Chesapeake gets DEP notice of violation
BY ERIC HRIN
The state Department of Environmental Protection (DEP) wants answers from Chesapeake Energy Corporation about the blowback incident at the company's natural gas well site this week in LeRoy Township.
The state agency sent a notice of violation via certified mail, dated April 22, to Chesapeake Energy and is requesting further information, including a complete list of materials in the fracking fluids used at the site.
One of the instructions in the notice informs Chesapeake to "include an explanation of why it took Chesapeake nearly 12 hours to address the uncontrolled release of fluids off the well pad."
Another calls for "a description of immediate actions taken by Chesapeake to regain control of the well and secure the wellhead, as well as any measures taken to ensure public safety."
"This should include an explanation of why Chesapeake took 12 hours to have a well control service company at the site when there are other well control service companies located closer" to the well. The letter was addressed to Chesapeake Regulatory Manager Tal Oden in Oklamhoma City, Okla. from Jennifer W. Means, Environmental Program Manager, Oil and Gas Management, with the DEP.
Late Tuesday night, the incident began with an equipment failure at the drill site, causing hydraulic fracturing fluid to be released into the environment, including into Towanda Creek and an adjacent tributary. Seven families were relocated from their homes as a precautionary measure on Wednesday. As a result of the accident, Chesapeake Energy has suspended its well completion operations in its Eastern Division until further notice. The cause of the equipment failure is undetermined at this time, according to Chesapeake.
Daniel Spadoni, community relations coordinator with the DEP, said on Friday afternoon that a well control company, Boots and Coots, was bleeding off pressure from the well, which he said is a standard procedure. He said they expected this process to continue into today, and didn't plan any significant activities for Friday night. He said the well would be plugged some time today.
Shortly before 4:30 p.m. Friday, he issued another update, noting that Boots and Coots was suspending bleed-off for the night, and said the well was stable and not leaking.
"There is 0 percent methane at the well head," he added.
He said the DEP does not have an estimate of the amount of fluid that was discharged.
According to Chesapeake's official summary of the incident, late in the evening of Tuesday, April 19, Chesapeake Energy "experienced an equipment failure while conducting completion operations on a Marcellus natural gas well operation in LeRoy Township." In the violation notice, the DEP described the equipment failure, stating that according to Chesapeake, a flange, below the frac stack, failed, resulting in loss of well control.
Also, the DEP stated that its investigation has, to date, revealed violations of the Clean Streams Law, the Solid Waste Management Act, the Oil and Gas Act, "and the rules and regulations promulgated under these statutes."
The DEP said its investigation found that "pollutional substances generated from activities associated with hydraulic fracturing were not contained. Specifically, an unknown quantity of frack fluid was released from a gas well on site," which was a violation of the department's regulations.
Also, the DEP said the investigation found "a pollution to waters of the commonwealth near the well site. Specifically, an unknown quantity of frack fluid was released from a gas well, that entered an unnamed tributary to Towanda Creek, a water of the commonwealth," which is a violation of the Clean Streams Law.
It continued: "The Department's investigation revealed an unpermitted discharge of residual waste onto the ground at the site. Specifically, frack fluid was released onto the ground." It said this was a violation of the Solid Waste Management Act.
The DEP asked Chesapeake to submit a written response to the Notice of Violation within five business days, and that its response should include the following:
- A complete list of materials used in the fracking fluids utilized at the site
- An evaluation of the materials released to the environment as part of the fracking operations
- A full description of actions taken by Chesapeake to prevent this discharge from reaching waters of the commonwealth. Include an explanation of why it took Chesapeake nearly 12 hours to address the uncontrolled release of fluids off the well pad.
- A description of immediate actions taken by Chesapeake to regain control of the well and secure the wellhead, as well as any measures taken to ensure public safety. The DEP noted that this should include an explanation of why Chesapeake took 12 hours to have a well control service company at the site when there are other well control service companies located closer to the Atgas 2H Well.
- A sampling plan that details future sampling locations and frequencies
- A detailed analysis/explanation of the root cause or causes of the failure at the wellhead that resulted in loss of control of the well
- An analysis of Chesapeake's completion activity and well control procedures existing on April 20, 2011
- Corrective actions that Chesapeake proposes to implement at all Marcellus Shale gas wells to prevent similar failures in the future, and a proposed implementation schedule
- Changes to Chesapeake's completion and well control procedures that Chesapeake proposes to implement at all Marcellus Shale gas wells, and a proposed implementation schedule
The DEP noted, "This notice of violation is neither an order nor any other final action of the Department of Environmental Protection. It neither imposes nor waives any enforcement action available to the Department under any of its statutes. If the Department determines that an enforcement action is appropriate, you will be notified of the action."
Late Friday night around 9:30 p.m., Chesapeake issued this update attributed to Brian Grove, Senior Director - Corporate Development:
"Chesapeake personnel conducted evaluations of the Atgas 2H through the course of Friday and formulated a plan with well-control specialist Boots & Coots to achieve full wellhead integrity. Personnel will continue to monitor the Atgas 2H through Friday evening while additional equipment and resources are gathered. The well has remained in a stable condition for more than 24 hours and is expected to continue in this state through final preparations," it read.
"Chesapeake's drilling operations continue throughout the Marcellus Shale while completion operations remain voluntarily suspended. In response to the wellhead failure experienced on the Atgas 2H, Chesapeake has suspended all completion operations in the Marcellus Shale in order to conduct thorough inspections of wellheads currently in use in those operations."
"Chesapeake crews and consultants, along with the Pennsylvania DEP, are on site to sample soil and water for any impacts of the discharged fluid. Thus far, testing results show minimal localized environmental impact. Further assessments are ongoing. Chesapeake remains committed to protecting our environment and mitigating any unfortunate impacts that may have occurred from this incident," the update noted.
"As a result of this equipment failure, brine water was released to the surface. While the majority of the brine water was controlled within containment structures on the site, portions of earthen berms surrounding the location were weakened by recent precipitation events and allowed some of the fluid to escape off of the location," it continued. "By midday on Wednesday, April 20, full containment was reestablished, and all water flowing from the well was completely confined to the well location. Emergency-response procedures and many of Chesapeake's best management practices in location design and construction significantly minimized the impact. Tests by both Chesapeake and the Pennsylvania DEP indicate little, if any, impact upon local waterways and aquatic wildlife. Additional testing will be done in conjunction with DEP to fully assess and remediate any environmental impacts."
"On Wednesday, efforts made by Chesapeake personnel and a well-control specialist team made some progress, regaining partial control of the well and continuing successful containment of any produced water. Early Thursday, the well began to produce some natural gas as well-control specialists began operations to completely seal the well," according to the update.
The update noted that, late Thursday afternoon, efforts to seal the leak and regain control of well pressure were successful. Chesapeake personnel monitored the well throughout the overnight hours between Thursday and Friday. The well remained in a stable condition, and there continued to be no emissions coming from the well.
"The cause of the equipment failure is undetermined at this time, and as a precaution, Chesapeake has voluntarily shut down all completion activity in its Eastern Division. A full investigation will be conducted to determine the root cause of the failure, evaluate best management practices and make any and all necessary corrections before returning to normal operations," according to the update.
"We regret the incident and the inconvenience that it has caused neighboring families and the community. Even though the environmental impact appears to be minimal and temporary, we have zero tolerance for any accident, and we will make additional improvements to our operations if any opportunities for development are identified during the investigation. We greatly appreciate the professional and responsive assistance of federal, state and local agencies that participated in these efforts," the update noted.
Eric Hrin can be reached at (570) 297-5251; e-mail: firstname.lastname@example.org.