The majority of FracTracker’s posts are generally considered articles. These may include analysis around data, embedded maps, summaries of partner collaborations, highlights of a publication or project, guest posts, etc.

Pennsylvania Oil & Gas Fines Analysis

April 12, 2017/by Matt Kelso, BA

In March 2017, FracTracker Alliance conducted a review of the available Pennsylvania oil and gas fine data released publicly by the PA Department of Environmental Protection (DEP) to identify trends in industry-related fines over time and by particular operators. In total, the DEP has assessed nearly $36 million in fines to oil and gas extraction and pipeline operators since January 1, 2000. Such fines are associated with over 42,000 violations issued¹ by DEP in that time frame, covering 204,000 known oil and gas locations,² as well as 91,000 miles of pipelines³ within the Commonwealth.

Understanding the Data Structure

The amount of money that the Pennsylvania Department of Environmental Protection (DEP) fines oil and gas (O&G) operations is included in the DEP’s compliance report published on their website. Even though fines data are made available, they are not necessarily straight-forward, and caution must be taken not to over-estimate the total number of assessed fines.

Records of fines are associated with enforcement identification codes on the compliance report. A single fine is often applied to numerous violations, and the full amount of the fine is listed on every record in this subset. Therefore, the total dollar amount of fines assessed to O&G companies appears overstated. For example, if a $400,000 fine were assessed to settle a group of 10 violations, that figure will appear on the report 10 times, for an apparent aggregate of $4,000,000 in fines. To get an accurate representation of fines assessed, we need to isolate fines associated with particular enforcement ID numbers, which are used administratively to resolve the fines.

This process is further complicated by the fact that, on occasion, such enforcement ID numbers are associated with more than one operator. This issue could result from a change in the well’s operator (or a change of the operator’s name), a group of wells in close proximity that are run by different operators, or it might point to an energy extraction company and a midstream company sharing responsibility for an incident. Sometimes, the second operator listed under an enforcement ID is in fact “not assigned.” The result is that we cannot first summarize by operator and then aggregate those subtotals without overstating the total amount of the assessed fines. In all, 62 of the enforcement ID numbers apply to more than one operator, but this figure amounts to less than one percent of the nearly 15,000 distinct enforcement ID numbers issued by DEP.

Conventional & Unconventional Violations & Fines

Oil and gas wells in Pennsylvania are categorized as either conventional or unconventional, with the latter category intended to represent the modern, industrial-scaled operations that are commonly referred to as “fracking wells.” Contrastingly, conventional wells are supposed to be the more traditional O&G wells that have been present in Pennsylvania since 1859. The actual definition of these wells leaves some blurring of this distinction, however, as almost all O&G wells now drilled in Pennsylvania are stimulated with hydraulic fracturing to some degree, and some of the conventional wells are even drilled horizontally – just not into formations that are technically defined as unconventional. For the most part, however, unconventional remains a useful distinction indicating the significant scale of operations.

Table 1. Summary of oil and gas wells, violations, and fines in Pennsylvania

Category	Conventional	Unconventional	(blank)	Total
Wells	193,655	10,291	0	203,946
Violations	27,223	6,126	9,026	42,375
Fines	$7,000,203	$13,689,032	$21,563,722	$35,949,495*
Fines per Violation	257	2,235	2,389	848
Fines per Well	36	1330	–	176.27
Violations per Well	0.14	0.60	–	0.21
Wells per Violation	7.11	1.68	–	4.81
* The total fine amount issued is not a summary of the three preceding categories, as some of the fines appear in multiple categories

Ninety-five (95)% of the state’s 204,000 O&G wells are classified as conventional, so it should not be surprising to see that this category of wells accounts for a majority of violations issued by the department. However, fines associated with these violations are less frequent, and often less harsh; the $7 million in fines for this category accounts for only 19% of the total assessed penalties. In contrast, the total penalties that have been assessed to unconventional wells in the state are nearly twice that of conventional wells, despite accounting for just 5% of the state’s well inventory

On the 54,412 records on the compliance report, 10,518 (19%) do not indicate whether or not it is an unconventional well. The list of operators includes some well-known conventional and unconventional drilling operators, and hundreds of names of individuals or organizations where O&G drilling is not their primary mode of business (such as municipal authorities and funeral homes). This category also contains violations for midstream operations, such as pipelines and compressor stations. Altogether, 3,795 operators have entries that were not categorized as either conventional or unconventional on the compliance report, and 124 of these operators were issued fines. One additional complication is that some of the violations and fines that fall into this category are cross-referenced in the conventional and unconventional categories, as well.

The resulting impact of these factors is that the blank category obscures the trends for violations and fines in the other two categories. While tempting to reclassify well data in this category as either conventional or unconventional, this would be a tall task due to the sheer number of records involved, and would likely result in a significant amount of errors. Therefore, the FracTracker Alliance has decided to present the data as is, along with an understanding of the complexities involved.

Most Heavily Fined Operators

Despite the numerous caveats listed above, we can get a clear look at the aggregated fines issued to the various O&G operators in the state by constructing our queries carefully. Table 2 shows the top 12 recipients of O&G-related fines assessed by DEP since 2000. Ten of these companies are on the extraction side of the business, and the total number of well permits issued⁴ to these companies since 2000 are included on the table. By looking at the permits instead of the drilled wells, we discover the operator that was originally associated with the drilling location, whereas the report of drilled wells associates the current operator associated with the site, or most recent operator in the event that the location is plugged and abandoned.

Stonehenge Appalachia and Williams Field Services operate in the midstream sector. Combining the various business name iterations and subsidiaries would be an enormous task, which we did not undertake here, with the exception of those near the top of the list. This includes Vantage Energy Appalachia, which was combined with records from Vantage Energy Appalachia II, and the compliance history of Rice Energy is the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.

Table 2. Top 12 operators that have been assessed oil and gas-related fines by DEP since 2000

Operator	Total Fines	Conventional Permits	Unconventional Permits	Violations	Fines / Violation	Fines / Permit
Range Resources Appalachia LLC	$5,717,994	2,104	2,206	819	$6,982	$1,327
Chesapeake Appalachia LLC	$3,120,123	18	3,072	754	$4,138	$1,010
Rice Energy*	$2,336,552		442	165	$14,161	$5,286
Alpha Shale Res LP	$1,681,725	3	62	31	$54,249	$25,873
Stonehenge Appalachia LLC	$1,500,000	–	–	294	$5,102	–
Cabot Oil & Gas Corp	$1,407,275	19	902	726	$1,938	$1,528
CNX Gas Co LLC	$1,274,330	1,613	677	387	$3,293	$556
WPX Energy Appalachia LLC	$1,232,500		347	159	$7,752	$3,552
Chevron Appalachia LLC	$1,077,553	2	604	113	$9,536	$1,778
Vantage Energy Appalachia LLC**	$1,059,766	3	300	35	$30,279	$3,498
Williams Field Services Co, LLC	$872,404	–	–	158	$5,522	–
XTO Energy Inc	$739,712	1,962	461	383	$1,931	305
* Fines for Rice Energy here represent the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream. ** Fines for Vantage Energy Appalachia were combined with records from Vantage Energy Appalachia II.

Predictably, many of the entries on this list are among the most active drillers in the state, including Range Resources and Chesapeake Appalachia. However, Alpha Shale Resources has the dubious distinction of leading the pack with the highest amount of fines per violation, as well as the highest amount of fines per permit. Fitting in with the theme, the story here is complicated by the fact that Alpha had a joint venture with Rice, before selling them their stake in a group of wells and midstream operations that were fined $3.5 million by DEP.⁵ On this compliance report, the fines from this incident are split between the two companies.

Fines Issued Over Time

It is worth taking a look at how O&G related fines have varied over time, as well (Figure 1, shown in millions of dollars). Numerous factors could contribute to changes in trends, such as the number of available DEP inspectors,⁶ the amount of attention being paid to the industry in the media, differing compliance strategies employed by various political administrations, or changes in practices in the field, which could in turn be impacted by significant fines issued in the past.

Figure 1. O&G Fines Issued by DEP, 2000 through 2016

The notable spike in fines issued from 2010 to 2012 corresponds with the peak of unconventional drilling in the state – 4,908 of these industrial scaled wells were drilled during those three years, amounting to 48% of all unconventional wells in PA. In contrast, only 504 unconventional wells were drilled in 2016, or around a quarter of the total for 2011. In this context, the reduction in fines since the early part of the decade seems reasonable.

The association with the number of unconventional wells falls apart a bit in the years 2013 to 2014, however. These two years saw an average of 1,293 unconventional wells drilled, but the fines issued amounted to only 35% of the 2011 total.

Considerable strides have been made in the public accessibility of oil and gas data available from the PA DEP since FracTracker started requesting and reviewing this information in 2009. Still, there are many gaps in the datasets, such as geolocation details for 10 of the 20 largest fines issued by the department. FracTracker hopes external analyses like this one will help to close such gaps and identify operators who, too, need to improve their compliance records.

References & Footnotes

Pennsylvania Department of Environmental Protection (PA DEP) Oil and Gas (O&G) Compliance Database.
PA DEP O&G Spud Database. Note: Starting date 1/1/1800 captures unknown spud (wells drilled) dates.
Pipeline Hazardous Materials and Safety Administration (PHMSA) Pipeline Data Mart Reports.
PA DEP Permits Issued Database.
State Impact PA. (2016). Rice Energy fined $3.5 million for wellsite and pipeline violations.
PennEnvironment Research & Policy Center. (2017). Fracking Failures 2017, Oil and Gas Industry Environmental Violations in Pennsylvania.

