Radical Transparency – Compliance Process and Violations
Pennsylvania has one of the most comprehensive and stringent regulatory environments for oil and gas operations in the country. CNX takes our duty as a responsible operator very seriously and we have implemented an Environmental Management System that is overseen by skilled environmental compliance experts in our Operational Excellence and our Environmental Strategy teams. These teams are dedicated to our environmental stewardship efforts and ensure compliance with environmental laws, regulations, and proactive improvement efforts.
The Department of Environmental Protection (DEP) and other regulatory agencies perform regular inspections of our sites. For example, there were 969 inspections performed on CNX sites by the PA DEP Office of Oil and Gas Management and recorded in the system over 2022–2023. That’s almost 1.5 per day on average, seven days a week, 365 days a year. During that time period, 943 of these inspections had no findings, 24 inspections were triggered because CNX had self-reported events, and two events were discovered by inspectors. To learn more about the number of violations the public sees and the correlation to the number of events that actually occurred, as well as the process CNX and the DEP follow, read this article “Challenging Environmental NGO/Media Optics with Facts and Data”.
The important thing to note is that if an event occurs, CNX self-reports to the DEP and quickly acts to remediate. CNX has been around this region for over 160 years – our team members were born here, live here, and desire to stay here. Our kids and parents breathe the same air and drink the same water as everyone else. It’s why we jumped at the chance to embrace Radical Transparency. It’s also the foundational reason why CNX works diligently with the regulatory community to self-report any incident, to efficiently abate any violation, and to always work with the agency to correct or improve the system.
We have a duty to respond in writing to NOVs we receive from the DEP and while we may disagree with the number of citations cited/interpretation of the law, CNX rarely takes the step to appeal the violations we receive, preferring to work instead with our regulators to resolve outstanding issues quickly and efficiently. Because when issues can be resolved without applying undue strain on DEP resources and taxpayer dollars that a costly appeal process entails, the outcome is better for all Pennsylvanians.
CNX is further committing to our Radical Transparency program by disclosing every Notice of Violation that we receive (listed below) and will continue to disclose the data for NOVs across federal, state, and local regulatory agencies on our ESG Performance Scorecard, along with the penalties we have paid, for our entire operating footprint.
CNX self-reported a failure to conduct a performance test within 180 days of permit reauthorization
The performance test was conducted
Failure to submit monthly production and status report.
The report was filed on 9/17/26.
Failure to achieve vegetative cover
Continuing to monitor vegetation growth.
NOV response submitted on 9/24/2026.
Failure to provide notification prior to starting construction.
The commencement notification was submitted.
Department inspection on 8/28/2026 – NOV is CLOSED.
Failure to have an updated ERP on site.
Updated ERP was delivered to the site.
NOV response submitted on 8/26/2026.
Failure to install the permit number on a completed well.
The well tag was re-attached to the well.
NOV response submitted on 8/26/2026.
CNX self-reported a slope failure to the DEP.
The area has been temporarily stabilized, and E&S controls have been installed.
NOV response submitted 8/14/2026.
Failure to submit Annual Production Report and Mechanical Integrity Assessment
CNX is not the owner/operator of this well. This well was transferred to Leatherwood Inc. in 2017.
NOV response submitted on 6/8/2026 with a request that this NOV be rescinded.
DEP performed a follow-up inspection on 6/15/2026 – ICS.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
Water Supply Restoration
Currently being investigated.
NOV response submitted on 5/14/2026.
CNX self-reported a release of 20 gallons of produced fluid to the ground.
Remediation efforts are complete. Impacted soils have been excavated and properly disposed of.
DEP Compliance Evaluation on 5/11/2026 – NOV is CLOSED.
The enclosed flares/bypass valve vents in the dehydration units were not operating
correctly. The flares were operating below the minimum operating temperature of 1400°.
CNX increased the set point for the flares to 1500°. CNX is working on a Stack Test Protocol.
The DEP was provided with the NOV response on 4/10/2026.
Failure to install the permit number on a completed well.
The well tag had blown off in a wind storm the previous day. It was found several feet from the well and was immediately re-
attached to well head.
The DEP was provided with the NOV response on 4/8/2026.
DEP Compliance Evaluation on 4/13/2026 – NOV is CLOSED.
Failure to restore site within 9 months of completion of drilling all permitted wells on the well site
Wellsite restoration extension was filed prior to issuance of this NOV. The DEP has provided a new restoration completion date of 11/19/2027.
