We previously wrote about historical vs recent spills in the last 12 months; here is a visualization of the same statistic over the last 10 years. Some observations:
- The number of reported spills has tripled over the last 10 years.
- The 2025 data is incomplete; we only have spill data through the end of October.
- There are a number of compounding causes for this increase; reporting thresholds have decreased, reporting criteria have expanded (see below), and the number of wells plugged and abandoned has increased.
- None of these factors fully explain the dramatic increase in reported historical releases in 2024 and 2025.
- The number of recent spills has remained relatively constant over the last 10 years, with a median of 403.5 and an interquartile range of 63.3.
ECMC Rule 912 Reporting Criteria (2021 Changes)
In 2021, the criteria for reporting a spill changed dramatically, which correlates to the large increase in reported spills since 2021.
Below are the current reporting criteria according to the ECMC Rule 900 Series. Before 2021, only criteria A through D were applicable:
- A Spill or Release of any size that impacts or threatens to impact any Waters of the State, Public Water System, residence or occupied structure, livestock, wildlife, or publicly-maintained road;
- A Spill or Release in which 1 Barrel or more of E&P Waste or produced Fluids is spilled or released outside of berms or other secondary containment;
- A Spill or Release of 5 Barrels or more of E&P Waste or produced Fluids regardless of whether the Spill or Release is completely contained within berms or other secondary containment.
- Within 6 hours of discovery, a Grade 1 Gas Leak. For a Grade 1 Gas Leak from a Flowline, the Operator also must submit the Form 19 – Initial, document number on a Form 44, Flowline Report, for the Grade 1 Gas Leak.
- The discovery of 10 cubic yards or more of impacted material resulting from a current or historic Spill or Release. Discovery and reporting will not be contingent upon confirmation samples demonstrating exceedance of Table 915-1 standards.
- The discovery of impacted Waters of the State, including Groundwater. Discovery and reporting will not be contingent upon confirmation samples demonstrating exceedance of Table 915-1 standards. The presence of free product or hydrocarbon sheen on Groundwater or surface water is reportable. The presence of contaminated soil in contact with Groundwater or surface water is reportable.
- A suspected or actual Spill or Release of any volume where the volume cannot be immediately determined, including a Spill or Release of any volume that daylights from the subsurface.
- A Spill or Release resulting in vaporized hydrocarbon mists that leave the Oil and Gas Location or Off-Location Flowline right of way from an Oil and Gas Location and impacts or threatens to impact off-location property.
- A Release of natural gas that results in an accumulation of soil gas or gas seeps.
- A Release that results in natural gas in Groundwater.