Oil & Gas Fines White Paper

This analysis is also available for download in a printer-friendly, white paper format:

Download White Paper (PDF)

2017 PA Oil & Gas Fines Analysis by FracTracker Alliance

Cover Photo by Pete Stern, Loyalsock, PA

SCOTT STOCKDILL/NORTH DAKOTA DEPARTMENT OF HEALTH VIA AP - for oil spills in North Dakota piece

Oil Spills in North Dakota: What does DAPL mean for North Dakota’s future?

April 11, 2017/by Kyle Ferrar, MPH

By Kate van Munster, Data & GIS Intern, and
Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Pipelines are hailed as the “safest” way to transport crude oil and other refinery products, but federal and state data show that pipeline incidents are common and present major environmental and human health hazards. In light of current events that have green-lighted multiple new pipeline projects, including several that had been previously denied because of the environmental risk they pose, FracTracker Alliance is continuing to focus on pipeline issues.

In this article we look at the record of oil spills, particularly those resulting from pipeline incidents that have occurred in North Dakota, in order to determine the risk presented by the soon-to-be completed Dakota Access Pipeline.

Standing Rock & the DAPL Protest

To give readers a little history on this pipeline, demonstrators in North Dakota, as well as across the country, have been protesting a section of the Dakota Access Pipeline (DAPL) near the Standing Rock Sioux Tribe’s lands since April 2016. The tribe’s momentum has shifted the focus from protests at the build site to legal battles and a march on Washington DC. The pipeline section they are protesting has at this point been largely finished, and is slated to begin pumping oil by April 2017. This final section of pipe crosses under Lake Oahe, a large reservoir created on the Missouri River, just 1.5 miles north of the Standing Rock Sioux Tribal Lands. The tribe has condemned the pipeline because it cuts through sacred land and threatens their environmental and economic well-being by putting their only source for drinking water in jeopardy.

Pipelines

… supposedly safest form of transporting fossil fuels, but …

Pipeline proponents claim that pipelines are the safest method of transporting oil over long distances, whereas transporting oil with trucks has a higher accident and spill rate, and transporting with trains presents a major explosive hazards.

However, what makes one form of land transport safer than the others is dependent on which factor is being taken into account. When considering the costs of human death and property destruction, pipelines are indeed the safest form of land transportation. However, for the amount of oil spilled, pipelines are second-worst, beaten only by trucks. Now, when it comes to environmental impact, pipelines are the worst.

What is not debatable is the fact that pipelines are dangerous, regardless of factor. Between 2010 and October 2016 there was an average of 1.7 pipeline incidents per day across the U.S. according to data from the Pipeline and Hazardous Materials Safety Administration (PHMSA). These incidents have resulted in 100 reported fatalities, 470 injuries, and over $3.4 billion in property damage. More than half of these incidents were caused by equipment failure and corrosion (See Figures 1 and 2).

Figure 1. Impacts of pipeline incidents in the US. Data collected from PHMSA on November 4th, 2016 (data through September 2016). Original Analysis

Figure 2. Cause of pipeline incidents for all reports received from January 1, 2010 through November 4, 2016. Original Analysis

Recent Spills in North Dakota

To dig into the risks posed in North Dakota more specifically, let’s take a look at some spill data in the state.

Map 1. Locations of Spills in North Dakota, with volume represented by size of markers

View map fullscreen | How FracTracker maps work

In North Dakota alone there have been 774 oil spill incidents between 2010 and September 2016, spilling an average of 5,131 gallons of oil per incident. The largest spill in North Dakota in recent history, and one of the largest onshore oil spills in the U.S., took place in September 2013. Over 865,000 gallons of crude oil spilled into a wheat field and contaminated about 13 acres. The spill was discovered several days later by the farmer who owns the field, and was not detected by remote monitors. The state claims that no water sources were contaminated and no wildlife were hurt. However, over three years of constant work later, only about one third of the spill has been recovered.

This spill in 2013 may never be fully cleaned up. Cleanup attempts have even included burning away the oil where the spill contaminated wetlands.

More recently, a pipeline spilled 176,000 gallons of crude oil into a North Dakota stream about 150 miles away from the DAPL protest camps. Electronic monitoring equipment, which is part of a pipeline’s safety precautions, did not detect the leak. Luckily, a landowner discovered the leak on December 5, 2016 before it got worse, and it was quickly contained. However, the spill migrated nearly 6 miles down the Ash Coulee Creek and fouled a number of private and U.S. Forest lands. It has also been difficult to clean up due to snow and sub-zero temperatures.

Even if a spill isn’t as large, it can still have a major effect. In July 2016, 66,000 gallons of heavy oil, mixed with some natural gas, spilled into the North Saskatchewan River in Canada. North Battleford and the city of Prince Albert had to shut off their drinking water intake from the river and were forced to get water from alternate sources. In September, 2 months later, the affected communities were finally able to draw water from the river again.

Toxicology of Oil

Hydrocarbons and other hazardous chemicals

Crude oil is a mixture of various hydrocarbons. Hydrocarbons are compounds that are made primarily of carbon and hydrogen. The most common forms of hydrocarbons in crude oil are paraffins. Crude oil also contains naphthenes and aromatics such as benzene, and many other less common molecules. Crude oil can also contain naturally occurring radioactive materials and trace metals. Many of these compounds are toxic and carcinogenic.

Figure 3. Four common hydrocarbon molecules containing hydrogen (H) and carbon (C). Image from Britannica

Crude oil spills can contaminate surface and groundwater, air, and soil. When a spill is fresh, volatile organic compounds (VOCs), such as benzene, quickly evaporate into the air. Other components of crude oil, such as polycyclic aromatic hydrocarbons (PAHs) can remain in the environment for years and leach into water.

Plants, animals, and people can sustain serious negative physical and biochemical effects when they come in contact with oil spills. People can be exposed to crude oil through skin contact, ingestion, or inhalation. Expsure can irritate the eyes, skin, and respiratory system, and could cause “dizziness, rapid heart rate, headaches, confusion, and anemia.” VOCs can be inhaled and are highly toxic and carcinogenic. PAHs can also be carcinogenic and have been shown to damage fish embryos. When animals are exposed to crude oil, it can damage their liver, blood, and other tissue cells. It can also cause infertility and cancer. Crops exposed to crude oil become less nutritious and are contaminated with carcinogens, radioactive materials, and trace metals. Physically, crude oil can completely cover plants and animals, smothering them and making it hard for animals to stay warm, swim, or fly.

An Analysis of Spills in ND

Below we have analyzed available spill data for North Dakota, including the location and quantity of such incidents.

North Dakota saw an average of 111 crude oil spills per year, or a total of 774 spills from 2010 to October 2016. The greatest number of spills occurred in 2014 with a total of 163. But 2013 had the largest spill with 865,200 gallons and also the highest total volume of oil spilled in one year of 1.3 million gallons. (Table 1)

Table 1. Data on all spills from 2010 through October 2016. Data taken from PHMSA and North Dakota.

	2010	2011	2012	2013	2014	2015	Jan-Oct 2016
Number of Spills	55	80	77	126	163	117	156
Total Volume (gallons)	332,443	467,544	424,168	1,316,910	642,521	615,695	171,888
Ave. Volume/Spill (gallons)	6,044	5,844	5,509	10,452	3,942	5,262	1,102
Largest Spill (gallons)	158,928	106,050	58,758	865,200	33,600	105,000	64,863

The total volume of oil spilled from 2010 to October 2016 was nearly 4 million gallons, about 2.4 million of which was not contained. Most spills took place at wellheads, but the largest spills occurred along pipelines. (Table 2)

Table 2. Spills by Source. Data taken from PHMSA and North Dakota.

	Wellhead	Vehicle Accident	Storage	Pipeline	Equipment	Uncontained	All Spills
Number of Spills	694	1	12	54	13	364	774
Total Volume (gallons)	2,603,652	84	17,010	1,281,798	68,623	2,394,591	3,971,169
Ave. Volume/Spill (gallons)	3,752	84	1,418	23,737	5,279	6,579	5,131
Largest Spill (gallons)	106,050	84	10,416	865,200	64,863	865,200	865,200

A. Sensitive Areas Impacted

5,875 square miles

Total Affected Areas (408 linear miles)

Spills that were not contained could potentially affect sensitive lands and waterways in North Dakota. Sensitive areas include Native American Reservations, waterways, drinking water aquifers, parks and wildlife habitat, and cities. Uncontained spill areas overlapped, and potentially contaminated, 5,875 square miles of land and water, and 408 miles of streams.

Drinking Water Aquifers – 2,482.3 total square miles:

Non-Community Aquifer – 0.3 square miles
Community Aquifer – 36 square miles of hydrologically connected aquifer
Surficial Aquifer – 2,446 square miles of hydrologically connected aquifer

A large area of potential drinking water (surficial aquifers) are at risk of contamination. Of the aquifers that are in use, aquifers for community use have larger areas that are potentially contaminated than those for non-community use.

Native American Tribal Reservation

Fort Berthold, an area of 1,569 square miles

Cities – 67 total square miles

Berthold
Dickinson
Flaxton
Harwood
Minot
Petersburg
Spring Brook
Stanley
West Fargo

Map 2. Areas where Oil Spills Present Public Health Threats

View map fullscreen | How FracTracker maps work

B. Waterways Where Spills Have Occurred

Floodplains – 73 square miles of interconnected floodplains
Streams – 408 miles of interconnected streams
Of the 364 oil spills that have occurred since 2010, 229 (63%) were within 1/4 mile of a waterway
Of the 61 Uncontained Brine Spills that have occurred since 2001, 38 (63%) were within 1/4 mile of a waterway.

