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.
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.
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.
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.