EARTHWORKS

Colorado Oil & Gas Enforcement - Inspections

As shown in the table below, at the end of 2010 Colorado hosted more than 43,000 active wells. That year the COGCC employed 15 inspectors who performed a total of 16,228 inspections.

Assuming that each inspection was conducted at a different well site, approximately 27,000 wells or 63% of Colorado’s active oil and gas wells were not inspected in 2010.

Even fewer inspections were conducted in 2011 (12,239), while the number of active wells increased to 46,835, leaving approximately 34,500 (74%) of active wells with little or no oversight.

Colorado Inspection Data

Click chart for larger, footnoted version

Colorado’s inspection capacity lags behind other states

Pennsylvania has greatly increased its inspection and enforcement staff in response to its (Marcellus) shale gas boom. Between 2000 and 2010 the number of active wells in Pennsylvania almost doubled from 36,000 to 71,000. In response to the drilling of thousands of shale gas wells, Pennsylvania Department of Environmental Protection recently quadrupled the size of its enforcement staff to 130 employees, 65 of which are inspectors.

• In 2010, each Pennsylvania oil and gas inspector was responsible for, on average, 1,092 active wells.
• In Colorado, with 43,000 active wells just 15 inspec­tors in 2010, each COGCC inspector was responsible for an average of 2,890 active wells – more than twice the number of their Pennsylvania counterparts.

It is nearly impossible for one inspector to visit, let alone carefully inspect 2,890 well sites a year.

In 2010, each of COGCC’s 15 inspectors performed, on average, 1,082 inspections. That number is high compared to oil and gas inspectors in Pennsylvania, Ohio and New York state, each of whom conducted 253, 499 and 154 inspections in 2010, respectively, and implies that COGCC inspectors are not able to spend as much time on each inspection as their counterparts in some other states.

States, such as Pennsylvania, North Dakota and New York recommend that each producing well be inspected at least once per year, and new wells, especially horizontal wells, be inspected multiple times during the drilling and completion process.

Colorado must hire more inspectors

To do an adequate job of inspecting new and active wells, all new wells should be inspected at least three times (e.g., twice during the drilling/completion process, and once after drilling is completed), and each active well in Colorado should be inspected at least once a year. This means that COGCC should perform at least 55,000 inspections in 2012. In 2011, COGCC conducted 12,239 inspections.

Clearly, the COGCC needs to hire more inspectors to keep up with the growing number of new and active wells in Colorado.

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For more information:

• Earthworks: Enforcement Report - COGCC: Inadequate enforcement means current Colorado oil and gas development is irresponsible. Report
• Earthworks: Colorado Oil & Gas Enforcement. Web page
• Earthworks: Colorado Oil & Gas Enforcement - Inspections. Web page
• Earthworks: Colorado Oil & Gas Enforcement - Enforcement Actions. Web page
• Earthworks: Colorado Oil & Gas Enforcement - Violations. Web page

Endnotes

1 Pennsylvania: 65 inspectors conducted 16,199 inspections, or 249 per inspector. Ohio: 21 inspectors conducted 10,472 inspections, or 499 per inspector.  New York: 16 inspectors conducted 2,460 inspections, or 154 per inspector.  (Note: Ohio inspection data from Beth Wilson, Public Information officer with Ohio Division of Minerals Resources Management (Email request for data made Sept. 16, 2011. Data received Oct. 4, 2011).

2 At minimum, in 2012 Colorado should be able to perform:  [3 inspections x 2,700 new wells in 2012 (assumed to be similar to wells spud in 2011 and 2010)] + 46,800 inspections of active wells (the number of active wells at beginning of 2012) = 8,100 + 46,800 = 54,900 inspections.

3 If COGCC inspectors continue to perform approximately 1,000 inspections per year (as they did in 2005, 2006, 2007, 2008, 2010), then COGCC would need 55 inspectors to keep to this schedule. There are currently 15 inspectors. If each COGCC inspector conducted fewer inspections per year (i.e., spent more time on inspections like their counterparts in PA, NY and OH), e.g., 500 inspections per year, then approximately 110 inspectors would be needed to do the work. That is more than seven times the current inspection staff.

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