If a spill occurs in a floodplain during or before a flood and is uncontained, the flood waters could disperse the oil over a much larger area. Similarly, contaminated streams can carry oil into larger rivers and lakes. Explore Map 3 for more detail.

Map 3. Oil Spills in North Dakota Waterways

View map fullscreen | How FracTracker maps work

C. Parks & Wildlife Habitat Impacts

1,684 total square miles

Habitat affected

National Grasslands – on 1,010 square miles of interconnected areas
United States Wildlife Refuges – 84 square miles of interconnected areas
North Dakota Wildlife Management Areas – 24 square miles of interconnected areas
Critical Habitat for Endangered Species – 566 square miles of interconnected areas

The endangered species most affected by spills in North Dakota is the Piping Plover. Explore Map 4 for more detail.

Map 4. Wildlife Areas Impacted by Oil Spills

View map fullscreen | How FracTracker maps work

Methods

Using ArcGIS software, uncontained spill locations were overlaid on spatial datasets of floodplains, stream beds, groundwater regions, sensitive habitats, and other sensitive regions.

The average extent (distance) spilled oil traveled from uncontained spill sites was calculated to 400 meters. This distance was used as a buffer to approximate contact of waterways, floodplains, drinking water resources, habitat, etc. with uncontained oil spills.

Oil Spills in North Dakota Analysis References:

Cover Photo: The site of a December 2016 pipeline spill in North Dakota. Credit: Scott Stockdill/North Dakota Department of Health via AP

For the Environmental Justice Listening Tour

PA DEP Environmental Justice Listening Tour

April 10, 2017/by FracTracker Alliance

A Guide to Current EJ Rules and Potential Changes

by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance
and Veronica Coptis, Executive Director, Center for Coalfield Justice

The Pennsylvania Department of Environmental Protection (DEP) will be hosting a nine-stop “listening tour” to hear residents’ perspectives on environmental justice (EJ). These sessions begin in the western part of the state on April 12th and 13th. The complete list of dates and locations of these meetings can be found here. The DEP will also be accepting written comments, which can be either mailed or emailed to DEP-OEJ@pa.gov.

The EJ listening tour follows on the heels of events in May 2016, when environmental advocacy groups questioned the well pad siting practices of oil and gas drilling company Range Resources, causing the DEP to announce it would revisit its EJ policies. Such changes would include reassessing how EJ zones are designated and what kinds of development triggers additional scrutiny by the DEP’s Office of Environmental Justice. We wrote about this story, and detailed how present EJ rules fail to account for oil and gas development in June 2016.

The following guide is meant to provide helpful information to residents in preparing for the listening tour. We first offer a summary of PA’s present EJ policies, followed by a commentary on what gaps we believe exist in those policies, and conclude with some reflections on EJ policies in other U.S. states and what we might learn from them in reassessing our own state’s EJ laws.

Listening Sessions Format

Each environmental justice listening tour will include opening remarks from Acting Secretary McDonnell, followed by a brief presentation from the Office of Environmental Justice, and then will open to receive testimony from the public. Verbal testimony is limited to 3 minutes for each witness. Organizations are asked to designate one witness to present testimony on their behalf. Verbal comments will be recorded by a court stenographer, and transcripts will be made available to the public at a later date.

The DEP Office of Environmental Justice has offered a set of eight questions to guide comments in the listening tour sessions. They are as follows:

What environmental justice concerns are most pressing in your community?
Do you feel that the current definition of an environmental justice community (20% poverty and/or 30% minority) properly represents the needs of your community and the Commonwealth at large?
Do you feel the DEP is engaged with marginalized communities to ensure that they have a voice in the decision making process? How can the DEP be more engaged with these communities?
What tools have you used to find out information on DEP permitting/enforcement actions?
What ways can the DEP be more effective at sharing information with the public?
How can the DEP be more effective at receiving public input?
What resource(s) is your community lacking that the DEP can provide that would assist in efforts to ensure environmental equity?
What additional steps can be taken by the Department to effectively reach out to these vulnerable communities to ensure that their concerns are taken into consideration?

Summary of Existing EJ Policies

According to the U.S. Environmental Protection Agency, environmental justice is “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” This same definition is used by the DEP.

In 2004, the DEP codified this EJ definition in the Environmental Justice Public Participation Policy. EJ designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. Designations are based on the U.S. Census Bureau and by the federal poverty guidelines.

Below is a map of current EJ designated census tracts in PA that also shows the counties where listening tour sessions will be held. When zoomed in to regional scale, EJ areas can be clicked to see their current poverty and minority percentages. The locations of oil and gas wells and permits are also visible at the regional scale.

Map of current EJ areas (based on 2015 census data) shown in teal, with listening tour counties outlined in red

View map fullscreen | How FracTracker maps work

Of note in the 2004 policy are the kinds of permits that trigger a potential EJ review – specifically: industrial wastewater facilities, air permits for new major source of hazardous air pollution, waste permits for landfills and incinerators, coal mining permits and coal refuse facilities, and/or concentrated animal feeding operations. The policy also allows for review of “opt-in permits” the DEP believes warrant special consideration, but we have found no evidence to suggest that this option has been historically used.

When a project triggers EJ review, the DEP “strongly encourages” the applicant meets with community stakeholders prior to submitting their permit, with the idea that additional public outreach makes project details more apparent. The applicant is also encouraged to produce “plain language” information sheets, online and in print form, regarding the proposed activity.

Issues with Existing PA EJ Policies

A complete list of what may occur when a project triggers EJ review can be found here. The following table is a breakdown of where we see deficiencies in PA EJ policies that need to be addressed:

Existing Policy	Issue	Possible Solutions
EJ Definition EJ areas defined by 20% poverty/30% minority indicators.EJ ensures meaningful involvement of all people regardless of race, color, national origin, or income.	Many communities are just outside poverty/minority thresholds, or are spread across multiple census tracts experiencing concentrated industrial activities. Disproportionate exist due to other factors besides poverty and race.	DEP should go beyond the census tracts, as well as account for other factors such as the “working poor”, homeownership rates, assisted school lunches rate, disability and elderly populations, and language barriers. Reviews should factor in “cumulative impacts” of more developing relative to existing industrial burdens. Regardless of “age and gender” should be added to EJ protection language.
Trigger Permits Limited kinds of “trigger” permit types are listed in the Public Participation Policy as eligible for EJ review.	Permits outside of these categories are also degrading the communities and being targeted to environmental justice communities. Oil and gas extractions, pipelines, and other infrastructure are not currently considered trigger permits but are impacting many environmental justice areas.	DEP should oil and gas permits to the trigger list. All permits, even of seemingly lesser severity, should trigger review to see if they contribute to cumulative impacts to already burdened community.
Permit Notifications DEP program staff must notify the Office of EJ when a permit “trigger” EJ review and report the details of the proposed activity.	Currently not all DEP program staff are alerting the EJ office of trigger permits, and many are not education on EJ policies.	More training and funding needs to be allocated to make sure that trigger permits are not overlooked or mishandled.
Public Education Requiring the distribution of “plain language” information sheets regarding the proposed activity and permit conditions. Public notices are to be placed in widely read publications in print and online.	Does not always happen or the information produced is inadequately written or poorly distributed. Public notices are put in the legal sections of paper, often initial meetings are not even publicly noticed if the company is the only one organizing the meeting.	Enforce this requirement and include real infographics as much as possible. Consult with local community groups to determine what communication tools work best. Publish additional notice outside of newspaper in widely read publications, flyers in local businesses, community centers, and church bulletins. Require applicants to do direct mailing. Updated the “eFacts notification system to include more information and send email notices to interested parties when updates in non-technical language.
Applicant Public Meetings DEP “strongly suggests” applicants meet with all stakeholders, before applying for permit, as well as throughout the permitting process.	Not all stakeholders are being brought into conversations and often DEP allows the applicant to decide who these people should be. Applicants are often not transparent about their plans. Meetings do not occur at all stages of the process.	It should not be up to the applicant to control the process and do outreach. DEP should ensure that all interested parties are engaged in the permitting process. Meeting should be held during the entire permitting process. This should be required, not “strongly suggested.” A meeting should occur after a permit is administratively complete and again after technical review is done but before a decision is made. Many changes happened during technical review and this gives communities the opportunity to weigh in on the final project and understand its timeline. DEP should always participate in these meetings and make themselves available to answer questions from the community.
DEP Public Meetings DEP holds an informal public conference within 30 days of receiving the application to inform residents of EJ area designation and the nature of project.	These meetings frequently are not able to answer people questions and residents are told to wait for additional information. The format of these meetings do not allow for dialogue, which prevents the community from learning from each other.	The DEP needs to hold the informal public conferences in discussion formats so residents can ask questions together and receive answers in person, not just take notes and tell residents they will receive a written response. DEP staff responsible for reviewing the proposal must be present at the meetings to answer questions.
Public Comments DEP accepts comments from EJ communities.	These comments are often not taken into consideration, or given very little weight during the permitting process. Instead, the comments are merely noted for the record.	Create a formal process for integrating comments from community experts who are often best able to provide information about how a project will impact their community.
DEP Availability DEP will maintain presence and be availability to residents throughout permitting process.	DEP staff are available during public meetings but are otherwise unavailable until there is a permit decision. Inadequate continuing public oversight of how EJ policies are administered across the state.	Actively provide updates on the permitting process and changes to the application. The burden should not be on an EJ community to stay up date on the permit, but should be the DEP and applicant’s responsibility. DEP staff responsible for reviewing the proposal must be available to the community to answer questions. DEP should also prioritize filling its regional Environmental Advocate staff positions currently vacant in many of its districts. Convert the DEP Citizen Environmental Justice Advisory Board (EJAB) to a full committee, with the power to oversee EJ permits under review and influence state EJ policies. Hold quarterly EJAB meetings in different DEP regions on a rotating basis.

