By Samantha Malone, MPH, CPH – DrPH Student in Environmental & Occupational Health; Communications Specialist for FracTracker.org

As natural gas drilling in the Marcellus Shale region of our country moves forward, people in many states are debating over the best ways to regulate the natural gas industry. I’m not going to get into the impact fee discussion in this piece, although it is an obvious point of contention that needs addressed in PA immediately. Rather, I’d like to propose a way to manage the permitting and future development of the companies operating in this field.

Pipeline Safety

There are 2.5 million miles of pipelines in the U.S., the majority of which are for gas transmission and distribution. A recent 4-part series by the Philadelphia Inquirer brought to light the real and potential dangers of the gas pipeline system, which is being expanded in PA to handle the Marcellus gas destined for the market. The biggest concern highlighted in these articles in my opinion is the lack of oversight anywhere in the process – especially when our regulatory officials cannot even locate the pipelines. (Specific geographic locations of pipelines are often held close to the chest due to the perception that this information poses a risk to national security and infrastructure.)

Pipelines do fail, as demonstrated by the toxic liquid spills map below. This graphic was created by the New York Times, who in a earlier article discussed the lack of human and fiscal resources available to the Pipeline and Hazardous Materials Safety Administration – noting that although the number of spills have declined, pipelines are still responsible for approximately 100 significant spills per year.

NEW YORK TIMES | Source: Department of Transportation, Pipeline and Hazardous Materials Safety Administration

If you’d like to be able to find where pipelines are located (approximately) in your county, visit the U.S. DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) website for Pipeline Safety Awareness. The site also provides you with data about pipeline incidents. In case you would rather not go diving through the raw data, below are some U.S. pipeline incident datasets and example maps from 2010 – Nov 2011 data that  Matt Kelso obtained from PHMSA:

• PHMSA Hazardous Liquids Pipeline Incidents: Dataset | Map
• PHMSA Gas Distribution Pipeline Incidents: Dataset | Map
• PHMSA Gas Transmission Pipeline Incidents: Dataset | Map

Violations in PA

Violations Jan-Sept 2011 PA (EHS violations in red)

Another concern about natural gas drilling is the risk of environmental health and safety incidents occurring throughout the rest of the drilling process.¹

The map to the left created using Data.FracTracker.org shows all of the violations that were issued to drillers from Jan-Sept. 2011 in Pennsylvania. The red dots are the violations that fall under the DEP’s loose category of Environmental Health and Safety (EHS).²

As you can see, EHS incidents do occur, but is that the whole story? Perhaps we should be asking ourselves, who exactly is responsible for these incidents – pipelines and the like? When you look more closely at the data the industry’s safety record becomes less monolithic than at first glance.

Focusing on the Bad Actors

The PR surrounding natural gas drilling is controversial at best. We have seen blanket statements about how safe – and dangerous – natural gas drilling and pipelines can be. We all must recognize that the answer lies somewhere in between. However, where is the perfect medium located, and how do we address the root of the problems that do arise?

One approach that is taken by some regulatory bodies such as OSHA is to focus on the bad actors. In two of his more recent posts, FracTracker’s Matt Kelso analyzed the ‘bad actors’ that exist within the violations issued in PA. While this is certainly not an easy or straightforward task, he was able to identify operators with the highest and lowest violations per well drilled, as well as trends between 2010 and 2011. Check out these analyses here: Part 1 |  Part 2.

Bad actors are not good for the industry’s PR or the Commonwealth’s residents. If the agencies responsible for issuing drilling permits quantitatively began to take violation trends into account, this would allow the safer drillers to continue operating, while limiting those with a less than appealing track record.

¹ One of the great changes made by the PA Department of Environmental Protection in the last 2 years has been the transfer from the paper record system for keeping track of the violations they issue to a digital version that allows people access to the comprehensive, raw data. This is certainly also something that should be on NY’s Department of Environmental Conservation radar prior to issuing its first permit for high volume hydraulic fracturing.

² EHS violations are a loose category because often times when we sift through the data we will find administrative oversights like paperwork mislabeled as EHS, and more serious spills and fires mislabeled as administrative.

Pavillion, WY

The Internet is alive today after the U.S. Environmental Protection Agency released a report that indicates hydraulic fracturing (used when drilling for natural gas in tight shale formations) can contaminate groundwater. Residents of Pavillion, WY have been complaining about the state of their groundwater for some time now. The draft EPA report lends credibility to their claims with the finding that chemicals associated with the process were found in some deep water aquifers in the area. And when you look at all of the evidence around this issue – outside of the EPA’s study – the results are even more ‘ground-breaking.’

Having said that, there are a few questions regarding the EPA report/research. No field study could ever account for all of the potential confounders and variables – especially given the amount of resources the EPA had at its disposal to conduct this work. However, some of the most significant questions that I would like to see answered before this draft is finalized include:

1. How representative is the data from the two monitoring wells in relation to residents’  drinking water wells?
2. Has the potential for surface contamination of the monitoring wells been ruled out?
3. Why weren’t the duplicate samples that were analyzed by separate labs also able to detect 2-BE?

These questions (and surely more) are exactly why this is only a draft report. According to the EPA, it will be available for a 45-day public comment period. A subsequent 30-day peer-review process will be led by a panel of independent scientists to ensure that the results that stay on the records are accurate.

Photo Credit: Salvation Army, Randall Thomas, Wilkes-Barre, PA

Pennsylvania is no stranger to water and flooding, as we receive between 38 and 45 inches of rain per year on average. Unfortunately, the storms that hit the region starting on August 27th were more than we could handle – to say the least. During this time Hurricane Irene and the remnants of Tropical Storm Lee burdened the eastern portion of the state with flooding at water levels that rivaled Hurricane Agnes (1972).

While most residents hit hardest by flooding focused on protecting their families, homes, and livelihoods, others throughout the Commonwealth were also concerned about the impact that rising water levels could have on natural gas well pads. This is especially an issue for those sites operating in floodplains with open frac ponds. According to the reports we have been able to gather no shale gas well sites were compromised or sustained environmental damage in PA.  Apparently, Marcellus Shale drillers were advised to prevent overflows from wastewater/’frac’ ponds by the governor, although due to a communication loophole it is unclear as to whether all of the relevant sites temporarily shut down during the inclement weather. Regardless, with the number of wells being drilled in PA especially in the northeast, being able to prevent any incidents during these storms is quite a feat on the part of the drillers and should be recognized as such. Industry reports also indicate that drilling companies provided financial contributions, expertise, equipment, work hours, and supplies to aid in the flood relief efforts. Learn more about these contributions here.

We ask that if you have any knowledge that contradicts this information, please let us know and contact your local representative to report the incident.