvania Bulletin on October 8, 2016. This regulation allows the use of modular aboveground storage structures at unconventional well sites to temporarily contain regulated substances upon prior DEP approval and notice before installation. DEP will maintain a list of approved modular structures on its well site. These modular aboveground storage structures are often preferred by operators since they reduce the footprint of a well pad and allow for storage that can be assembled and disassembled quickly as needed.

Operators may submit a “Request for Approval of Previously Approved Alternative Waste Management Practices” form (OG-71B) to use a pre-approved modular aboveground storage structure that appears on the list.

DEP partnered with the Pennsylvania Emergency Management Agency (PEMA) to develop, “Guidelines for the Development and Implementation of Oil and Gas Well Site Integrated Contingency Plans for Unconventional Well Sites.” This guide instructs unconventional oil and gas operators how to consolidate multiple emergency/contingency planning requirements into a single document. Prior to this, operators routinely submitted multiple emergency and contingency plans to both agencies to meet various regulatory and statutory obligations.

This guide covers multiple factors related to regulated substances, accident prevention, mitigation, and response at well sites. It contains critical information for first responders, a site-specific plan, and a core emergency response plan as well as regulatory references and forms for emergency response field use. This single-plan approach is intended to minimize duplication of effort and standardize the format of emergency response information and preparedness, prevention and contingency plans.

An Integrated Contingency Plan prepared in accordance with this document will satisfy requirements of multiple DEP regulations and guidance documents and is the preferred method of such planning for unconventional oil and gas well sites. The draft proposed version of this policy was presented to the Oil and Gas Technical Advisory Board on April 13, 2017.

In response to public comment, DEP implemented several changes to the “Guidelines for Implementing Area of Review (AOR) Regulatory Requirement for Unconventional Wells” technical guidance document (TGD) that was published in the Pennsylvania Bulletin as interim final on October 8, 2016, with a 60-day public comment period concluding on December 7. The TGD can be viewed here.

The document was developed through a multi-stakeholder technical workgroup effort, and DEP received and evaluated 11 comments. DEP is currently drafting a Comment and Response document.

The Oil and Gas Technical Advisory Board (TAB) voted unanimously at its November 1, 2017 meeting in support of publication of the interim final TGD. DEP intends to publish the guidelines as final in the Pennsylvania Bulletin in 2018.

The purpose is to inform those engaged in hydraulic fracturing activities on complying with the requirements of the Clean Streams Law, the 2012 Oil and Gas Act, 25 Pa. Code Chapter 78a, and other applicable laws. This policy is developed to facilitate appropriate risk mitigation for unconventional well operators and includes a risk-based classification system for offset well locations and commensurate levels of monitoring; sections addressing communication incident management, reporting, and resolution; and operational alternatives and technical considerations for different anticipated scenarios. This policy also provides an outline of DEP’s well adoption permitting process.

This guidance has been developed to facilitate appropriate unconventional well inactivation and re-entry procedures in advance of, and subsequent to, longwall coal panel removal. This will allow for continuous isolation of gas from workable coal seams, protection of mining personnel, and prevention of pollution of the waters of the commonwealth, consistent with applicable law.

The “Guidelines for Chain Pillar Development and Longwall Mining Adjacent to Unconventional Wells” TGD was published in the Pennsylvania Bulletin as interim final on December 16, 2017, with a 45-day public comment period concluding on January 30, 2018. Click here to view the interim final TGD. The guidelines are primarily aimed at ensuring safe operations when longwall mining is taking place adjacent to completed unconventional wells, and could serve as an international model.

Two individuals submitted comments, which DEP is currently evaluating. DEP and the TAB Coal-Gas Coordination Subcommittee have been developing the interim final TGD since March 2016. Successful development of the TGD involved a significant effort with multiple stakeholders, including the DEP Bureaus of Oil and Gas Planning and Program Management, District Oil and Gas Operations, and Mine Safety; the U.S. Mine Safety and Health Administration and the National Institute for Occupational Safety and Health; as well as representatives from the oil and gas and mining industries. TAB voted unanimously at its November 1, 2017, meeting in support of publication of the final TGD.

DEP has been in communication with other Appalachian basin partners, including Virginia, West Virginia, Tennessee, Maryland, Ohio, and Kentucky, and intends to publish the guidelines as final in 2018.

DEP published a report on February 17, 2017, that found that seismic events that occurred in western Lawrence County in April, 2016, were likely correlated to natural gas hydraulic fracturing.

On April 25, 2016, a series of low-magnitude earthquakes occurred in North Beaver, Union, and Mahoning Townships that showed a marked temporal/spatial relationship to hydraulic fracturing activities at a nearby unconventional natural gas development well pad that had begun hydraulic fracturing and stimulation activities.

The Pennsylvania Seismic Network registered four earthquakes. The final magnitude of the earthquakes ranged from 1.8 to 2.3 on the Richter Scale, putting them in the category of microseismic events, which are likely to go unnoticed by humans and only recorded by sensitive seismic monitors.

The operator of the nearby unconventional natural gas well pad used a technique known as “zipper fracturing,” or hydraulic fracturing operations that are carried out concurrently at two parallel and adjacent horizontal well bores. The four wells on this well pad target the Utica formation and have an average true vertical depth of 7,900 feet. When DEP contacted the operator, they immediately volunteered to stop activities and later reported they would discontinue hydraulic fracturing and stimulation operations at the well pad.

The report outlined a DEP-approved plan for the operator to monitor and respond to seismic activity associated with the Utica Shale formation gas wells in North Beaver, Mahoning and Union Townships. DEP recommends that other operators in this area discontinue the practice of zipper fracturing during any future completions when the distance between lateral portions of adjacent wellbores is less than a quarter mile. DEP also recommends other operators in this area adopt a seismic event reporting schedule and response plan.

Click here to view a webinar discussion about these seismic events.

The Pennsylvania Grade Crude Development Advisory Council (CDAC) was established when Governor Wolf signed Act 52 into law on June 23, 2016. The first meeting of CDAC occurred on February 21, 2017 and the council met two additional times during the year.

Although DEP is a voting member of CDAC, the law did not assign this council to function under DEP. The Department of Community and Economic Development (DCED) provides administrative support and technical assistance to the council to carry out its duties.

The council is authorized to “examine and make recommendations regarding existing technical regulations promulgated under 58 Pa. C.S. (relating to oil and gas), and policies implemented by DEP that impact the conventional oil and gas industry of the Commonwealth of Pennsylvania.” CDAC is also responsible for other duties and serves to promote the long-term viability of the conventional oil and gas industry.

DEP consults with CDAC on all policies and technical regulations promulgated under 58 Pa. C.S.; relating to oil and gas.

The council consists of 17 members, including:

• the Environmental Protection secretary
• the Community and Economic Development secretary
• two state senators
• two state representatives
• eleven members appointed by the Governor including:
• two members of PA Independent Petroleum Producers (PIPP)
• two members of PA Independent Oil and Gas Association (PIOGA)
• two members of PA Grade Crude Oil Coalition (PGCC)
• two representatives of refineries of PA grade crude oil
• one member of academia who is a geologist with expertise in petroleum geology
• one member of academia who is a hydrologist
• one member of nonprofit corporation that promotes history and economic benefits of the conventional oil and gas industry