Reflections on other states’ EJ policies

States that use poverty and race indicators differently:

Connecticut: Uses income below 200% of the federal poverty level (“working poor”).
Illinois: indicates low-income and/or minority population as being “greater than twice the statewide average.”
Massachusetts: Defines by census “block group” rather than census tract, which can identify pocket EJ areas that might be lost in larger census tracts.
Texas: For income indicator, uses census block group and income below 200% of the federal poverty level.

States that go beyond poverty and race indicators:

California: Considers existing disproportionate environmental burden. Also, demographics include “low levels of homeownership, high rent burden…or low levels of educational attainment.”
Connecticut: includes a “distressed community” indicator, defined as whether it is eligible for HUD grants, or experienced layoffs/tax loss due to a major plant closing.
Georgia: includes language for elderly and disabled populations “The Americans with Disabilities Act (ADA) encourages the involvement of people with disabilities in the development and improvement of transportation and paratransit plans and services.”
Massachusetts: Uses linguistic isolation, defined as “25% or more of households having no one over the age of 14 who speaks English only, or very well.”
New Jersey: Communities can file a petition to be recognized as a vulnerable.

Example of better public participation affordances:

New Jersey: When a community is designated EJ, a task force is formed to develop a unique “Action Plan” after consultation with residents, local, and county government, that will address environmental, social and economic factors affecting their health or environment. This task force monitors Action Plan implementation, and advises development projects to reduce impacts.

Conclusions

Environmental justice rules came into existence in order to deal with the burdens of large polluting facilities like landfills, incinerators, and coal mines. Race and poverty measures are, without question, two very important indicators that have provided for the fair treatment of people of all races, income, and cultures in these instances. However, if we are to properly assess how residents are disproportionately impacted across a range of environmental burdens in the state, other indicators of marginalization should be included. The Center for Coalfield Justice suggests a few in a report titled Community Indicators of Environmental Justice: A Baseline Report Focusing on Greene and Washington Counties, Pennsylvania.

Fair treatment in EJ communities should also mean offering mechanisms for meaningful input that allow residents to shape the ultimate direction of proposed projects, as well. Finally, current EJ policies are very limited in only addressing future projects, whereas issues such as how disadvantaged communities, struggling with legacy problems such water, air, and soil pollution, are left to other agencies to deal with.

We encourage residents of Pennsylvania to attend an environmental justice listening tour session to share their perspectives, and how the DEP can better fulfill its mandates to protect vulnerable communities.

Photo: Clairton Coke Works, by Mark Dixon, Blue Lens, LLC.

Interview with Sherry Knowlton, Author of Dead of Spring

April 6, 2017/by Guest Author

The Shale Gas & Oil Health Registry: A Collective Step to Track the Impacts of Fracking

April 4, 2017/by FracTracker Alliance

“It’s all about facts. Documented facts…”

… asserted a county commissioner to a recent gathering of concerned residents in Hannibal, Ohio. His comment came at the end of over an hour of deeply moving narratives from residents, sharing disturbing changes in their health after a disastrous well pad fire in their community and other ongoing shale development in the area. One family, whose home was blanketed by the heavy black smoke from the fire, which burned for five days in 2014, told of respiratory problems, hair loss, newly-diagnosed thyroid issues, and a premature birth. Another family reported worsening of existing cardiac conditions, sleep disturbances, and considerable stress due to continued encroachment of pipelines and compression stations.

Figure 1: Residents of the Fort Berthold Indian Reservation in North Dakota live amid numerous oil rigs. Photo credit: Shalefield Stories, Vol. 2.

Throughout the country, personal stories like these offer a meaningful window into the experiences of people living at the frontlines of shale gas and oil development – often called ‘fracking.’ But aggregated into a formal health registry, these experiences can also form the kind of documentation needed to inform public health research and legislators who, like the county commissioner in Ohio, insist on documented evidence before issuing health-protective policies.

A health registry is “a dataset of uniform information about individuals collected in a systematic and comprehensive way, in order to serve a predetermined medical or public health purpose.”

The Southwest PA Environmental Health Project (EHP), in partnership with the Genetic Alliance, has just introduced the first such national system. In this online system, participants share – and control access to – their own data, making it unique among many other registries. This exciting new forum invites those living, working, or going to school near shale gas and oil development, like the families described above, to share their exposures and document their health symptoms. Perhaps most importantly, it ensures that personal stories are collected, respected, and treated as the important data that they are.

Figure 2: These quick and informative videos introduce EHP’s Shale Gas & Oil Health Registry and how it works. They feature the voices of those who helped create it, including public health professionals, the director of EHP, and a community member.

Why a registry?

Public health research affirms that there are significant health risks for those living, working, or attending school near shale gas and oil development. Research points to links between proximity to fracking and worsened asthma and other respiratory impacts and skin conditions; fracking’s noise pollution and stress-related conditions, like cardiovascular problems; and low birth weight babies among mothers living near numerous hydraulically fractured wells.

Physicians, Scientists, and Engineers for Healthy Energy (PSE) conducted a thorough examination of the extensive and growing body of shale gas and oil-related research and found that between 2009 and 2015, 84% of the studies focused on health have findings that “indicate public health hazards, elevated risks, or adverse health outcomes.”

US map of populations near active drilling activity

Figure 3: Populations in the U.S. near active drilling. The Shale Gas & Oil Health Registry has a national scope. Click on the image to learn more about how this map was made.

For years, some medical professionals attuned to environmental effects on health have noted correlations between fracking and health symptoms in their patients. But without a clear explanation of causation that links such symptoms to fracking, researchers need more data.

The Pennsylvania Medical Society recommended a registry as a necessary step toward getting a grasp on the public health problem. A health registry collects health data systematically, and may support further epidemiology and toxicology research by putting these patterns in higher contrast.

Laying the Groundwork

The Shale Gas & Oil Health Registry did not emerge in isolation, but rather is one of several ongoing efforts toward gathering the innumerable accounts of health symptoms from shale development regions around the country.

Important grassroots initiatives include the List of the Harmed, started by Jenny Lisak in 2011. The List catalogues over 20,000 stories of human, animal, and environmental impacts. The Natural Gas Exploration & Production Health and Community Impacts Survey, created by The Damascus Citizens for Sustainability (DCS), is an effort to collect health impact information from individuals in shale gas communities and hopefully trigger further review from the Agency for Toxic Substances and Disease Registry (ATSDR). Additionally, there are numerous peer reviewed studies on the topic, but they are often too limited in scope and size to be generalized to communities outside of where the data was originally collected.

Families in Washington Co., Pa who are facing possible issues through the creation of cybergentic gas processing plant in western Pa. A Cibus Imperial compression station sits above a suburban community, people there are fearful of their air quality because of this plant, in Bulger, PA

Figure 4: In Washington County, PA, houses sit just below a compressor station, a type of natural gas facility that can produce air emissions, noise, and light pollution. In the health registry, participants can answer questions about the types of facilities they are exposed to. Photo credit: Karen Kasmauski, iLCP.

Two states have begun their own registry-related efforts. Colorado’s Oil & Gas Health Information and Response Program includes an online self-referral form, a hotline for those with health concerns potentially related to oil and gas, and a health information “clearinghouse.” Their program aims to illuminate “possible health effects related to oil and gas operations,” which the program intends to make available to the public, researchers, and policy-makers (source).

Pennsylvania, where EHP does much of its on-the-ground work, has a history of legislative calls for its own registry, beginning with recommendations issued by Governor Tom Corbett’s Marcellus Shale Advisory Commission in 2011. The Secretary of Health at the time called a registry “the most timely and important initiative” for the Department of Health (DOH). Current Governor Tom Wolf called for a shale gas health registry in his 2014 gubernatorial campaign. He proposed budgeting $100,000 to the PA Department of Health (DOH) for the cause, although health professionals argue that more is needed to implement an effective registry. According to recent conversations with EHP, DOH is in the process of developing a system similar to Colorado’s, in coordination with that state. For the time being, Pennsylvanians seeking assistance from DOH will find a webpage with limited information, directing calls to the state’s Bureau of Epidemiology.

Making the Registry a Reality

There is a clear need for a system to collect individuals’ exposures and health symptoms, with a national scope that matches the country-wide scale of shale development. Yet, the costs of initiating and maintaining a registry, political issues related to industry reporting on the chemicals they use and discharge, and scientific issues such as scant exposure data and limited funding for research, are some of the various obstacles that faced the implementation of a health registry.

From a health perspective, symptoms potentially related to drilling activity may be similar to symptoms from unrelated causes, or may be exacerbations of existing health conditions. Added to this is the complexity of exposure sources, since an individual or family may live, work, or go to school in proximity to multiple types of shale gas and oil facilities. Moreover, those at the frontlines of shale oil and gas development – whose health data is essential to the registry – may be reluctant to participate due to social or family pressures.

The Shale Gas & Oil Health Registry directly addresses each of these challenges. Using an existing registry infrastructure created by Genetic Alliance significantly reduced the costs of launching and maintaining the registry. Including systematic questions that let users record their proximity to – and frequency of – exposure captures the complexity of this important information. And through steps like collecting zip codes instead of home addresses, and offering the choice of privacy settings that only allow researchers to see data in anonymous form, the registry ensures confidentiality and user control of data.

wv-host-farms-program-photo — Poorly constructed well pad permitted to operate on a wetland, Photo by WV Host Farms

ed-wade-jr — Well pad fire in WV, Photo by Ed Wade Jr.

wv-host-farms-program-photo-truck-convoy — Heavy truck traffic is common near drilling sites, Photo by WV Host Farms

Figure 6. A variety of sources can trigger health issues during shale gas and oil development. These include air emissions from processing facilities and well pad accidents, as well as the heavy truck traffic required to drill and frack a well; spills and other forms of water contamination; and psychological impacts like stress and sleep disruption.