This NOV was issued as VIOIC and was immediately closed.
CNX self-reported a release of 20 gallons of production fluid to the ground.
Remediation efforts are complete. Impacted soils have been excavated and properly disposed of.
DEP is reviewing the NOV response and waste manifests that were submitted on 3/10/2026 – ICS.
Compliance Evaluation on 4/13/2026 – NOV is CLOSED.
Failure to provide initial report within 15 days
Act 2 report submitted to the DEP on 5/20/2026.
DEP Compliance Evaluation on 5/27/26 – NOV is CLOSED.
CNX self-reported a release of 20 gallons of diesel fuel to the ground.
Remediation efforts are complete.
NOV response and waste manifests were submitted on 2/17/2026.
DEP Compliance Evaluation on 3/12/2026. NOV is CLOSED.
Failure to provide DEP notification
Failure to notify the Department within 24 hours of having received a complaint.
NOV response was submitted on 2/13/2026.
CNX self-reported a release of 5 bbls of produced fluid to the ground.
Act 2 report submitted to the DEP on 5/20/2026.
DEP compliance evaluation inspection on 5/27/2026. NOV is CLOSED.
Failure to provide DEP notification within two hours of discovery of an incident
CNX self-disclosed the incident to the Department.
NOV response was submitted on 12/18/2025.
Closure of the NOV is pending final approval from the DEP.
CNX self-reported a release of 10 gallons of produced fluid to the ground.
Remediation efforts are complete.
DEP Compliance Evaluation inspection on 1/8/2026. NOV is CLOSED.
Inadvertent release of 5 gallons of produced fluid outside of containment.
Corrective actions and remediation efforts are complete.
NOV response has been submitted.
Closure of the NOV is pending final approval after the Department has completed a follow-up inspection.
Failure to restore site within 9 months of completion of drilling.
The site is stabilized. Erosion control blankets and compost filter socks are already in place.
DEP follow-up inspection on 4/17/2026 determined that CNX restoration efforts are ICS.
DEP compliance evaluation inspection on 5/26/2026. NOV is CLOSED.
CNX self-reported a release of 10 gallons of produced fluid to the ground.
Remediation efforts are complete.
NOV response was submitted to the DEP on 10/30/2025.
DEP compliance evaluation on 12/15/2025. NOV is CLOSED.
The annual permit compliance certification report was submitted after the due date.
The annual report was submitted prior to the issuance of the violation.
No outstanding corrective actions are required.
Failure to plug a non-producing well
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards
CNX will be plugging the well. The well was added to the plugging schedule to be plugged by 6/30/2026, but was delayed due to 3rd party utility relocations.
Failure to identify 2 requirements when filing well site restoration reports.
Correction in progress.
CNX self-reported a release of 84 gallons of produced fluid to the ground.
Act 2 clean-up is complete and the final report was submitted to the DEP on 9/11/2025.
Act 2 Report approved by the DEP on 10/20/2025.
DEP compliance evaluation on 10/22/2025. NOV is CLOSED.
CNX self-reported a release of 4 gallons of produced fluid to the ground.
Remediation efforts are complete.
Department inspection on 10/7/2025. NOV is CLOSED.
Failure to provide PUC notification within one hour after the discovery of a release.
CNX did provide notification, but it was outside of the one-hour window.
CNX updated emergency response procedures and training was provided to relevant personnel on 6/10/2025.
Copies of the updated procedures and the training rosters were submitted to the PUC on 6/11/2025.
Closure of the NOV is pending final approval from the PUC.
CNX self-reported that a CBM pit liner was accidentally punctured, which compromised the integrity of the liner and resulted in a produced water spill (NOV received 4/23/2025).
Remediation efforts are complete.
Department inspection on 5/16/2025. NOV is CLOSED.
Failure to post complete contact information. (NOV received 5/1/2025)
CNX updated the contact information on 5/14/2025.
CNX self-reported a slope failure to the DEP. Accelerated erosion and sedimentation was noted near a stream crossing for a tributary of Templeton Fork stream. (NOV received 4/9/2025).
Permanent stabilization of the upper slope and lower slope has been completed. Vegetation has been established, and the site is stable.
DEP Compliance Evaluation inspection on 7/23/2025. NOV is CLOSED.
See further discussion on these type of events at Enabling Environmental Stewardship
Failure to submit the NOT prior to expiration of ESCGP (NOV received as VIOIC on 4/22/2025).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
NOV issued and immediately CLOSED on 4/22/2025.
Agency inspection, directly after a rain event, discovered erosion and sedimentation below the soil stockpile and on the Northeast corner of the well pad.
The erosion downslope of the soil stockpile and on the Northeast corner of the well pad has been stabilized. E&S controls are in place.
DEP compliance evaluation inspection on 4/10/2025. NOV is CLOSED.
See further discussion on these type of events at Enabling Environmental Stewardship
Failure to prevent erosion and sedimentation along the pipeline right-of-way, specifically noting erosion along the access road.
The erosion issues originated at a third party well site and were outside of the CNX LOD. CNX worked with the third party to re-grade and stabilize the area. E&S controls were installed.
DEP compliance evaluation inspection on 3/14/2025. NOV is CLOSED.
See further discussion on these type of events at Enabling Environmental Stewardship
Unreported release by Apex prior to the acquisition by CNX. Discovered and reported by CNX on 2/14/2025 (NOV issued 2/18/2025)
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
Completed Act 2 remediation. DEP approved the Act 2 report on 9/9/2025. DEP compliance evaluation inspection on 10/6/2025. NOV is CLOSED.
Failure to plug a non-producing well (NOV received 3/14/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
CNX will be plugging the well. The well has been added to the 2026 plugging schedule.
Failure to plug non-producing well (NOV received 3/14/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
On 4/1/2025, CNX submitted to the DEP a plan to return the well to Active Status.
Unreported release by Apex prior to the acquisition by CNX. Discovered and reported by CNX on 1/31/25.
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
Completed Act 2 remediation. DEP approved the Act 2 report on 6/24/2025. NOV is CLOSED.
CNX self-reported a release of 30 gallons of produced fluid to the ground. (NOV received 1/29/2025).
Remediation efforts are complete.
DEP compliance evaluation inspection on 2/21/2025. NOV is CLOSED.
CNX self-reported a release of 40 gallons of brine fluid to the ground. (NOV received on 1/27/2025).
Remediation efforts are complete.
DEP compliance evaluation inspection on 4/1/2025. NOV is CLOSED.
Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
DEP restoration inspection on 5/22/2025. NOT shall be approved and NOV is CLOSED.
Failure to submit the NOT prior to expiration of ESCGP (NOV received 2/3/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
DEP follow-up inspection on 4/22/2025. NOV is CLOSED.
Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
DEP follow-up inspection on 4/22/2025. NOV is CLOSED
Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards,
DEP follow-up inspection on 4/22/2025. NOV is CLOSED.
Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
DEP follow-up inspection on 4/22/2025. NOV is CLOSED.
Agency inspection finding related to performance tests (NOV issued 1/28/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
NOV is CLOSED.
Agency inspection finding related to performance tests (NOV issued 2/3/25).
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards.
NOV is CLOSED.
CBM (Coal Bed Methane) – a type of gas well.
ERP – Emergency Response Plan
E&S (Erosion & Sedimentation) Controls – Controls installed to prevent earth movement caused by rain events / sheet flow.
ESCGP (Erosion & Sediment Control General Permit)- an earth disturbance permit associated with oil and gas activities.
ICS (In Compliance with Schedule) or ICP (In Compliance with Policy) – typically used to describe a pre-existing issue where the repairs are proceeding as planned.
LOD (Limit of Disturbance) – as per the permit, this refers to the outermost boundary of the area that can be disturbed.
NOT (Notice of Termination) – a document filed with the DEP to effectively terminate an existing earth disturbance permit. Filed after all planned earth disturbance is completed.
NOV (Notice of Violation) – issued by a regulatory agency to indicate a potential issue.
PUC (Public Utility Commission) – regulatory agency that oversees natural gas, pipeline, water, and wastewater services.
VIOIC (Violation Onsite Immediately Corrected) – regulatory agency identified
To find more information on compliance and enforcement or specific information on violations (when available) in these states please visit: Virginia Energy – Gas and Oil – Inspection and Enforcement, PADEP Oil and Gas Compliance – Report Extracts, WVDEP Office of Oil and Gas Enforcement Search, or Oil & Gas Inspections and Enforcement | Ohio Department of Natural Resources.
