But online, this incident has only one violation — for the failures with the erosion and sedimentation controls — and there is no explanation why the other violations were dropped.
Another regional difference was brought to light two years ago when drillers complained about disparities in how inspectors in the two busiest drilling areas — the Southwest region and the Northcentral and Northeast regions — handled erosion and sediment violations on well pads. A driller in the Northcentral region might receive the same violation in connection with every well that had been drilled on the pad, while a driller in the Southwest region would receive only one violation no matter how many wells had been drilled.
The state has tried to stop that disparity by issuing just one violation, no matter how many wells were drilled, Mr. Ryder said.
“We absolutely knew that how people entered their information into eFACTS” differed by region, Mr. Perry said. He said the DEP is considering completely changing the way violations are issued.
“What we need to do is have that one violation and have everyone understand [for example] that when they overtop a pit, this is the code that you’re going to use. And in the comments section you can list out all of the other violations,” he said.
The state likes inspectors to cite multiple violations for the same offense from different sections of the state code — from the Clean Streams Law and the Oil & Gas Act, for example — because if the case becomes difficult and deserves a bigger fine, the state can combine potential penalties.
Such a change would mean there would be no way to compare the enforcement of the early years of the Marcellus era to future years. But Mr. Perry said the existing system is so flawed, he doesn’t think it’s possible to go back and correct the past inconsistencies and problems.
He wants to end the practice whereby the only way to fully understand what is happening at a well site is to read the paper permit file at one of DEP’s six regional offices.
The state began scanning well records and eventually will require electronic filing of well records to a searchable database. That system went live in December and for now features a searchable mapping system for wells that will pull up a copy of the well permit if it has been uploaded to the system.
Mr. Perry said the goal is to make the information completely searchable: “You want to know how many Chesapeake wells are 6,000 feet deep? Well, you can run a query and get that. But we’re not there yet.”
“These are public records. Let’s get them out there for the public.”
But how long will it be before trips to the various DEP regional offices will be replaced by a few keystrokes on a computer to see complete records?
“All in all, it’s going to take years,” he said. “But that is the direction we’re headed in.”
Check out PG’s interactive map of Marcellus Shales wells around Pennsylvania