End Result: The Shale Gas & Oil Health Registry

Figure 7: The health registry includes a set of questions for participants whose exposures come from working in the gas and oil industry. Photo credit: Bill Hughes.

The result of these efforts is a secure, online system where participants – people within five miles of shale gas and oil development, with or without health symptoms – can create an account for themselves and/or their family members. The online registry guides them through a series of screens inviting them to share the various exposures they encounter, such as heavy truck traffic, air emissions, and water impacts. Participants can catalogue and update health symptoms that have surfaced or worsened during their exposure, while controlling who can view and share their personal information.

Industry workers and children can even be registered in this system using a set of tailored questions. The registry also allows an assistor to create a profile and answer the questions for someone not comfortable with or able to use the online system.

One Registry to Meet Many Needs

EHP created the health registry to respond to the needs of several groups: affected communities, researchers, policymakers, and the public.

Figure 8: A resident of Washington County, PA sits in front of paperwork documenting health struggles that may be connected to shale gas development near her home. Photo credit: Shalefield Stories, Vol. 2.

In developing the health registry, EHP recognized that those affected by shale development must not be treated as “data points,” but as collaborators in – and beneficiaries of – the process. As a venue to share health concerns, the registry helps give voice to those who may be suffering in silence. Participants can connect with researchers, receive a biannual newsletter of updates on the growing size of the registry and new knowledge around health impacts and treatment. In the long view, the registry gives individuals an opportunity to take part in a large-scale effort that may ultimately inform positive change and promote protections from ever-expanding shale development.

The data participants provide via the registry can also help researchers identify emergent patterns and generate testable hypotheses for new studies. Through this process, a registry can enable research that is responsive to community needs.

Policymakers stand to benefit, as well. The patterns that the registry highlights, and the additional research it makes possible, can help elected leaders to understand the scope of the health problem. In time, this knowledge can inform policies and regulations that benefit those living in shale country.

A chance to be a part of something larger

EHP encourages those who live near shale gas and oil development, with or without health symptoms, to register now and fill out the registry questionnaire. The three-step process takes only about 20 minutes.

Share: Answer as many questions as you would like, and control how and with whom that information is shared
Connect: Find out how you compare to others, and let support and helpful resources come to you
Discover: If you wish, let researchers access your information to help them understand the health impacts of shale oil and gas development and transport

Researchers and healthcare providers who want to take part in the possibilities created by the registry, such as studying data patterns from participants who have elected to share certain information, can contact Jill Kriesky (jkriesky@environmentalhealthproject.org) or Beth Weinberger (bweinberger@environmentalhealthproject.org) for more information.

Button to join the Shale Gas & Oil Health Registry

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Click here to join the Shale Gas & Oil Health Registry!

Sincere Appreciation

Many thanks to those who contributed to this article about the Shale Gas & Oil Health Registry through interviews and by sharing the images used in this story.

The International League of Conservation Photographers and the Environmental Integrity Project for sharing photographs of families coping with fracking where they live, “The Human Cost of Energy Production.”

Dana Dolney, co-founder of Friends of the Harmed. Friends of the Harmed, publishers of Shalefield Stories, dedicate 100% of donations they receive to providing much-needed direct aid to families negatively affected by fracking.

Jenny Lisak, creator of List of the Harmed. List of the Harmed is an ever-growing list of the individuals and families that have been harmed by fracking (or fracked gas and oil production) in the U.S.

Barbara Arrindell, director of Damascus Citizens’ Group. Damascus Citizens for Sustainability (DCS) is a collaborative endeavor to preserve and protect clean air, land and water as a civil and basic human right in the face of the threat posed by the shale gas extraction industry.

Jill Kriesky, Associate Director and Beth Weinberger, Research & Communications Specialist, both of The Southwest PA Environmental Health Project. The Environmental Health Project (EHP) is a nonprofit public health organization that assists and supports residents of Southwestern Pennsylvania and beyond who believe their health has been, or could be, impacted by unconventional oil and gas development (UOGD, or “fracking”).

By Leann Leiter, Environmental Health Fellow, FracTracker Alliance & EHP

Radium Watersheds a Risk

April 3, 2017/by Guest Author

By Greg Pace – Columbus Community Bill of Rights, and Julie Weatherington-Rice – Environmental Consultant

Figure 1. Map of Columbus, OH Watersheds and Class II Injection Wells

Most Ohio residents are unaware of the frack fluid deep underground injection occurring north of Columbus, underneath the region’s source water protection watersheds (Figure 1).

Materials injected are liquids that have as much as ten times the salt concentration of sea-water. Mixed with this “brine” solution is a combination from hundreds of chemicals that are used in different stages of horizontal hydraulic fracturing, the process used to extract natural gas, petroleum, and hydrocarbon liquids used to make industrial materials such as plastics. BTEX compounds including benzene are always present in the wastewater, along with formaldehyde, bromides, ethylene glycol (antifreeze), and arsenic, with many other carcinogenic and otherwise highly-toxic substances.

Radioactivity of Shale Gas Wastewater

One of the biggest questions in this mix of toxic disposal is how much radioactive content exists. Radium-226 is most worrisome, as it has a very long half-life (1,600 years). It is water-soluble and, once it enters the human body, seeks to find a home in our bones where it will emit its cell-formation-destabilizing effects for the remainder of our lifetime. This radionuclide is known to cause leukemia, bone cancers, blood disorders, and other diseases.

The state of Ohio does not monitor the content of materials that are injected into our Class II injection wells deep in the ground. This oil and gas waste can come from anywhere, including Pennsylvania’s Marcellus shale, which is the most highly-radioactive geology of all the shale plays in the country. Radium-226 readings as high as 15,000 pico-curies per liter have been read in Marcellus shale brines. The EPA drinking water limit for radium-226 is 5 pico-curies per liter, which puts the Marcellus reading at 3,000 times higher than the drinking water limit.

Exposure through drinking water is a pathway to human disease from radium-226. Once oil and gas waste is disposed of underground in a sandstone or limestone layer, the fluids are subject to down-gradient movement, wicking through capillary action, and seepage over time. This means that the highly radioactive wastewater could eventually end up in our underground drinking water sources, creating radium watersheds. This practice is putting our watersheds at risk from radioactive contamination for hundreds of years, at least.

Can injected fluids migrate?

Depending on whether you confer with a geologist who works with the oil and gas industry, or from an independent geologist, you will get a different opinion on the likelihood of such a pollution event occurring. Industry geologists mostly claim that deep injection leaves very low risk of water contamination because it will not migrate from the planned area of injection. On the other hand, independent geologists will tell you that it is not a matter of if the liquids will migrate, but how and when. The ability to confirm the geology of the underground area layer of injection “storage” is not exact, therefore accuracy in determining the probability for migration over time is poor.

Figure 2. Ohio Utica Brine Production and Class II Injection Well Disposal

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We do know, however, that all underground systems in Ohio leak – Research by The Ohio State University and the US Geological Survey show that the age of the water in brine formations is far younger than the age of the rock deposits they are found in. See where wastewater is being created and disposed of in Ohio using the dynamic map above (Figure 2).

Spill Risks to Columbus, OH Water

According to area geologist, Dr. Julie Weatherington-Rice, the source for Columbus’s water to the north is mostly from surface water. This water comes from the Delaware and Morrow county watersheds that feed into sources such as the Hoover and Alum Creek reservoirs. The major threat from injection wells to our watershed is from spills, either from trucks or from storage at the injection well sites themselves.

Dead fish floating in Vienna area pond contaminated by injection well system spill Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

Figure 3. Dead fish floating in Vienna area pond contaminated by injection well system spill. Source: MetropolitanEnegineering Consulting & Forensics-Expert Engineers

In April 2015, as much as 8,000 gallons of liquid leaked from a malfunctioning pipe in the storage apparatus of an oil/gas waste storage and injection well site in Vienna, OH. This caused a wildlife kill in two ponds (Figure 3), and the spill was not contained until 2/3 mile downstream in a tributary. The firm who owned the facility was found negligent in that they did not install a required containment liner for spills. The incident was discovered by neighboring residents, but apparently employees knew of the leak weeks before. Of note in this incident was that Ohio Department of Natural Resources, the regulatory agency that oversees all oil/gas production activity in Ohio including injection, stated that there was “minimal impact to wildlife.”

Figure 4. Brine tanker rollover near Barnesville, OH spilled 5,000 gal. of produced brine. Source: Barnesville, OH Fire Department

In March, 2016, a tanker truck carrying produced waste from a hydraulically fractured well pad overturned outside of the Village of Barnesville, Ohio (Figure 4). The truck spilled 5,000 gallons of liquid waste into a field that led into a tributary, leading the fluids to enter one of the city’s three drinking water supply reservoirs. The water source was shut down for more than two months while regulators determined if water levels were safe for consumption. There was a noted spike in radium-226 levels during water testing immediately after the spill.

Of greatest concern is that, although many millions of gallons of frack waste have been injected into the wells north of Columbus over the past few years, we expect that this activity will increase. For the first time, the United States began exporting its own natural gas in 2016, to regions such as Europe and South America. As the industry consolidates from the depression of oil prices over the past two years and begins to ramp up again, we expect the extraction activity in the Marcellus and especially Utica to increase to levels beyond what we have seen since 2011. The levels of injection will inevitably follow, so that injection wells in Ohio will receive much more than in the past. The probability of spills, underground migration, and human-induced earthquakes may increase steeply, as well.

An Aging Disposal Infrastructure

On our Columbus Community Bill of Rights website, we show pictures of some of the Class II injection wells in Morrow County, most of them converted from legacy production wells. These old wells are located in played out oil/gas fields that may still be producing or have abandoned but not plugged (closed) wells, allowing other routes for injected liquids to migrate into shallow ground water and to the surface. The dilapidated condition of these converted Class II wells makes it hard to believe that they are used to inject millions of gallons of wastewater under high pressure. While many of the wells in the state are as deep as 9,000 feet, all of the injection wells we have seen in Morrow County are only 3,000-4,000 feet deep. This situation puts surface water at greater risk over time, as it is probable that, over the generations, some of the fluids will migrate and wick into the higher subterranean strata.

Figure 5. Ohio Class II Injection Wells by Type

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One well (Power Fishburn unit, photo below) showed signs of poor spill control when we took our October 2015 injection well tour. While we were there, a brine tanker arrived and began pumping their load into the well. The driver took pictures of our license plates while we were there watching him. A year later, there is a whole new structure at the well, including a new storage tower, and an extensively beefed-up spill control berm. Maybe we need to visit all of the facilities when they come by to use them!

Another well (Mosher unit, photo below) which hadn’t been used since 2014 according to available records, showed signs of a spill around the well. The spill control berms look as if they probably had flooded at some point. This well sits on the edge of a large crop field.

Figures 6a and 6b. Photos of Class II injection wells. Click on the images to expand them.

North of Columbus, the city of Delaware’s underground source water is at risk of becoming contaminated from underground migration of disposed wastewater over time, through wicking and seepage effects (as explained earlier in this article). They are also vulnerable to their reservoir being contaminated from surface spill migration through their watershed.

Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

Figure 7. Google maps rendition of Ohio Soil Recycling facility in south Columbus, Ohio, that accepts shale drill cuttings for remediation to cap the landfill. Source: Google Maps/author

South of Columbus is another threat – drill cuttings from the drilling process have been authorized for disposal at a “remediation” landfill adjacent to the Alum Creek (Figure 7). The bioremediation treatment used is not indicated to solve the problem of removing radionuclides from the materials. This landfill had been remediated under the Ohio EPA twice when it was a toxic drum dump, after toxins were found to have been leaching into the watershed creek. Columbus’s Alum Creek well, as well as Circleville, are at risk of contamination in their drinking water if radionuclides from the cuttings leach into Alum Creek. Again, this is a long-term legacy of risk to their water.

Radiation Regulatory and Monitoring Gaps

Since The Ohio legislature deemed the radioactive content of shale cuttings to be similar to background levels in the 2013 state budget bill, cuttings can be spread around to all licensed landfills in Ohio with absolutely no accountability for the radium and other heavy metal levels in them. Unfortunately, the measuring protocol used in the pilot study for the Columbus facility to demonstrate to Ohio EPA that radium-226 was below EPA drinking water limits has been shown in a University of Iowa study to be unreliable. The inadequate protocol was shown to indicate as little as 1% of the radium levels in shale waste samples tested.

As such, there have been hundreds of incidents where truckloads of cuttings have been turned away at landfills with crude radiation monitors. In 2013 alone, 2 loads were turned away in Ohio landfills, and over 220 were turned away from Pennsylvania landfills.

Ohio has a long way to go before it can be considered a clean energy state. The coal industry polluted significant water sources in the past. The fracking industry seems to be following suit, where contaminations will surprise us long into the future and in broader areas.

Map Data for Download

Mysterious leak near Porterville Compressor Station, NY

March 27, 2017/by Karen Edelstein

Last month, FracTracker Alliance featured a blog entry and map exploring the controversy around National Fuel’s proposed Northern Access Pipeline (NAPL) project, shown in the map below. The proposed project, which has already received approval from the Federal Energy Regulatory Commission (FERC), is still awaiting another decision by April 7, 2017 — Section 401 Water Quality Certification. By that date, the New York State Department of Environmental Conservation (NYS DEC) must give either final approval, or else deny the project.

Northern Access Pipeline Map

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The NAPL project includes the construction of 97-mile-long pipeline to bring fracked Marcellus gas through New York State, and into Canada. The project also involves construction of a variety of related major infrastructure projects, including a gas dehydration facility, and a ten-fold expansion of the capacity of the Porterville Compressor Station located at the northern terminus of the proposed pipeline, in Erie County, NY.

On three consecutive days in early February, 2017, the New York State Department of Environmental Conservation (NYS DEC) held hearings in Western New York to gather input about the NAPL project. On February 7^th, the day of the first meeting at Saint Bonaventure University in Allegany County, NY, an alarming — and yet to be fully reported — incident widely considered to be a gas leak, occurred at, or near, the Porterville Compressor Station (also known locally as the “Elma Compressor Station”). The incident is thought to be connected to the planned upgrades to the facility, but was not even mentioned as a concern during the public meetings relating to the Northern Access Pipeline in the subsequent hours and days.

What follows is a story of poor communication between the utility company, first responders, and local residents, resulting in confusion and even panic, and has yet to be conclusively explained to the general public.

Incident Description

Area of incident in NY State

We know that a little past 10 AM on February 7^th, people in the villages of Elma and East Aurora, within about a mile of the Porterville Compressor Station, reported strong odors of gas. They filed complaints with the local gas utility (National Fuel), and the local 911 center, which referred the calls to the local Elma Fire Department. The fire department went to the Porterville Compressor station to investigate, remembering a similar incident from a few years earlier. At the compressor station, representatives from National Fuel, the operator of the compressor station, assured the fire company that they were conducting a routine flushing of an odorant line, and the situation was under control, so the fire company departed.

Residents in the area became more alarmed when they noticed that the odor was stronger outside their buildings than inside them. National Fuel then ordered many residents to evacuate their homes. The East Aurora police facilitated the evacuation and instructed residents to gather in the East Aurora Library not far from those homes. Nearby businesses, such as Fisher Price, headquartered in East Aurora, chose to send their employees home for the day, due to the offensive odor and perceived risks.

Around 11:30 in the morning, up to 200 clients at Suburban Adult Services, Inc. (SASi), were evacuated to the Jamison Road Fire Station, where they remained until around 3 PM that afternoon. Over 200 reports were received, some from as far away as Orchard Park, eight miles down-wind of the compressor station.

After East Aurora elementary and middle schools placed complaints, National Fuel told them to evacuate students and staff from their buildings. Realizing that the smell was stronger outside than inside the building, school leaders revised their plans, and started to get buses ready to transport student to the high school, where there had not been reports of the odor. Before the buses could load, however, the police department notified the school that the gas leak had been repaired, and that there was no need to evacuate. School officials then activated the school’s air circulation system to rid the building of the fumes.

Perplexingly, according to one report, National Fuel’s Communications Manager Karen Merkel said “that the company did not reach out into the community to tell people what was going on because the company cannot discourage anyone from making an emergency gas call.”

Merkel noted further, “You never know if the smell being reported is related to work we are doing or another gas leak,” she said. “This wouldn’t be determined until we investigate it.”

That smell…

Some background on gas leaks & odorant additives

Ethyl mercaptan molecule

An odorant, such as ethyl mercaptan, is often added to natural gas in order to serve as an “early warning system” in the event of a leak from the system. Odorants like mercaptan are especially effective because the humans can smell very low concentrations of it in the air. According to the National Cen ter for Biotechnology Information, “The level of distinct odor awareness (LOA) for ethyl mercaptan odorant is 1.4 x10^-4 ppm,” or 0.00014 parts per million. That translates to 0.000000014 percent by volume.

Not all natural gas is odorized, however. According to Chevron Phillips, “mercaptans are required (by state and federal regulations) to be added to the gas stream near points of consumption as well as in pipelines that are near areas with certain population density requirements, per Department of Transportation regulations… Not all gas is odorized, though; large industrial users served by transmission lines away from everyday consumers might not be required to use odorized gas.” Also, because odorants tend to degrade or oxidize when gas is travelling a long distance through transmission lines, they are not always added to larger pipeline systems.

The explosion and flammability concentration limit for natural gas refers to the percentage range at which a gas will explode. At very low concentrations, the gas will not ignite. If the concentration is too high, not enough oxygen is present, and the gas is also stable. This is why gas in non-leaky pipelines does not explode, but when it mixes with air, and a spark is present, the result can be disastrous. Methane, the primary component of natural gas, has a lower explosive level (LEL) of 4.4% and an upper explosive limit (UEL) (above which it will not ignite) of 16.4%. Nonetheless, levels above 1% are still worrisome, and may still be good cause for evacuation.

Therefore, the margin of safety between when natural gas is detectable with an odorant present, and when it may explode, is very broad. This may help to explain why the smell of gas was detected over such a broad distance, but no explosion (very fortunately) took place.

Local memories of gas explosion in East Aurora

Many East Aurora residents have had first-hand experience with the dangers posed by gas lines in their community. Less than 25 years ago, in September 1994, a high-pressure pipeline owned by National Fuel ruptured in an uninhabited area between East Aurora and South Wales along Olean Rd. The blast left a 10-foot-deep, 20-foot-wide crater, and tree limbs and vegetation were burned as far as 50 feet away.

Porterville first-hand accounts and inquiries

FracTracker spoke extensively with one resident of East Aurora, Jennifer Marmion, about her experiences, and efforts to understand what had actually happened the day of this incident.

When personnel from the Jamison Fire Company — who are assumed to be first responders to emergencies of this sort — arrived at the Porterville Compressor Station, they were told by National Fuel that there was no hazard and that their services were not needed. Consequently, these crews left the site. The East Aurora Police Department was given a different explanation by National Fuel; there was a valve malfunction somewhere along Two Rod Road in Marilla. Still later, National Fuel indicated that the pipeline changeover occurred closer to the compressor station itself. The closest distance between anywhere on Two Rod Road and the compressor station, itself, is a mile and a half. And Ms. Marmion was given a still different story by a National Fuel engineer: that the odor, indeed, resulted during the replacement of a 100-foot-long section of aging pipeline at the Porterville (“Elma”) Compressor Station.

Key locations in incident report

Some reports indicated an alternate explanation: that the odor originated at the East Aurora Town Hall (J. Marmion, pers. comm., via Channel 7 News), or a leaky valve along a pipeline near Marilla (J. Marmion, pers. comm, via East Aurora Police Department dispatcher). A member of the East Aurora Fire Department surmised that the leak might have been closer to Olean Road, south of the village, where there was a history of other leaks. The day after the incident, National Fuel indicated that the odor originated from the compressor station, and was the result of a routine, scheduled “blowdown” by National Fuel — wherein gas lines at the compressor station are cleared as part of routine maintenance. However, when pressed for more details, they did not provide them.

In need of follow up

More than six weeks have passed since the incident, and there is still no definitive explanation available. Clearly, there was considerable confusion about what the correct, and safe, procedure needed to be, as well as how this information needed to flow to the public. Ultimately, a representative from National Fuel’s Government Affairs office agreed that he would alert the local towns and fire departments when maintenance activities would be occurring. It is surprising that this was not already standard practice.

Although Ms. Marmion is continuing to be a determined citizen activist, she has been met with a frustrating array of ambiguous and often conflicting descriptions, phone calls that go un-answered, voice mailboxes at offices that are either full or not set up to receive messages. Furthermore, although National Fuel has told Marmion that there is an Action Plan to be followed in the event of an emergency, they have been unable to provide her with a written or electronic version of this document, because “the action plan is just known.”

National Fuel points to the weather

National Fuel maintains that the only factor that was out of the ordinary was that during the event, a combination of unusual weather factors caused the released gas to travel in an unusual manner and also not dissipate as quickly as expected. National Fuel also indicated that the strong odor (created by the additive mercaptan) was a benefit to the local community, added to natural gas so that residents would be alerted to problems. It’s important to note that the largest gas transmissions pipelines, like the nearby 26” diameter Tennessee Gas Pipeline to the east of Elma and East Aurora, as well other pipelines that will run to the greatly expanded Porterville Compressor Station as part of the Northern Access Pipeline project, will be without the odorant.

Here’s what FracTracker could verify, based on National Weather Service, and Weather Underground historical data. In the morning and afternoon of February 7^th, the wind was uncharacteristically blowing from the east/northeast — atypical for western New York, when winds normally come from the west. Wind speeds were recorded between 10-15 mph. Humidity was also uncharacteristically high for February — topping out at 93% that day. Warm air aloft, combined with freezing rain, created a temperature inversion. The moist air then trapped the odor, which lingered across the region.

Screen captures of weather statistics on February 7, 2017 (Source: wunderground.com). Note dominant wind direction from ENE, as well as high humidity, during morning and early afternoon, when incident took place.

Who monitors air quality in Western New York?

Calls by FracTracker for clarification from the New York State DEC’s Division of Air Resources have gone unanswered. The only station at which the DEC monitors methane is located more than 275 miles away to the southeast, in the Bronx. In Erie County, where the incident took place, there are only four permanent ambient air pollution monitoring stations. These include stations in:

Amherst: Continuous monitoring of ozone, NO_2.Manual monitoring of PM₅, acid deposition.
Buffalo: Continuous monitoring of SO₂, NO_x, NO, NO_2,NO_y, CO, CPM₅. Manual monitoring of PM_2.5, PM₁₀, toxics
Brookside Terrace/Tonawanda: Continuous monitoring of SO₂, CPM₅. Manual monitoring of toxics and carbonyls
Grand Island (special purpose only): Continuous monitoring of CPM₅. Manual monitoring of toxics and carbonyls

“PM” refers to particulate matter diameter. PM_5,for example, denotes particulate matter 5 microns in diameter, and smaller.

The East Aurora and Elma fire departments lack the appropriate air quality detection instruments to make their own judgements on the explosive nature of these gas plumes. Instead, small towns rely on the expertise of National Fuel to arrive on the scene after a call has been made, so that National Fuel can take measurements and then respond to the community. Some residents waited over three hours for an assessment, but by this time the plume had drifted away two hours ago.

National Fuel, however, has not disclosed any of the air quality data measurements they made on February 7^th when they responded to this complicated incident. Ms. Marmion and others still want to know what levels of methane were measured in the communities involved in this incident, or the specific quantity of gas that entered the air that day.

What’s next?

While National Fuel did not notify the residents or the school district administration in advance of the scheduled “blowdown,” their Government Affairs Representative indicated that in the future, town governments, community leaders, and the local fire companies would be alerted to the upcoming releases and maintenance work. Nonetheless, weeks after the odor incident, National Fuel has neither contacted the local community leaders, nor local law enforcement, to provide complete and detailed answers as to what actually happened on February 7^th.

By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance. Special thanks to East Aurora resident Jennifer Marmion, for her insights and comments.

Re-imagine Beaver County meeting - Photo by Sophie Riedel

Mapping a new vision in PA: Alternatives to petrochemical development

March 24, 2017/by FracTracker Alliance

At a Re-Imagine Beaver County gathering in Pennsylvania earlier this month, static maps became dynamic in the hands of those who live in and around the region depicted. Residents of this area in the greater Pittsburgh region gathered to depict a new vision for Beaver County, PA. This county is currently faced with the proposal of a massive Shell-owned petrochemical facility – also called a “cracker” – and further build-out that could render the area a northern version of Louisiana’s “Chemical Corridor.” Participants at this event, from Beaver County and beyond, were encouraged to collectively envision a future based on sustainable development. The picture they created was one that welcomes change – but requires it to be sustainable and for the benefit of the community that makes it happen.

Re-Imagine Beaver County Group Mapping - by Sophie Riedel

Figure 1: Participants study a map of Beaver County. Photo credit: Sophie Riedel.

Re-Imagine Beaver County Participants

Panelists from municipal government, organic agriculture, and leaders and entrepreneurs of sustainable initiatives started off the event, sponsored by the League of Women Voters of Pennsylvania and endorsed by the Beaver County Marcellus Awareness Committee. After an hour, the room of 60 or so participants dove into the lively de- and re-construction of large format maps of the area. They were invited to markup the maps, created by Carnegie Mellon University graduate student of the School of Architecture, Sophie Riedel. Each table worked from a different base map of the same area – centering on the confluence of the Ohio and Beaver rivers, including the already heavily-industrialized riverside and the site of Shell’s proposed petrochemical facility.

Massive shell processing plant under construction in Beaver County PA and across the Ohio River from the town of Beaver. This massive processing plant, near residential areas, schools and hospitals, will be a serious threat to the health of the those living in the region.

Figure 2: The site of the proposed petrochemical facility in Beaver County (on left) and the Ohio River that participants hope to see reinvented as a recreational waterway buttressed by public parks. Photo credit: Garth Lenz, iLCP.

Much more than a thought exercise, the gathering represented a timely response to a growing grassroots effort around the proposed petrochemical inundation. Changes are already underway at the site, and those who live in this region have the right to give input. This right is especially salient when considering the risks associated with the petrochemical industry – including detrimental health impacts on babies before they are even born, asthma exacerbation, and increased cancer rates.

Charting a new vision

The re-invented Beaver County would be one of increased connectivity and mobility, well-equipped to provide for local needs with local means.

Many ideas included on the maps reflected a longing for transportation options independent of personal vehicles – including better, safer, more connected bike trails and walking paths, use of existing rail lines for local travel, and even the inventive suggestion of a water taxi. These inherently lower-impact means of transport coincide with preferences of millennials, according to several of the panelists, who want more walkable, bikeable communities. Ushering in such sustainable suggestions would welcome more young families to an area with an aging population. More than just about moving people, transportation ideas also included ways to get locally grown foods to those who need it, such as the elderly.

Figure 3: Participants modify maps to reflect a new vision. Photo credit: Sophie Riedel.

The value of beauty was a subtheme in many of the ideas to connect and mobilize the population and goods, ideas which often held a dual aim of protecting open space, creating new parks, and offering recreation possibilities. Participants ambitiously reimagined their river, the Ohio, from its current status as a closed-off corridor for industrial usage and waste, to a recreational resource for kayaking and fishing walleye.

Participants marked up the maps to show the resources that help sustain this community, and voiced a strong desire for development that would enable additional self-reliance. These forward-thinking changes included increased agriculture and use of permaculture techniques, and community gardens for growing food near the people who currently lack access. Ideas for powering the region abounded, like harnessing wind power and putting solar panels on every new building.

Participants were firm on local sourcing for another key resource: the labor required for these efforts, they insisted, must come from the local populace. Educational programs designed to channel learners into workers for sustainability might include training to rebuild homes to “greener” standards, and programs aimed at bringing a new generation of farmers to the fields. Perhaps a nod to the world-wide plastic glut that a petrochemical facility would add to, suggestions even included local ways of dealing with waste, like starting a composting program and establishing more recycling centers.

Whose vision?

Who is a part of this vision, both in creating it and living it out? Inevitably, the selection of panelists and the interests of the audience members themselves influenced the vision this group crafted. The question of inclusion and representation found articulation among many participants, and the hosts of the event welcomed suggestions on reaching a broader audience moving forward. Looking around the room, one man asked, “Where are all the young people, and families with kids?” Indeed, only several members of this demographic were present. Though indicative of the racial makeup of Beaver County, the audience appeared to be primarily white, meaning that the racially diverse communities in the region where not represented. Others pointed out that going forward, the audience should also include those residents struggling with un- and underemployment, who have a major stake in whatever vision of Beaver County comes to fruition. Another said he would like to see more elected officials and leaders present. Notably, Potter Township Board of Supervisors Chairperson, Rebecca Matsco, who is a strong advocate for the proposed petrochemical project in her township, was present for the first half of the event.

Local means for meeting local needs

People who welcome petrochemical development in Beaver County might believe that those who voice concerns about the proposed Shell plant aren’t forward-thinking, or simply oppose change. Quite in contrast, participants at Re-Imagine Beaver County went to work reinventing their community with optimism and enthusiasm. They didn’t seem to be resisting change, but instead, wanting to participate in the process of change and to ultimately see benefits to their community. For example, discussion of solar power generated substantial excitement. According to panel speaker Hal Saville, however, the biggest challenge is making it affordable for everyone, which suggests that the estimated $1.6 billion in tax breaks going to Shell for the petrochemical plant could be better allocated.

A key narrative from supporters of the ethane cracker centers on the pressing need for jobs in this area, though some locals have expressed concern about how many of Shell’s promised jobs would go to residents. Whoever gets hired, these jobs come with serious dangers to workers. Participants at this event proposed alternative initiatives – both ambitious and small – for creating jobs within the community, like providing “sprout funds” to encourage new business start-ups, and launching a coordinated effort to rehab aging housing stock. These ideas suggest that the people of this region feel their energy and ingenuity would be best spent making Beaver County a better place to live and work, in contrast to producing disposable petrochemical products for export around the world. The fact that so many participants emphasized local means for meeting their needs in no way downplays the need for good jobs. Rather, it points to the fact that people want jobs that are good for them and for the future of their community.

Moving the vision forward

Where do we go from here? Can the momentum of this event draw in greater representation from the region to have a voice in this process? Will these visions become animated and guide the creation of a new reality? Broader and deeper planning is in order; participants and panelists alike pointed to tools like comprehensive community plans and cleaner, “greener” industrial policies. More than anything, the group articulated a need for more deliberation and participation. As panelist and farm co-owner Don Kretschmann put it, when it comes to change, we need to “think it through before we go ahead and do it.”

The maps themselves, bearing the inspirations scrawled out during the event, have not reached the end of the road. From here, these maps will accompany an upcoming exhibition of the artworks in Petrochemical America, which locals hope to bring to the greater Pittsburgh area in the coming months. League of Women Voters, for their part, continue to move the vision forward, inviting input from all on next steps, with an emphasis on pulling in a broader cross-section of the community.

To voice your vision, and to stay in the loop on future Re-Imagine Beaver County events, contact reimaginelwvpa@gmail.com.

Many thanks to Sophie Riedel for sharing photographs from the event, and to the International League of Conservation Photographers and the Environmental Integrity Project for sharing the aerial photograph of the Shell site from their joint project, “The Human Cost of Energy Production.”

By Leann Leiter, Environmental Health Fellow

34 states with active drilling activity in US map

34 states have active oil & gas activity in U.S. based on 2016 analysis

March 23, 2017/by FracTracker Alliance

Each year, FracTracker Alliance compiles a national well file to try to assess how many wells have been drilled in the U.S. We do this by extracting data from the various state regulatory agencies that oversee drilling in oil and gas producing states. We’re a little late posting the results of our 2016 analysis, but here it is.

Based on data from 2014-2015, 34 states * saw drilling activity, amounting to approximately 1.2 million facilities across the U.S. – from active production wells, to natural gas compressor stations, to processing plants.

The process we used to count these wells and related facilities for the 2016 analysis changed a bit this time around, which obviously impacts the total number of wells in the dataset. 2016’s compilation was created in consultation with Earthworks, for the purpose of informing the Oil and Gas Threat Map project. The scope was more restrictive than previous editions (see our 2014 and 2015 analyses), focusing only on wells that we were reasonably confident were actively producing oil and gas wells, thus excluding wells with inactive or uncertain statuses, as well salt water disposal (SWD) and other Class II injection (INJ) well types.

There are facilities included in this dataset that we don’t normally tally, as well (See Table 1 below). Earthworks was able to determine the latitude and longitude coordinates of a number of compressors and other processing plants, which are included in the dataset below and final map.

In all, the facility counts are reduced from about 1.7 million in 2015 to about 1.2 million in 2016, but this is more a reflection of the definition than substantial changes in the active well inventory in the U.S. You can explore this information by state, and additional results of this project, using Earthworks’ Threats Maps. Additionally, the national well file is available to download below.

Download 2016 National Well File Data

* The zip file separates out TX wells from the rest of the states due to the significant number of TX facilities.

You’ll notice that we don’t refer to the wells in this analysis as “fracked” wells. The primary reason for not using such terminology is because no one common definition exists across those states for what constitutes a hydraulically fractured well. In PA, for example, such wells are considered “unconventional” because drilling occurs in an unconventional formation and usually involves some sort of well stimulation. Contrastingly, in CA, often drillers use “acidizing” not fracking – a similar process that breaks up the ground using acidic injected fluids instead of the high pressure seen in traditional fracking. As such, we included all active oil and gas production instead of trying to limit the analysis to just wells that have been stimulated. We will likely continue to use this process until a federal or national definition of what constitutes a “fracked” well is determined.

Table 1. Facilities by State and Type

State	Count of Facilities by Type			Grand Total
State	Compressor	Processor	Well	Grand Total
AK		7	3,356	3,363
AL		17	7,016	7,033
AR	231	8	13,789	14,028
AZ			40	40
CA	7	21	92,737	92,765
CO	426	49	50,881	51,356
FL		2	102	104
ID			6	6
IL		5	48,748	48,753
IN			7,374	7,374
KS		9	90,526	90,535
KY		5	11,769	11,774
LA	6,486	94	2,555	9,135
MI		19	16,525	16,544
MO		2	687	689
MS		6	4,556	4,562
MT		5	9,768	9,773
ND		19	13,024	13,043
NE		1	16,202	16,203
NM	902	37	57,839	58,778
NV			176	176
NY			12,244	12,244
OH	29	10	90,288	90,327
OK	856	96	29,042	29,994
OR			56	56
PA	452	11	103,680	104,143
SD			408	408
TN			15,956	15,956
TX	758	315	397,776	398,849
UT		18	20,608	20,626
VA			9,888	9,888
WI		1		1
WV		20	16,118	16,138
WY	325	48	38,538	38,911
Grand Total	10,472	825	1,182,278	1,193,575
* NC facilities are not included because the state did not respond to multiple requests for the data. This exclusion likely does not significantly affect the total number of wells in the table, as historically NC only had 2 oil and gas wells.

For schools and hospitals analysis, 2017

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

March 13, 2017/by Ted Auch, PhD

A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

	Utica		Class II Injection
Well Distance (Miles)	Schools	Medical Facilities	Schools	Medical Facilities
0.5	3	1	9	0
0.5-1	19 (22)	9 (10)	16 (25)	13 (13)
1-2	79 (101)	41 (51)	88 (113)	79 (92)
2-3	84 (185)	49 (100)	165 (278)	122 (214)
3-4	85 (270)	79 (179)	168 (446)	112 (326)
4-5	92 (362)	63 (242)	196 (642)	166 (492)
5-10	388 (750)	338 (580)	796 (1,438)	584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties^[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.

Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).

Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

	Utica			Class II Injection
Well Distance (Miles)	# Schools	# Students	Avg	# Schools	# Students	Avg
0.5	3	1,360	453	7	3,312	473
<1	21	7,910	377	19	7,984	420
<2	96	35,390	376	90	41,565	462
<3	169	67,713	401	215	104,752	487
<4	241	97,448	404	350	176,067	503
<5	317	137,911	435	505	254,406	504
<10	600	280,330	467	1,126	569,343	506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.

Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

	Utica			Class II Injection
Distance from Well (Miles)	# Schools	# Students	Avg	# Schools	# Students	Avg
0.5	.	.	.	1	.	.
<1	.	.	.	2	25	13
<2	2	22	11	9	186	21
<3	7	874	125	30	4,460	149
<4	12	1,912	159	45	6,303	140
<5	21	2,471	118	61	9,610	158
<10	60	6,727	112	135	20,836	154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools

View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.

Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

	Marcellus			Class II Injection
Distance from Well (Miles)	#	Sum	Avg	#	Sum	Avg
0.5	19	5,674	299	1	.	.
<1	52 (71)	16,992 (22,666)	319	5 (6)	1,544	257
<2	169 (240)	52,737 (75,403)	314	16 (22)	5,032 (6,576)	299
<3	133 (373)	36,112 (111,515)	299	18 (40)	6,132 (12,708)	318
<4	88 (461)	25,037 (136,552)	296	21 (61)	5,235 (17,943)	294
<5	56 (517)	15,685 (152,237)	295	26 (87)	8,913 (26,856)	309
<10	118 (635)	37,131 (189,368)	298	228 (315)	69,339 (96,195)	305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.

Conclusion

A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

their role in induced seismicity,
potential water and air quality issues, and
concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance