Piecing together the ethane cracker - Graphic by Sophie Riedel

Piecing Together an Ethane Cracker

May 31, 2017/by FracTracker Alliance

How fragmented approvals and infrastructure favor petrochemical development

By Leann Leiter and Lisa Graves-Marcucci

Let’s think back to 2009, when oil and gas companies like Range Resources began drilling the northeast shale plays in earnest. Picture the various stages involved in drilling – such as leasing of land, clearing of trees, boring of wells, siting of compressor stations, and construction of pipelines to gather the gas. Envision the geographic scope of the gas infrastructure, with thousands of wells in Pennsylvania alone, and thousands of miles of pipelines stretching as far as Louisiana.

Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter

Now, picture the present, where a homeowner looks out over her yard and wonders how a lease she signed with Shell several years prior made it possible for the company to run an ethane pipeline across her property and between her house and her garage.

Think forward in time, to 2022, the year when a world-scale ethane cracker is set to go online in Beaver County, Pennsylvania, to begin churning through natural gas liquids from wells in PA and others, producing a variety of disposable plastic products.

At each of these moments in gas development, which of the many stakeholders – industry leaders, local governments, state regulatory agencies, or landowners and residents – were granted a view of the full picture?

The proposed Shell ethane cracker in Beaver County is an illustration of the fragmented nature of gas development. From the extensive web of drilling infrastructure required to supply this massive facility, to several years of construction, this project is a case-study in piecemeal permitting. Such fragmentation creates a serious barrier to transparency and to the informed decision-making that relies upon it.

In the first two articles in this series on the petrochemical development in Beaver County, we focused on ethane cracker emergency scenarios and how the area might prepare. In this article, we draw the lens back to take in the larger picture of this region-altering project and highlight the effects of limited transparency.

The “Piecemeal” Nature of Gas Development

All across the Pennsylvania, proposed industrial development – even coal operations – have historically provided to the public, elected officials, and regulatory agencies the extent or footprint of their planned operations. Nonetheless, the oil and gas industry has in several instances undertaken a practice of developing its extensive infrastructure piece-by-piece. Operators of these facilities first acquire a GP-5 General Permit, which is only available to certain oil and gas operations with “minor” emissions and which allows them to avoid having the permit undergo public notice or comment. These operators then add emissions sources and increases through a series of minor amendments. While they are required to obtain a “major” source permit once their modifications result in major emissions, they avoid the scrutiny required for a major source by this fragmented process.

Unlike most other industrial permitting, the gas industry has enjoyed a much less transparent process. Instead of presenting their entire planned operation at the time of initial permit application, gas operators having been seeking – and receiving – incremental permits in a piecemeal fashion. This process puts local decision makers and the women, men, and children who live, work, and go to school near gas development at a severe disadvantage in the following ways:

Without full disclosure of the entirety of the planned project, neither regulatory bodies nor the public can conduct a full and factual assessment of land use impacts;
Incremental approvals allow for ever-expanding operations, including issuance of permits without additional public notification and participation;
Piecemeal approvals allow operations to continuously alter a community and its landscape;
The fragmented approval process prevents consideration of cumulative impacts; and
Without full transparency of key components of the proposed operations, emergency planning is hampered or non-existent.

From the Well to the Ethane Cracker

In the fragmented approval process of gas development, the proposed ethane cracker in Beaver County represents a pertinent example. Developers of this massive, multi-year, and many-stage project have only revealed the size and scope in a piecemeal fashion, quietly making inroads on the project (like securing land leases along the route of the pipeline required for the cracker, years in advance of permit approvals for the facility itself). By rolling out each piece over several years, the entirety of the petrochemical project only becomes clear in retrospect.

A World-Scale Petrochemical Hub

While Shell is still pursuing key approval from the PA Department of Environmental Protection, industry leaders treat the ethane cracker as a foregone conclusion, promising that this facility is but one step in turning the area into a “petrochemical hub.”

The cracker facility, alone, will push existing air pollution levels further beyond their already health-threatening state. Abundant vacant parcels around Shell’s cracker site are attractive sites for additional spin-off petrochemical facilities in the coming “new industry cluster.” These facilities would add their own risks to the equation, including yet-unknown chemical outputs emitted into the air and their resulting cumulative impacts. Likewise, disaster risks associated with the ethane cracker remain unclear, because in the piecemeal permitting process, the industry is not required to submit Preparedness, Prevention, and Contingency (PPC) Plans until after receiving approval to build.

Figure 2: Visualization shows a portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh's Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 "Annual Report of Natural Gas and Supplemental Gas Supply and Disposition," 2007.

Figure 2. A portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh’s Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.

92.3 Miles of Explosive Pipeline

More than just a major local expansion, communities downriver and downwind will be susceptible to the impacts, including major land disturbance, emissions, and the potential for “incidents,” including explosion. The pipeline required to feed the cracker with highly flammable, explosive ethane would tie the tri-state region into the equation, expanding the zone of risk into Ohio and crossing through West Virginia.

Figure 3. The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP

Renewed Demand at the Wellhead

No one piece of the gas infrastructure stands alone; all work in tandem. According to the Energy Information Administration (EIA), the new US ethane crackers will drive consumption of ethane up by a 26% by the end of 2018. Gas wells in the northeast already supply ethane; new ethane crackers in the region introduce a way to profit from this by-product of harvesting methane without piping it to the Gulf Coast. How this renewed demand for ethane will play out at fracked wells will be the result of complex variables, but it will undoubtedly continue to drive demand at Pennsylvania’s 10,000 existing unconventional oil and gas wells and those of other states, and may promote bringing new ones online.

Figure 4. Excerpt from Executive Summary of IHS Markit Report, “Prospects to Enhance Pennsylvania’s Opportunities in Petrochemical Manufacturing.”

Along with drilling comes a growing network of gathering and transmission lines, which add to the existing 88,000 miles of natural gas pipeline in Pennsylvania alone, fragment wildlife habitat, and put people at risk from leaks and explosions. Facilities along the supply stream that add their own pollution and risks include pump stations along the route and the three cryogenic facilities at the starting points of the Falcon Pipeline (see Fig. 6).

Figure 4: Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter.

Figure 5. Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter

The infrastructure investment required for ethane crackers in this region could reach $3.7 billion in processing facilities, pipelines for transmitting natural gas liquids including ethane, and storage facilities. A report commissioned by Team Pennsylvania and the PA Department of Community and Economic Development asserts that “the significant feedstock and transportation infrastructure required” will “exceed what is typically required for a similar facility” in the Gulf Coast petrochemical hub, indicating a scale of petrochemical development that rivals that of the southern states. This begs the question of how the health impacts in Pennsylvania will compare to those in the Gulf Coast’s “Cancer Alley.”

Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP

Water Impacts, from the Ohio River to the Arctic Ocean

Shell’s facility is only one of the ethane crackers proposed for the region that, once operational, would be permitted to discharge waste into the already-beleaguered Ohio River. This waterway, which traverses six separate states, supplies the drinking water for over 3 million people. Extending the potential water impact even further, the primary product of the Shell facility is plastics, whose inevitable disposal would unnecessarily add to the glut of plastic waste entering our oceans. Plastic is accumulating at the alarming rate of 3,500 pieces a day on one island in the South Pacific and as far away as the waters of the Arctic.

$Figure 7: View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.$

Figure 7. View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.

How does fragmentation favor industry?

The gas and petrochemical industry would likely defend the logistical flexibility the piecemeal process affords them, allowing them to tackle projects, make investments, and involve new players as needed overtime. But in what other ways do the incredibly fragmented approval processes, and the limited requirements on transparency, favor companies like Shell and their region-changing petrochemical projects? And what effect does the absence of full transparency have on local communities like those in Beaver County? We conclude that it:

“Divides and conquers” the region. The piecemeal approach to gas development, and major projects like the Shell ethane cracker, deny any sense of solidarity between the people along the pipeline route resisting these potentially explosive channels cutting through their yards, and residents of Beaver County who fear the cracker’s emissions that will surround their homes.
Makes the project seem a foregone conclusion, putting pressure on others to approve. For example, before Shell formally announced its intention to build the facility in Potter Township, it rerouted a state-owned road to facilitate construction and increased traffic flow. Likewise, though a key permit is still outstanding with the PA DEP, first responders, including local volunteer firefighters, have already begun dedicating their uncompensated time to training with Shell. While this is a positive step from a preparedness standpoint, it is one of many displays of confidence by Shell that the cracker is a done deal.
Puts major decisions in the hands of those with limited resources to carry them out and who do not represent the region to be affected. In the case of the Shell ethane cracker, three township supervisors in Potter Township granted approvals for the project. The impacts, however, extend well beyond Potter or even Beaver county and include major air impacts for Allegheny County and the Pittsburgh area. Effects will also be felt by landowners and residents in numerous counties and two states along the pipeline route, those near cryogenic facilities in Ohio and Pennsylvania, plus those living on the Marcellus and Utica shale plays who will see gas well production continue and potentially increase.

Figures 8a and 8b. Potter Township Supervisors give the go-ahead to draft approval of Shell’s proposed ethane cracker at a January meeting, while confronted with public concern about deficiencies in Shell’s permit applications. Photos courtesy of the Air Quality Collaborative.

Fragmented Transparency, Compromised Decision-making

The piecemeal, incremental, and fragmented approval processes for the ethane cracker – and other gas-related facilities in the making – create one major problem. They make it nearly impossible for locals, elected officials, and regulatory agencies to see the whole picture as they make decisions. The bit-by-bit approach to gas development amounts to far-reaching development with irreversible impacts to environmental and human health.

We ask readers, as they contemplate the impacts closest to them – be it a fracked well, a hazardous cryogenic facility, the heavily polluted Ohio River, a swath of land taken up for the pipeline’s right-of-way, or Shell’s ethane cracker itself – to insist that they, their elected officials, and regulators have access to the whole picture before approvals are granted. It’s hard to do with a project so enormous and far-reaching, but essential because the picture includes so many of us.

Sincere Appreciation

To The International League of Conservation Photographers, The Ohio Environmental Council, and The Air Quality Collaborative for sharing photographs.

To Sophie Riedel for sharing her visualizations of natural gas interstate pipelines.

To Lisa Hallowell at the Environmental Integrity Project, and Samantha Rubright and Kirk Jalbert at FracTracker, for their review of and and invaluable contributions to this series.

Feature image: Map of US counties and natural gas interstate pipeline system describes the wide-diameter (20-42 inch), high capacity trunklines that carry most of the natural gas that is transported throughout the nation. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.

Wayne National Forest Could Be Deforested – Again

May 24, 2017/by Guest Author

Guest article by Becca Pollard

Eighty years ago, Southeastern Ohio was a wasteland of barren, eroding hills. During the 18th and 19th centuries this once heavily forested area in the Appalachian foothills had been clear cut and mined beyond recognition. When the Great Depression struck, lowering crop prices made farming unprofitable in the area, and 40% of the population moved away.

In 1933, President Franklin Delano Roosevelt established the Civilian Conservation Corps (CCC), a public work relief program that employed men aged 18-25 to do manual labor related to conservation and development of natural resources such as planting trees, constructing trails, roads, and lodges, fighting wildfires, and controlling erosion. The following year, Ohio’s legislature agreed to allow the federal government to purchase land in the state for the purpose of establishing a national forest. The Forest Service was tasked with restoring the land for what is now called Wayne National Forest (WNF). A tree nursery was established near Chillicothe, and with the help of the CCC and volunteers, including members of the Daughters of the American Revolution, garden clubs, and school children, reforestation began.

Photos Credit: US Forest Service

An Area on the Mend

Today, WNF comprises three units that span 12 Ohio counties in the Unglaciated Allegheny Plateau. The hills are covered in biologically diverse mixed mesophytic forest, which includes approximately 120 species of trees and provides habitat for at least 45 species of mammals, 158 species of birds, 28 species of reptiles, 29 species of amphibians, and 87 species of fish. The US Forest Service estimates that 240,000 people visit this ecological wonder annually, according to Forest Recreation Program Manager, Chad Wilberger, in Nelsonville, Ohio. The restoration of barren public land to its current state is a great achievement. If it continues to be protected, Wayne could one day resemble the old growth forest that thrived here before the arrival of European settlers.

The Bureau of Land Management (BLM), however, has recently decided to lease up to 40,000 acres of Wayne to gas and oil companies for horizontal hydraulic fracturing, or fracking. The first auction took place last December resulting in the lease of 700 acres. A second auction this March leased another 1,200 acres. Nearly all of this land lies within the 60,000 acre Marietta Unit of the forest. This brings Oil & Gas Expressions of Interest (EOI) acreage to roughly 7.5% of all WNF owned parcels in this unit.

Wayne National Forest and Adjacent Existing Oil and Gas Infrastructure
Below is a map of the Wayne National Forest, along with parcels owned by WNF (shown in gray) and those that might be subject to unconventional oil and gas development (gray parcels outlined with dashes). We also include existing unconventional oil and gas infrastructure near the park. Explore the map below, or click here to view the map fullscreen.

View map fullscreen | How FracTracker maps work

Not new, not old

Gas and oil development is not new to the Wayne. Since the passage of The Federal Land Policy and Management Act of 1976, the US Forest Service’s land management plan for WNF has included conventional drilling, and derricks are a common sight on both public and private land in southeastern Ohio.

Fracking (unconventional drilling), however, has a far greater impact, requiring clear cutting of large areas of land for the construction of concrete well pads, and the use of millions of gallons of water that will become contaminated during the process and then transported by truck to injection wells. Accidents can be catastrophic for workers and nearby residents, and fracking and waste water disposal have been linked to earthquakes in Ohio.

In 2012, BLM updated its WNF Land and Resource Management Plan to allow fracking in the forest without conducting new impact studies.

What is at risk?

The Marietta Unit of the WNF is located in Monroe, Perry, and Washington counties in Southeastern Ohio along the Ohio River. Within its boundary are a wealth of trails used for hiking, backpacking, horseback riding, and mountain biking, campgrounds, and waterways ideal for kayaking and fishing. Both the highest and lowest points in the Wayne lie in this unit, as does the Irish Run Natural Bridge. The area is also known for its exceptional wildflowers, as shown in the photos below.

One popular recreation area, Lamping Homestead, lies directly within an oil and gas Expression Of Interest (EOI) parcel #3040602400 (See Map Above), one of the areas under consideration for lease. In the 1800s, it was the site of the Lamping family’s farm, but today all that remains of the settlers is a small cemetery with an iron gate atop a hill overlooking a small lake. Six campsites are situated around the western side of the lake, and two intersecting hiking loops rise into the wooded hills to the east. On the western side of the parking lot is a covered picnic area. A creek flows out of the lake and into Clear Fork, a tributary of the Little Muskingum River, across the road from the parking lot.

Both the lake and stream are popular boating and fishing areas. Lamping is an excellent spot for wildlife viewing. The lake, the creeks that flow in and out of it, and the surrounding wooded hills support an impressive variety of plant and animal species. During the day, visitors might spot ducks, geese, great blue herons, red-winged blackbirds, summer tanagers, red spotted newts, box turtles, northern water snakes, garter snakes, deer, rabbits, and muskrats. At night, they could be greeted by a cacophony of voices from frogs, owls, and coyotes.

Species of trees, plants, and fungus are also numerous. In winter, stands of white pine pop out against the bare branches of oak, hickory, maple, buckeye, and other deciduous trees. In spring, eye-catching splotches of blooming dogwood and redbud contrast against the many shades of green. But hikers who pull their gaze away from the brightly colored canopy and look down are rewarded with an abundance of wildflowers and the butterflies they attract, as well as many varieties of mushrooms and fungus, including such edible varieties as morels, wood ear, and dryad’s saddle.

Estimating Disturbances

It is unclear how much surface disturbance would occur on public land if this parcel were to be fracked, but even if the well pad and pipelines were constructed on private land adjacent to the forest, in order to drill under the forest, the public land and its inhabitants and visitors would certainly be impacted.

There is no question that noise and air pollution from traffic and construction would be disruptive both to wildlife and to human visitors. Explore various photos of the oil and gas industry in the gallery below:

The extraction process requires 2 million to 6 million gallons of fresh water each time a well is fracked. The rate at which hydraulic fracturing’s water demand is increasing on a per-well basis here in Ohio reached an exponential state around Q4-2013 and Q1-2014 and continues to rise at a rate of 3.1 million gallons per well per year (Figure 1).

Ohio Hydraulic Fracturing Total and Per Well Freshwater Demand between Q3-2010 and Q3-2016.

In Ohio, oil and gas companies are allowed to pull this water directly from streams and rivers at no cost. All this is possible, despite the fact that after its use it is so contaminated that it must be disposed of via injection wells and is permanently removed from the water cycle. The industry is already pulling water from streams in the Marietta Unit of the WNF for use in fracking on private land. Fracking public land simply means water withdrawals will occur on a much larger scale.

Ohio and West Virginia Shale Water Demand and Injection Waste Disposal
This map shows Utica wells weighted by water demand and disposal (and/or production). It also depicts water, sand, and chemical usage as well as injection waste and oil production. Explore the map below, or click here to view map fullscreen.

View map fullscreen | How FracTracker maps work

Inevitable methane leaks, in addition to contributing to climate change, affect humans and wildlife in their immediate vicinity, causing headaches and nausea and even killing trees and plants.

In addition to the anticipated harm that fracking inflicts upon a natural area, there is also a risk of accidents with potentially devastating consequences. Residents of Monroe County have already seen a few in recent years from fracking on private land. In 2014, a well pad fire in the village of Clarington resulted in a chemical spill that contaminated nearby Opossum Creek, killing 70,000 fish. The same year a large gas leak 15 miles south in the village of Sardis resulted in the evacuation of all homes within half mile radius.

Recent studies have shown that extraction wells, in addition to injection wells, can cause earthquakes. Unsurprisingly, Monroe County has seen a spike in seismic activity with the increase in fracking activity in the area. The most recent incident was a 3.0 magnitude earthquake in the forest less than five miles from Lamping Homestead in April of this year.

Supporters of Wayne National Forest

Many people have repeatedly spoken out against BLM’s plan, submitting a petition with more than 100,000 signatures, and protesting outside Wayne National Forest Headquarters and Athens Ranger Station in Nelsonville. They have even organized voters to call and write letters to Regional Forester Kathleen Atkinson and legislators, including Senators Sherrod Brown and Rob Portman, and Governor John Kasich. BLM has not budged on its decision, unfortunately, insisting that leasing this land for fracking, and associated infrastructure buildout, will have “no significant impact.”

This May, the Center for Biological Diversity, Ohio Environmental Council, Ohio Sierra Club, and Heartwood, a regional organization focused on protecting forests, filed a lawsuit against BLM, aiming to void BLM leases and halt all fracking operations within the national forest.

Concerned citizens continue to organize raise awareness as they await the outcome of the suit.

Becca Pollard is Freelance Journalist and Co-founder of Keep Wayne Wild

Data Downloads

Click on the links below to download the data used to create this article’s maps:

Underground Gas Storage map by Drew Michanowicz

Underground Gas Storage Wells – An Invisible Risk in the Natural Gas Supply Chain

May 23, 2017/by FracTracker Alliance

The largest accidental release of methane in U.S. history began October 23, 2015 with the blowout of an underground natural gas storage well in Aliso Canyon about 20 miles west of Los Angeles. By the time the well was plugged 112 days later, more than 5.0 billion cubic feet of methane and other pollutants had been released to the atmosphere. It was a disaster for the climate, the environment, California’s energy supply, and the more than 11,000 people that were forced to evacuate.

A new study from the Harvard T. H. Chan School of Public Health – Center for Health and the Global Environment shows that more than one in five of the almost 15,000 active underground gas storage (UGS) wells in the US could be vulnerable to serious leaks due to obsolete well designs – similar in design to the well that failed at the Aliso Canyon storage facility.

Published today in the journal Environmental Research Letters, the study presents a national baseline assessment of underground storage wells in the U.S. and indicates the need for a better understanding of the risks associated with the obsolescence of aging storage wells. The study also highlights the widespread nature of certain age-related risk factors, but indicates that some of the highest priority wells may be located in PA, OH, NY, and WV.

The study shows that the average construction year of largely unregulated active UGS wells in the US is 1963, with potentially obsolete wells that were not originally designed for storage operating in 160 facilities across 19 states. Some of the wells were constructed over 100 years ago – a time period that precedes many modern well containment systems such cement isolation and the use of multiple casings. Some of the oldest active UGS wells were not designed for two-way flow of gas, and therefore may not exhibit sufficient material-grade or redundant precautionary systems to prevent containment loss, as was evident at Aliso Canyon.

An Interview with the Author

Sam, Matt, and Kyle of FracTracker caught up with lead author and former FracTracker colleague, Dr. Drew Michanowicz, now with the Center for Health and Global Environment within the Harvard T. H. Chan School of Public Health to find out more about their study.

When we spoke with Drew, he began the interview by posing the first question to us:

Did you know that about 15% of the natural gas produced in the US is injected back into the ground each year?

While we had all heard of underground gas storage before, we had to admit that we never thought of the process like that before. In other words, some of the natural gas in the US is being produced twice from two different reservoirs before being consumed. And because many of these storage systems utilized depleted oil and gas reservoirs, many of the same pre- and post-conditioning processes, such as dehydrating and compressing, are necessary to bring the gas to market.

The following questions and answers from Drew expand upon the study’s findings:

Q: What prompted you and your colleagues to investigate this topic?

A: After the Aliso Canyon incident, we became interested in the question: ‘Is Aliso Canyon Unique?’ Interestingly, there were plenty of early warning signs at that facility that corrosion issues on very old repurposed wells were becoming a significant issue. Almost a year before the well blowout, Southern California gas went on record in front of California’s Public Utility Commission stating that they needed a rate increase to implement a necessary integrity management plan for their wells, and to be able to move beyond operating in a reactive mode. That unfortunately prophetic document really got us interested in better understanding why their infrastructure was in the state it was in. And like any major accident like this, a logical next step is to assess the prevalence of hazardous conditions elsewhere in the system, in the hope to prevent the next one.

From our research, it appears that a very large portion of the UGS sector may be facing similar obsolescence issues compared to Aliso, such as decades-old wells not originally designed for two-way flow. Our work here, however, is a simplified assessment that focused only on passive barriers or the fixed structures such as the steel pipes likely present in a well. Much more work is needed to fully understand the active-type safety measures in place such as safety valves, tubing/packers, and overall integrity management plans – all important factors for manage risks.

Q: We see that your team developed a well-level database of over 14,000 active UGS wells across 29 states. Because data-collation is a big part of our work here, can you describe that data collection process?

A: Very early on we also realized that underground gas storage was exempt from the Safe Drinking Water Act’s Underground Injection Control (UIC) program – similar to exemption with hydraulic fracturing and the Energy Policy Act of 2015, AKA the Halliburton Loophole. This meant in part that very little aggregate well data was available from the Federal Government or by third-party aggregators like FracTracker and DrillingInfo. Reminiscent of my former extreme data-paucity days at FracTracker, we knew we needed to build a database basically from scratch to effectively perform a hazard assessment that incorporated a spatial component.

We began by gathering what data we could from the U.S. Energy Information Administration (EIA), which gave us good detail at the field or facility level, but the fields were generalized to a county centroid. So to fully evaluate these infrastructure, we needed to figure out how to join the facility-level data to the well data for each state. We relied on NETL’s Energy Data eXchange to identify state-level wellbore data providers where applicable. Once we collected all of the state data, we created a decision-tree framework to join the individual wells to the EIA field names in order to produce a functional geodatabase. Because we had to manage data from so many sources, we had to devote quite a bit of effort to data QA/QC, and that is reflected in the methods and results of the paper. For example, some of our fields and wells had to be joined via visual inspection of company system maps, because of missing identifier information.

Q: We see that some of the oldest repurposed wells you mapped are located in PA, OH, NY, and WV. Was that a surprise to you?

A: That was a surprise considering this story started for us in California, and even more surprising was that some are more than 100 years old. Now, a bit of caution here is warranted when thinking about the age of any engineered system. On the one hand, something that functions for a very long time is an indication that the system was very well suited for its task, and likely has been very well taken care of – think of an antique automobile like a fully functional 1916 Model T Ford, for example. On the other hand, age and construction year relates to the integrity of an engineered system through two processes by:

providing information to how long a system has been exposed to natural degradation processes such as corrosion, and stresses from thermal and abrasive cycles; and by
proxying for knowledge and regulatory safety standards at the time of construction which informs the design, materials, technologies likely used.

To go back to the car example, while an old classic car may still be operational, it may not have certain safety features like antilock brakes, airbags, or safety belts, and generally will not be able to go as fast as a modern car. Therefore, a gas storage well’s integrity is at least indirectly related to its construction year when considering the multitude of technological and safety improvements have occurred over the years. This is how we have been thinking about well integrity from a 5,000 foot perspective. Needless to say, more research is needed to understand the causal effect of age on well integrity.

Q: So if we understand you correctly, these older wells can be maintained with sufficient management practices, but there may be inherent safety features missing on these older wells that don’t adhere to todays’ standards?

A: That’s right. So what we can say about some of these aging wells is that some will not reflect certain modern fail-safe engineering such as sufficient casing design strength and multiple casings or barriers along the full length. And these are permanent structural elements vestigial to the well’s original design, and therefore cannot be undone or redesigned away. In other words, it makes much more sense to drill a new well with new materials than attempt to significantly alter an old well. And the gas storage wells built today are designed with redundant fail-safe systems including multiple barriers and real-time pressure sensors.

But back to my earlier point about lack of federal regulations to set a minimum safety standard – because of that, there is also much uncertainty surrounding how many of these facilities have been dealing with safety and risk management. That is a future direction of this work – to really try to fill in some of regulatory gaps between states and the impending Federal guidelines and identify some best practices to help inform policy makers specifically at the state level.

Drew put together a map to highlight where some of these active storage wells are in PA, OH, NY, and WV:

This area map of PA, WV, OH, and NY displays where active underground natural gas storage operations are located. The small white points represent active storage wells that have a completion, SPUD, or permit date that occurs after the field was designated for storage indicating that these wells are more likely to have been designed for storage operations. The green points are active storage wells that predate storage operations, indicating that these wells may not have been designed for storage.

There are 121 storage fields connected to at least 6,624 active gas storage wells across these four states. A portion of wells in this region were not included in this final count because they did not contain sufficient status or date information. Pennsylvania has the most individual storage fields of any state with 47, while Ohio boasts the most active storage wells of any state in the country with 3,318 across its 22 active fields. Of the 6,624 active UGS wells across these four states, 1,753 predate storage designation indicating that these wells were likely not originally designed for storage. These ‘repurposed’ wells have a median age of 84 years, with 210 wells constructed over 100 years ago (red points). The 100 year cutoff is not arbitrary, as the year 1917 marks the advent of cement zonal isolation techniques, indicating that these wells may be of the highest priority in terms of design deficiencies related to well integrity, and they are primarily located across the four states pictured above.

Top Counties with Obsolete¹/Repurposed² Wells

Westmoreland, PA (86/93)
Ashland, OH (50/217)
Richland, OH (31/99)
Greene, PA (25/76)
Hocking, OH (18/99)

¹Obsolete wells are repurposed wells constructed before 1916
²Repurposed wells predate the storage facility

Read the Study

Additional Notes

The well that failed at Aliso Canyon was originally drilled in 1954 for oil production. In 1972, it was repurposed for underground gas storage, which entails both production and injection cycles in a single well. The problem seems to be that because it was not originally constructed to store natural gas, only a single steel pipe separated the flow of gas and the outside rock formation. That meant the well’s passive structural integrity was vulnerable to a single point-of-failure along a portion of its casing. When part of the subsurface well casing failed, there were no redundancies or safety valves in place to prevent or minimize the blow out.

More information related to the Aliso Canyon incident and this study is available here.
More info on the Center for Health and the Global Environment can be found here.

$Ethanol and fracking$

North American Ethanol’s Land, Water, Nutrient, and Waste Impact

May 22, 2017/by Ted Auch, PhD

Corn Ethanol and Fracking – Similarities Abound

Even though it is a biofuel and not a fossil fuel, in this post we discuss the ways in which the corn ethanol production industry is similar to the fracking industry. For those who may not be familiar, biofuel refers to a category of fuels derived directly from living matter. These may include:

Direct combustion of woody biomass and crop residues, which we recently mapped and outlined,
Ethanol¹ produced directly from the fermentation of sugarcanes or indirectly by way of the intermediate step of producing sugars from corn or switchgrass cellulose,
Biodiesel from oil crops such as soybeans, oil palm, jatropha, and canola or cooking oil waste,² and
Anaerobic methane digestion of natural gas from manures or human waste.

Speaking about biofuels in 2006, J. Hill et al. said:

To be a viable substitute for a fossil fuel, an alternative fuel should not only have superior environmental benefits over the fossil fuel it displaces, be economically competitive with it, and be producible in sufficient quantities to make a meaningful impact on energy demands, but it should also provide a net energy gain over the energy sources used to produce it.

Out of all available biofuels it is ethanol that accounts for a lion’s share of North American biofuel production (See US Renewables Map Below). This trend is largely because most Americans put the E-10 blends in their tanks (10% ethanol).³ Additionally, the Energy Independence and Security Act of 2007 calls for ethanol production to reach 36 billion gallons by 2022, which would essentially double the current capacity (17.9 billion gallons) and require the equivalent of an additional 260 refineries to come online by then (Table 1, bottom).

US Facilities Generating Energy from Biomass and Waste along with Ethanol Refineries and Wind Farms

View map fullscreen | How FracTracker maps work

But more to the point… the language, tax regimes, and potential costs of both ethanol production and fracking are remarkably similar. (As evidenced by the quotes scattered throughout this piece.) Interestingly, some of the similarities are due to the fact that “Big Ag” and “Big Oil” are coupled, growing more so every year:

The shale revolution has resulted in declining natural gas and oil prices, which benefit farms with the greatest diesel, gasoline, and natural gas shares of total expenses, such as rice, cotton, and wheat farms. However, domestic fertilizer prices have not substantially fallen despite the large decrease in the U.S. natural gas price (natural gas accounts for about 75-85 percent of fertilizer production costs). This is due to the relatively high cost of shipping natural gas, which has resulted in regionalized natural gas markets, as compared with the more globalized fertilizer market. (USDA, 2016)

Ethanol’s Recent History

For background, below is a timeline of important events and publications related to ethanol regulation in the U.S. in the last four decades:

Energy Research Advisory Board (ERAB) 1980, Gasohol
ERAB, 1981, “Biomass Energy”
Office of Energy, 1986, Fuel Ethanol and Agriculture: An Economic Assessment
Clean Air Act 1990 Amendments (1990 CAAA) ethanol Reid Vapor Pressure (RVP) exceptions
Congressional Research Service, 1994, Alcohol Fuels Tax Incentives and EPA’s Renewable Oxygenate Requirement
The Biomass Research and Development Act of 2000 (Title III of the Agricultural Risk Protection Act)
US Department of Energy (DOE), 2002, “Roadmap for biomass technologies in the United States. Biomass Technical Advisory Committee”, Found here and here
USDA, 2002, Ethanol Cost-of-Production Survey
US Natural Resources Conservation Service (NRCS), 2003, Crop residue removal for biomass energy production: Effects on soils and recommendations
US Department of Energy, 2003, Biomass program multi-year technical plan
The Renewable Fuel Standard (RFS) program is implemented as part of the Energy Policy Act of 2005 and extended in the Energy Independence and Security Act of 2007
US DOE, 2005, Energy Efficiency and Renewable Energy
US Energy Independence and Security Act, 2007
USDA, 2007, U.S. Ethanol Expansion Driving Changes Throughout the Agricultural Sector
USDA, 2007, Growing global demands for soy for edible oil, livestock feed, and biodiesel are also contributing to high soy prices (no file found on USDA site anymore)
Special Report of the Intergovernmental Panel on Climate Change (IPCC), 2011, Renewable Energy Sources and Climate Change Mitigation
2014 Farm Bill authorized the “Biomass Crop Assistance Porgram” (aka, The 2014 Agricultural Act)

Benefits of Biofuels

[Bill] Clinton justified the ethanol mandate by declaring that it would provide “thousands of new jobs for the future” and that “this policy is good for our environment, our public health, and our nation’s farmers—and that’s good for America.” EPA administrator Carol Browner claimed that “it is important to our efforts to diversify energy resources and promote energy independence.” – James Bovard citing Peter Stone’s “The Big Harvest,” National Journal, July 30, 1994.

Of the 270 ethanol refineries we had sufficient data for, we estimate these facilities employ 235,624 people or 873 per facility and payout roughly $6.18-6.80 billion in wages each year, at an average of $22.9-25.2 million per refinery. These employees spend roughly 423,000 hours at the plant or at associated operations earning between $14.63 and $16.10 per hour including benefits. Those figures amount to 74-83% of the average US income. In all fairness, these wages are 13-26% times higher than the farming, fishing, and forestry sectors in states like Minnesota, Nebraska, and Iowa, which alone account for 33% of US ethanol refining.

Additional benefits of ethanol refineries include the nearly 179 million tons of CO₂ left in the field as stover each year, which amounts to 654,532 tons per refinery. Put another way – these amounts are equivalent to the annual emissions of 10.7 million and 39,194 Americans, respectively.

Finally, what would a discussion of ethanol refineries be without an estimate of how much gasoline is produced? It turns out that the 280 refineries (for which we have accurate estimates of capacity) produce an average of 71.93 million gallons per year and 20.1 billion gallons in total. That figure represents 14.3% of US gasoline demand.

Costs of Biofuels

Direct Costs

Biofuel expansions such as those listed in the timeline above and those eluded to by the likes of the IPCC have several issues associated with them. One of which is what Pimentel et al. considered an insufficient – and to those of us in the fracking NGO community, familiar sounding – “breadth of relevant expertise and perspectives… to pronounce fairly and roundely on this many-sided issue.”

The above acts and reports in the timeline prompted many American farmers to double down on corn at the expense of soybeans, which caused Indirect Land Use Change (ILUC); the global soy market skyrocketed. This, in turn, prompted the clearing and/or burning of large swaths of the Amazonian rainforests and tropical savannas in Brazil, the world’s second-leading soy producer. More recently, large swaths of Indonesia and Malaysia’s equally biodiverse peatland forests have been replaced by palm oil plantations (Table 2 and Figure 3, bottom). In the latter countries, forest displacement is increasing by 2.7-5.3% per year, which is roughly equal to the the rate of land-use change associated with hydraulic fracturing here in the US⁴ (Figure 1).

Figures 1A and 1B. Palm Oil Production in A) Indonesia and B) Malaysia between 1960 and 2016.

There is an increasing amount of connectivity between disparate regions of the world with respect to energy consumption, extraction, and generation. These connections also affect how we define renewable or sustainable:

In a globalized world, the impacts of local decisions about crop preferences can have far reaching implications. As illustrated by an apparent “corn connection” to Amazonian deforestation, the environmental benefits of corn-based biofuel might be considerably reduced when its full and indirect costs are considered. (Science, 2007)

These authors pointed to the fact that biofuel expectations and/or mandates fail to account for costs associated with atmospheric – and leaching – emissions of carbon, nitrogen, phophorus, etc. during the conversion of lands, including diverse rainforests, peatlands, savannas, and grasslands, to monocultures. Also overlooked were:

The ethical concerns associated with growing malnourishment from India to the United States,
The fact that 10-60%⁵ more fossil fuel derived energy is required to produce a unit of corn ethanol than is actually contained within this very biofuel, and
The tremendous “Global land and water grabbing” occuring in the name of natural resource security, commodification, and biofuel generation.

Sacrificing long-term ecological/food security in the name of short-term energy security has caused individuals and governments to focus on taking land out of food production and putting it into biofuels.

The rationale for ethanol subsidies has continually changed to meet shifting political winds. In the late 1970s ethanol was championed as a way to achieve energy independence. In the early 1980s ethanol was portrayed as salvation for struggling corn farmers. From the mid and late 1980s onward, ethanol has been justified as saving the environment. However, none of those claims can withstand serious examination. (James Bovard, 1995)

This is instead of going the more environmentally friendly route of growing biofuel feedstocks on degraded or abandoned lands. An example of such an endeavor is the voluntary US Conservation Reserve Program (CRP), which has stabilized at roughly 45-57 thousand square miles of enrolled land since 1990, even though the average payout per acre has continued to climb (Figure 2).

Figure 2. The Average Subsidy to Farmers Per Acre of Conservation Reserve Program (CRP) between 1986 and 2015.

The primary goals of the CRP program are to provide an acceptable “floor” for commodity prices, reduce soil erosion, enhance wildlife habitat, ecosystem services, biodiversity, and improve water quality on highly erodible, degraded, or flood proned croplands. Interestingly CRP acreage has declined by 27% since a high of 56 thousand square miles prior to the Energy Independence and Security Act of 2007 being passed. Researchers have pointed to the fact that corn ethanol production on CRP lands would create a carbon debt that would take 48 years to repay vs. a 93 year payback period for ethanol on Central US Grasslands.

To quote Fred Magdoff in The Political Economy and Ecology of Biofuels:

Alternative fuel sources are attractive because they can be developed and used without questioning the very workings of the economic system — just substitute a more “sustainable,” “ecologically sound,” and “renewable” energy for the more polluting, expensive, and finite amounts of oil. People are hoping for magic bullets to “solve” the problem so that capitalist societies can continue along their wasteful growth and consumption patterns with the least disruption. Although prices of fuels may come down somewhat — with dips in the business cycle, higher rates of production, or a burst in the speculative bubble in the futures market for oil — they will most likely remain at historically high levels as the reserves of easily recovered fuel relative to annual usage continues to decline.

Indirect Costs: Ethanol, Fertilizers, and the Gulf of Mexico Dead Zone

This is the Midwest vs. the Middle East. It’s corn farmers vs. the oil companies. – Dwaney Andreas in Big Stink on the Farm by David Greising

Sixty-nine percent⁶ of North America’s ethanol refineries are within the Mississippi River Basin (MRB). These refineries collectively rely on corn that receives 1.9-5.1 million tons of nitrogen each year, with a current value of $1.06-2.91 billion dollars or 9,570-26,161 tons of nitrogen per refinery per year (i.e. $5.42-14.81 million per refinery per year). These figures account for 27-73% of all nitrogen fertilizer used in the MRB each year. More importantly, the corn acreage receiving this nitrogen leaches roughly 0.81-657 thousand tons of it directly into the MRB. Such a process amounts to 5-44% of all nitrogen discharged into the Gulf of Mexico each year and 1.7-13.8 million tons of algae responsible for the Gulf’s growing Dead Zone.

Leaching of this nitrogen is analogous to flushing $45.7-371.6 million dollars worth of precious capital down the drain. Put another way, these dollar figures translate into anywhere between 55% and an astonishing 4.53 times Direct Costs to the Gulf’s seafood and tourism industries of the Dead Zone itself.

These same refineries rely on corn acreage that also receives 0.53-2.61 million tons of phosphorus each year with a current value of 0.34-1.66 billion dollars. Each refinery has a phosphrous footprint in the range of 2,700 to 13,334 tons per year (i.e., $1.72-8.47 million). We estimate that 25,399-185,201 tons of this fertilizer phosphorus is leached into the the MRB, which is equivalent to 19% or as much as 1.42 times all the phosphorous dischared into the Gulf of Mexico per year. Such a process means $16.13-117.60 million is lost per year.

Together, the nitrogen and phosphorus leached from acreage allocated to corn ethanol have a current value that is between 75% and nearly 6 times the value lost every year to the Gulf’s seafood and tourism industries.

Indirect Costs: Fertilizer and Herbicide Costs and Leaching

The 270 ethanol refineries we have quality production data for are relying on corn that receives 367,772 tons of herbicide and insecticide each year, with a current value of $6.67 billion dollars or 1,362 tons of chemical preventitive per refinery per year (i.e. $24.7 million per refinery per year). More importantly the corn acreage receiving these inputs leaches roughly 15.8-128.7 thousand tons of it directly into surrounding watersheds and underlying aquifers. Leaching of these inputs is analogous to flushing $287 million to $2.3 billion dollars down the drain.

What’s Next?

During the recent Trump administration EPA, USDA, DOE administrator hearings, the Renewable Fuel Standard (RFS) was cited as critical to American energy independence by a bipartisan group of 23 senators. Among these were Democratic senator Amy Klobuchar and Republican Chuck Grassley, who co-wrote a letter to new EPA administrator Scott Pruitt demanding that the RFS remains robust and expands when possible. In the words of Democratic Senator Heidi Heitkamp – and long-time ethanol supporter – straight from the heart of the Bakken Shale Revolution in North Dakota:

The RFS has worked well for North Dakota farmers, and I’m fighting to defend it. As we’re doing today in this letter, I’ll keep pushing in the U.S. Senate for the robust RFS [and Renewable Volume Obligations (RVOs)] we need to support a thriving biofuels industry and stand up for biofuels workers. Biofuels create good-paying jobs in North Dakota and help support our state’s farmers, who rely on this important market – particularly when commodity prices are challenging.

Furthermore, the entire Iowa congressional delegation including the aforementioned Sen. Grassley joined newly minted USDA Secretary Sonny Perdue when he told the Iowa Renewable Fuels Association:

You have nothing to worry about. Did you hear what he said during the campaign? Renewable energy, ethanol, is here to stay, and we’re going to work for new technologies to be more efficient.

How this advocacy will play out and how the ethanol industry will respond (i.e., increase productivity per refinery or expand the number of refineries) is anybody’s guess. However, it sounds like the same language, lobbying, and advertising will continue to be used by the Ethanol and Unconventional Oil and Gas industries. Additional parallels are sure to follow with specific respect to water, waste, and land-use.

Furthermore, as both industries continue their ramp up in research and development, we can expect to see productivity per laborer to continue on an exponential path. The response in DC – and statehouses across the upper Midwest and Great Plains – will likely be further deregulation, as well.

From a societal perspective, an increase in ethanol production/grain diversion away from people’s plates has lead to a chicken-and-egg positive feedback loop, whereby our farmers continue to increase total and per-acre corn production with less and less people. In rural areas, mining and agriculture have been the primary employment sectors. A further mechanization of both will likely amplify issues related to education, drug dependence, and flight to urban centers (Figures 4A and B).

We still don’t know exactly how efficient ethanol refineries are relative to Greenhouse Gas Emissions per barrel of oil. By merging the above data with facility-level CO₂ emissions from the EPA Facility Level Information on Greenhouse gases Tool (FLIGHT) database we were able to match nearly 200 of the US ethanol refineries with their respective GHG emissions levels back to 2010. These facilities emit roughly:

195,116 tons of CO₂ per year, per facility,
A total of 36.97 million tons per year (i.e., 2.11 million Americans worth of emissions), and
22,265 tons of CO₂ per barrel of ethanol produced.

Emissions from ethanol will increase to 74.35 million tons in 2022 if the Energy Independence and Security Act of 2007’s prescriptions run their course. Such an upward trend would be equivalent to the GHG emissions of somewhere between that of Seattle and Detroit.

What was once a singles match between Frackers and Sheikhs may turn into an Australian Doubles match with the Ethanol Lobby and Farm Bureau joining the fray. This ‘game’ will only further stress the food, energy, and water (FEW) nexus from California to the Great Lakes and northern Appalachia.

We are on a thinner margin of food security, just as we are on a thinner margin of oil security… The [World] Bank implicitly questions whether it is wise to divert half of the world’s increased output of maize and wheat over the next decade into biofuels to meet government “mandates.” – Ambrose Evans-Pritchard in The Telegraph

Will long-term agricultural security be sacrificed in the name of short-term energy independence?

Figure 3. US and Global Corn Production and Acreage between 1866 and 2015.

Figures 4A and 4B. A) Number of Laborers in the US Mining, Oil and Gas, Agriculture, Forestry, Fishing, and Hunting sector and B) US Corn Production Metrics Per Farm Laborer between 1947 and 2015.

Ethanol Tables

Table 1. Summary of our Corn Ethanol Production, Land-Use, and Water Demand analysis

Gallons of Corn Ethanol Produced Per Year	17,847,616,000
Bushels of Corn Needed	6,374,148,571
Percent of US Production	44.73%
Land Needed	104,372,023 acres
“”	163,081 square miles
Percent of Contiguous US Land	5.51%
Percent of US Agricultural Land	11.28%
Gallons of Water Needed	49.76 trillion (i.e. 3.55 million swimming pools)
Gallons of Water Per Gallon of Oil	2,788
Average and Total Site/Industry Capacity
Average Corn Ethanol Production Per Existing or Under Construction Facility (n = 257)	69,717,250
Gallons of Corn Ethanol Produced Per Year	17,847,616,000
Difference Between 2022 Energy Independence and Security Act of 2007 36 Billion Gallon Mandate	18,152,384,000
# of New Refineries Necessary to Get to 2022 Levels	260
Percent Increase Over Current Facility Inventory	1.7
IEA 2009 World Energy Outlook 250-620% Increase Predictions for 2030
250%	44,619,040,000
# of New Refineries Necessary	640
Percent Increase Over Current Facility Inventory	150.00
620%	110,655,219,200
# of New Refineries Necessary	1,587
Percent Increase Over Current Facility Inventory	520.00

Table 2. Global Population Growth and Corn and Soybean Productivity Trends.

Percent Change	Metric
+1.13%	Global Population Growth Trend
Corn (Bushels Per Acre)
+1.15% Per Year	United States
+1.20% Per Year	Global
Soybean (Tons Per Acre)
+0.9% Per Year	United States
+1.5% Per Year	Brazil
Palm Oil (Tons)
+5.1% Per Year	Indonesia
+2.7% Per Year	Malaysia

References and Footnotes

Ethanol as defined in the Ohio Revised Code (ORC) Corporation Franchise Tax 5733.46 means “fermentation ethyl alcohol derived from agricultural products, including potatoes, cereal, grains, cheese whey, and sugar beets; forest products; or other renewable resources, including residue and waste generated from the production, processing, and marketing of agricultural products, forest products, and other renewable resources that meet all of the specifications in the American society for testing and materials (ASTM) specification D 4806-88 and is denatured as specified in Parts 20 and 21 of Title 27 of the Code of Federal Regulations.”
A) Pyrolysis is included in the biofuel category and involves the anaerobic decay of cellulose rich feedstocks such as switchgrass at high temperatures producing synthetic diesel or syngas, and
B) According to many researchers biofuels made from waste biomass or crops grown on degraded and abandoned lands with warm-season prairie grasses and legumes incur little or no carbon debt and provide “immediate and sustained Greenhouse Gas (GHG) advantages” by rehabilitating soil health and capturing, rather than emitting by way of increased fertilizer use, various forms of nitrogen including N₂O, NO₃^–, and NO₂^–.
According to Fred Magdoff, the ethanol complex is lobbying for “more automobile engines capable of using E-85 (85 percent ethanol, 15 percent gasoline) for which there are currently 2,710 fueling stations across the country although 56% of them are in just nine states: 1) Wisconsin (117), 2) Missouri (107), 3) Minnesota (335), 4) Michigan (174), 5) Indiana (172), 6) Illinois (221), 7) Iowa (193), 8) Texas (99), and 9) Ohio (97). Some states are mandating a mixture greater than 10 percent. Ethanol can’t be shipped together with gasoline in pipelines because it separates from the mixture when moisture is present, so it must be trucked to where it will be mixed with gasoline.” The E-85 blend comes with its own costs including higher emissions of CO, VOC, PM10, SO_x, and NO_x than gasoline.
McClaugherty, C., Auch, W. Genshock, E. and H. Buzulencia. (2017). Landscape impacts of infrastructure associated with Utica shale oil and gas extraction in eastern Ohio, Ecological Society of America, 100^th Annual Meeting, Baltimore, MD, August, 2015.
Hill et al. recently indicated “Ethanol yields 25% more energy than the energy invested in its production, whereas biodiesel yields 93% more.”
An additional 9-10 refineries or 73% of all ethanol refineries are within 25 miles of the Mississippi River Basin.

By Ted Auch, PhD, Great Lakes Program Coordinator, FracTracker Alliance

Cover photo, left: Oil and gas well pad, Ohio. Photo by Ted Auch.
Cover photo, right: A typical ethanol plant in West Burlington, Iowa. Photo by Steven Vaughn.

Data Downloads

Click on the links below to download the datasets used to create the maps in this article.

FracTracker Mobile App Now Includes Activity Feed and Mapped Pipelines

May 18, 2017/by FracTracker Alliance

Explore and Document Drilling Activity Near You with the FracTracker App

The oil and gas industry – from its wells to pipelines to refineries – has a variety of ways of impacting the communities and environment that surround its infrastructure. Given the scope of the industry, it’s almost impossible to see how oil and gas affects people and for them to share their experiences with others. Until today. FracTracker is excited to announce that we have completely rebuilt and significantly improved our frack-tracking mobile app. This app can serve as a documenting and tracking tool for reporters, residents, researchers, and groups concerned about oil and gas and its impacts.

Screenshots

Updated App Features

The free app, available for iPhone and Android users, still offers the ability to see drilling near you in the U.S. and add reports and photos about this activity onto a shared map. Based on feedback from many of our partners and readers, we have added and updated several features, as well.

Profile – Sign in to the app with an email address and password, with the option to add other information to your profile. This area is also where you can privately view your previous and pending reports.
Activity Feed – Shows the most recent submissions by app users. Scroll down to view older reports.
Save As Draft – Not ready to submit your report? Save it as a draft and return to submit it later.
Real-Time Submissions – We will no longer be curating incoming reports before they go live – so the activity feed and map show real-time submissions.
Flagging Tool – Mark a submission as inappropriate. A FracTracker moderator will review the report and take the appropriate action.
Indicate Senses Affected – Classify a report by the sense(s) impacted – e.g. Nearby drilling activity is loud, or an impoundment is causing noxious odors.
Pipelines Mapped – In addition to active wells and user reports, we have added national pipelines to the map. Please note that many of the pipeline locations are approximate because detailed, public pipeline data is lacking. Help us make this information more accurate by posting photos of pipelines near you.

Feedback Loops

Several organizations and community groups helped to test and improve the app during its redesign, including residents living amongst the oil and gas fields on the Front Range of Colorado and Southwest Pennsylvania, as well as with students at Drexel University.

When we redesigned our mobile app, we felt it was important to go into communities that are living amongst the oil and gas industry. Together, we identified what they needed most when reporting their concerns and potential impacts. The results are a very versatile app. People living around urban refinery hubs, as well as those living in rural extraction regions, will find this tool incredibly useful.

We’d love to hear your feedback about these changes once you have had a chance to explore the app’s updated features.

Download the App

Learn more about the app and see how it has been used in the field

The app was developed by FracTracker Alliance in collaboration with Viable Industries, L.L.C.

Mobile App Contact

Kirk Jalbert, PhD, MFA
Manager of Community-Based Research and Engagement
FracTracker Alliance
jalbert@fractracker.org

Tracking Refinery Emissions in California’s Bay Area Refinery Corridor

May 10, 2017/by Kyle Ferrar, MPH

Air quality in the California Bay Area has been steadily improving over the last decade, and the trend can even be seen over just the course of the last few years. In this article we explore data from the ambient air quality monitoring networks in the Bay Area, including a look at refinery emissions.

From the data and air quality reports we find that that many criteria pollutants such as fine particulate matter (PM_2.5) and oxides of nitrogen (NO_X) have decreased dramatically, and areas that were degraded are now in compliance.

While air pollution from certain sectors such as transportation have been decreasing, the north coast of the East Bay region is home to a variety of petrochemical industry sites. This includes five petroleum refineries. The refineries not only contribute to these criteria pollutants, but also emit a unique cocktail of toxic and carcinogenic compounds that are not monitored and continue to impact cardiovascular health in the region. This region, aptly named the “refinery corridor” has a petroleum refining capacity of roughly 800,000 BPD (barrels per day) of crude oil.

Petroleum refineries in California’s East Bay have always been a contentious issue, and several of the refineries date back to almost the turn of the 20th century. The refineries have continuously increased their capacities and abilities to refine dirtier crude oil through “modernization projects.” As a result, air quality and health impacts became such a concern that in 2006 and again in 2012, Gayle McLaughlin, a Green Party candidate, was elected as Mayor of the City of Richmond. Richmond, CA became the largest city in the U.S. with a Green Party Mayor. While there have been many strides in the recent decade to clean up these major sources of air pollution, health impacts in the region including cardiovascular disease and asthma, as well as cancer rates, are still disproportionately high.

Regulations

To give additional background on this issue, let’s discuss some the regulations tasked with protecting people and the environment in California, as well as climate change targets.

New proposals for meeting California’s progressive carbon emissions standards were proposed in January of 2017. A vote to decide on the plan to meet the aggressive new climate target and reduce greenhouse gas emissions 40% across all sectors of the economy will happen this month, May 2017! Over the last ten years the refineries have invested in modernization projects costing more than $2 billion to reduce emissions.

However – a current proposal will actually allow the refineries to process more crude oil by setting a standard for emissions by volume of crude/petroleum refined, rather than an actual cap on emissions. The current regulatory approach focuses on “source-by-source” regulations of individual equipment, which ignores the overall picture of what’s spewing into nearby communities and the atmosphere. Even the state air resources board has supported a move to block the refineries from accepting more heavy crude from the Canadian tar sands.

New regulatory proposals incentivize refineries to continue expanding operations to refine more oil, resulting in a larger burden on the health of these already disproportionately impacted environmental justice communities. Chevron, in particular, is upgrading their Richmond refinery in a way as to allow it to process dirtier crude in larger volumes from the Monterey Shale and Canada’s Tar Sands. Since the production volumes of lighter crudes are shrinking, heavier dirtier crudes are becoming a larger part of the refinerys’ feedstocks. Heavier crudes require more energy to refine and result in larger amounts of hazardous emissions.

Upgrades are also being implemented to address greenhouse gas emissions. While the upgrades address the carbon emissions, regulatory standards without strict caps for other pollutants will allow emissions of criteria and toxic air pollutants such as VOC’s, nitrosamines, heavy metals, etc… to increase. In fact, newly proposed emissions standards for refineries will make it easier for the refineries to increase their crude oil volumes by regulating emissions on per-barrel standards. Current refining volumes can be seen below in Table 1, along with their maximum capacity.

Table 1. Bay Area refineries average oil processed and total capacity

Refinery	Location	Ave. oil processed Barrels Per Day (2012 est.)	Max. capacity (BPD)
Chevron U.S.A. Inc. Richmond Refinery	Richmond	245,271	>350,000
Tesoro Refining & Marketing, Golden Eagle Refinery	Martinez	166,000	166,000
Shell Oil Products US, Martinez Refinery	Martinez	156,400	158,000
Valero Benicia Refinery	Benicia	132,000	150,000
Phillips 66, Rodeo San Francisco Refinery	Rodeo	78,400	100,000

Source: California Energy Commission. One barrel of oil = 42 U.S. gallons.

Environmental Health Inequity

The Bay Area, and in particular the city of Richmond, have been noted in the literature as a place where environmental racism and environmental health disparity exist. The city’s residents of color disproportionately live near the refineries and chemical plants, which is noted in early works on environmental racism by pioneers of the idea, such as Robert Bullard (Bullard 1993a,b).

Since the issue has been brought to national attention by environmental justice groups like West County Toxics Coalition, progress has been made to try to bring justice, but it has been limited. People of color are still disproportionately exposed to toxic, industrial pollution in that area. A recent study showed 93% of respondents in Richmond were concerned about the link between pollution and health, and 81% were concerned about a specific polluter, mainly the Chevron Refinery (Brody et al. 2012). Recent health reports continue to show the trend that these refinery communities suffer disproportionately from cases of asthma and cardiovascular disease and higher mortality rates from a variety of cancers.

Health Impact Studies

Manufacturing and refining are known to produce particularly toxic pollution. Additionally, there has been research done on the specific makeup of pollution in the refinery corridor. The best study to do this is the Northern California Household Exposure Study (Brody et al. 2009). They examined indoor and outdoor air in Richmond, a refinery corridor community, and Bolinas, a nearby but far more rural community. They found 33% more compounds in Richmond, along with higher concentrations of each compound. The study also found very high concentrations of vanadium and nickel in Richmond, some of the highest levels in the state. Vanadium and nickel have been shown to be some of the most dangerous PM2.5 components as we previously stated, which gives reason to believe the air pollution in Richmond is more toxic than in surrounding areas.

Another very similar study compared the levels of endocrine disrupting compounds in Richmond and Bolinas homes, and found 40 in Richmond homes and only 10 in Bolinas (Rudel et al. 2010). This supports the idea that a large variety of pollutants with synergistic effects may be contributing to the increased mortality and hospital visits for communities in this region. This small body of research on pollution in Richmond suggests that the composition of air pollution may be more toxic and thus trigger more pollution-related adverse health outcomes than in surrounding communities.

Air Quality Monitoring

As discussed above and in FracTracker’s previous reports on the refinery corridor, the refinery emissions are a unique cocktail whose synergistic effects may be driving much of the cardiovascular disease, asthma, and cancer risk in the region. Therefore, the risk drivers in the Bay Area need to be prioritized, in particular the compounds of interest emitted by the petrochemical facilities.

The targets for emissions monitoring are compounds associated with the highest risk in the neighboring communities. An expert panel was convened in 2013 to develop plans for a monitoring network in the refinery corridor. Experts found that measurements should be collected at 5 minute intervals and displayed to the public real-time. The gradient of ambient air concentrations is determined by the distance from refinery, so a network of three near-fence-line monitors was recommended. Major drivers of risk are supposed to be identified by air quality monitoring conducted as a part of Air District Regulation 12m Rule 15: Petroleum Refining Emissions tracking. According to the rule, fence-line monitoring plans by refinery operators:

… must measure benzene, toluene, ethyl benzene, and xylenes (BTEX) and HS concentrations at refinery fence-lines with open path technology capable of measuring in the parts per billion range regardless of path length. Open path measurement of SO₂, alkanes or other organic compound indicators, 1, 3-butadiene, and ammonia concentrations are to be considered in the Air Monitoring Plan.

The following analysis found that the majority of hazardous pollutants emitted from refineries are not monitored downwind of the facility fence-lines, much less the list explicitly named in the regulations above.

As shown below in Figure 1, the most impacted communities are in those directly downwind of the facility. According to the BAAQMD, each petroleum refinery is supposed to have fence-line monitoring. Despite this regulation developed by air quality and health experts, only two out of the five refineries have even one fence-line monitor. Real-time air monitoring data at the Chevron Richmond fence-line monitor and the Phillips 66 Rodeo fence-line monitor can be found on fenceline.org. Data from these monitors are also aggregated by the U.S. EPA, and along with the other local monitors, can be viewed on the EPA’s interactive mapping platform.

Figure 1. Map of Hydrogen Sulfide Emissions from the Richmond Chevron Refinery

Hazardous Emissions and Ambient Pollution

Since the majority of hazardous chemicals emitted from the refineries are not measured at monitoring sites, or there are not any monitoring sites at the fence-line or downwind of the facility, our mapping exercises instead focus on the hazardous air pollution for which there is data.

As shown in the map of hydrogen sulfide (H₂S) above, the communities immediately neighboring the refineries are subjected to the majority of hazardous emissions. The map shows the rapidly decreasing concentration gradient as you get away from the facility. H₂S would have been a good signature of refinery emissions throughout the region if there were more than three monitors. Also, those monitors only existed until 2013, when they were replaced with a singular monitor in a much better location, as shown on the map. The 2016 max value is much higher because it is more directly downwind of Chevron Refinery.

The interpolated map layer was created using 2013 monitoring data from three monitors that have since been removed. The 2016 monitoring location is in a different location and has a maximum value more than twice what was recorded at the 2013 location.

Table 2. Inventory of criteria pollutant emissions for the largest sectors in the Bay Area

	Annual average tons per day
	PM₁₀	PM_2.5	ROG	NO_X	SO_X	CO
Area wide	175.51	52.90	87.95	19.92	0.62	161.86
Mobile	20.33	16.27	183.12	380.52	14.93	1541.50
Total Emissions	16.30	12.14	106.58	50.59	45.95	44.31

Table adapted from the BAAQMD Refinery Report. PM₁₀ = particulate matter less than 10 microns in diameter (about the width of a human hair); PM_2.5 = PM less than 2.5 microns in diameter; ROG = reactive organic gases; NO_X = nitrogen oxides; SO_X = sulfur oxides; CO = carbon monoxide.

Additionally, exposure assessment can also rely on using surrogate emissions to understand where the plumes from the refineries are interacting with the surrounding communities. It is particularly important to also discriminate between different sources of pollution. As we see in Table 2 above, the largest volume of particulate matter (PM), NO_X, and CO emissions actually come from mobile sources, whereas the largest source of sulfur dioxide and other oxides (SO_X) is from stationary sources. Since the relationship between PM_2.5 and health outcomes is most established, the response to ambient levels of PM_2.5in the refinery corridor gives insight into the composition of PM as well as the presence of other species of hazardous air pollution. On the other hand, SO₂ can be used as a surrogate for the footprint of un-monitored air toxics.

Pollutants’ Fingerprints

Particulate Matter

Figure 2. Map of fine particulate matter (PM_2.5) for the Bay Area Air Quality Management District

View map fullscreen | How FracTracker maps work

Figure 2 above displays ambient levels of PM_2.5, and as the map shows, the highest levels of particulate matter surround the larger metro area of downtown Oakland and also track with the larger commuting corridors. The map shows evidence that the largest contributor to PM_2.5 is truly the transportation (mobile) sector. PM_2.5 is one hazardous air pollutant which negatively impacts health, causing heart attack, or myocardial infarction (MI), among other conditions. PM_2.5 is particulate matter pollution, meaning small particles suspended in the air, specifically particles under 2.5 microns in diameter. Exposure to high levels of PM_2.5 increases the risk of MI within hours and for the next 1-2 days (Brooks et al. 2004; Poloniecki et al. 1997).While refineries may not be the largest source of PM in the Bay Area, they are still large point sources that contribute to high local conditions of smog.

The chemical make-up of the particulate matter also needs to be considered. In addition, the toxicity of PM from the refineries is of particular concern. Since particulate matter acts like small carbon sponges, the source of PM affects its toxicity. The cocktail of hazardous air toxics emitted by refineries absorb and adsorb to the surfaces of PM. When inhaled with PM, these toxics including heavy metals and carcinogens are delivered deep into lung tissue.

Pooled results of many studies showed that for every 10 micrograms per meter cubed increase in PM_2.5 levels, the risk of MI increases 0.4-1% (Brooks et al. 2010). However, this relationship has not been studied in the context of EJ communities. EJ communities are generally low income communities of color (Bullard 1993), which have higher exposures to pollution, more sources of stress, and higher biological markers of stress (Szanton et al. 2010; Carlson and Chamberlein 2005). All of these factors may affect the relationship between PM_2.5 and MI, and increase the health impact of pollution in EJ communities relative to what has been found in the literature.

Sulfur Dioxide

Figure 3 below shows the fingerprint of the refinery emissions on the refinery corridor, using SO₂emissions as a surrogate for the cocktail of toxic emissions. The relationship between SO₂and health endpoints of cardiovascular disease and asthma have also been established in the literature (Kaldor et al. 1984).

In addition to assessing SO₂as a direct health stressor, it is also the most effective tracer of industrial emissions and specifically petroleum refineries for a number of reasons. Petroleum refineries are the largest source of SO₂in the BAAQMD by far (Table 1), and there are more monitors for SO₂than any of the other emitted chemical species that can be used to fingerprint the refineries. The distribution of SO₂is therefore representative of the cocktail of a combination of the hazardous chemicals released in refinery emissions.

Figure 3. Map of Sulfur Dioxide for the Bay Area Air Quality Management District

View map fullscreen | How FracTracker maps work

Further Research

The next step for FracTracker Alliance is to further explore the relationship between health effects in the refinery communities and ambient levels of air pollution emitted by the refineries. Our staff is currently working with the California Department of Public Health to analyze the response of daily emergency room discharges for a variety of health impacts including cardiovascular disease and asthma.

References

Brody, J. G., R. Morello-Frosch, A. Zota, P. Brown, C. Pérez, and R. A. Rudel. 2009. Linking Exposure Assessment Science With Policy Objectives for Environmental Justice and Breast Cancer Advocacy: The Northern California Household Exposure Study. American Journal of Public Health 99:S600–S609.

Brook, R. D., B. Franklin, W. Cascio, Y. Hong, G. Howard, M. Lipsett, R. Luepker, M. Mittleman, J. Samet, S. C. Smith, and I. Tager. 2004. Air Pollution and Cardiovascular Disease. Circulation 109:2655–2671.

Brooks, R. D., S. Rajagopalan, C. A. Pope, J. R. Brook, A. Bhatnagar, A. V. Diez-Roux, F. Holguin, Y. Hong, R. V. Luepker, M. A. Mittleman, A. Peters, D. Siscovick, S. C. Smith, L. Whitsel, and J. D. Kaufman. 2010. Particulate Matter Air Pollution and Cardiovascular Disease. Circulation 121:2331–2378.

Bullard, R. D. 1993a. Race and Environmental Justice in the United States Symposium: Earth Rights and Responsibilities: Human Rights and Environmental Protection. Yale Journal of International Law 18:319–336.

Bullard, R. D. 1993b. Confronting Environmental Racism: Voices from the Grassroots. South End Press.

Carlson, E.D. and Chamberlain, R.M. (2005), Allostatic load and health disparities: A theoretical orientation. Res. Nurs. Health, 28: 306–315. doi:10.1002/nur.20084

Kaldor, J., J. A. Harris, E. Glazer, S. Glaser, R. Neutra, R. Mayberry, V. Nelson, L. Robinson, and D. Reed. 1984. Statistical association between cancer incidence and major-cause mortality, and estimated residential exposure to air emissions from petroleum and chemical plants. Environmental Health Perspectives 54:319–332.

Poloniecki, J. D., R. W. Atkinson, A. P. de Leon, and H. R. Anderson. 1997. Daily Time Series for Cardiovascular Hospital Admissions and Previous Day’s Air Pollution in London, UK. Occupational and Environmental Medicine 54:535–540.

Rudel, R. A., R. E. Dodson, L. J. Perovich, R. Morello-Frosch, D. E. Camann, M. M. Zuniga, A. Y. Yau, A. C. Just, and J. G. Brody. 2010. Semivolatile Endocrine-Disrupting Compounds in Paired Indoor and Outdoor Air in Two Northern California Communities. Environmental Science & Technology 44:6583–6590.

Szanton SL, Thorpe RJ, Whitfield KE. Life-course Financial Strain and Health in African-Americans. Social science & medicine (1982). 2010;71(2):259-265. doi:10.1016/j.socscimed.2010.04.001.

By Daniel Menza, Data & GIS Intern, and Kyle Ferrar, Western Program Coordinator, FracTracker Alliance

Cover photo credit: Claycord.com

Photo by Garth Lenz, iLCP - for Ethane Cracker article about risk and disclosure

Understanding in Order to Prepare: Ethane Cracker Risk and Disclosure

May 3, 2017/by FracTracker Alliance

By Leann Leiter and Lisa Graves Marcucci
Maps and data analysis by Kirk Jalbert

Highly industrialized operations like petrochemical plants inherently carry risks, including the possibility of large-scale disasters. In an effort to prepare, it is incumbent upon all stakeholders to fully understand the risk potential. Yet, the planned Shell ethane cracker and additional petrochemical operations being proposed for Western Pennsylvania are the first of their kind in our region. This means that residents and elected officials are without a frame of reference as they consider approving these operations. Officials find themselves tasked with reviewing and approving highly complicated permit applications, and the public remains uncertain of what questions to ask and scenarios to consider. Often overlooked in the decision-making process is valuable expertise from local first responders like police, fire and emergency crew members, HAZMAT teams, and those who protect vulnerable populations, like emergency room personnel, nursing home staff, and school officials.

Steam cracker at BASF's Ludwigshafen site. Photo credit: BASF - for risk and disclosure article

Example of cracker producing ethylene, located at BASF’s Ludwigshafen site. Photo credit: BASF

In the first article in this series , we tried to identify the known hazards associated with ethane crackers. In this article, we look more closely at how that risk could play out in Beaver County, PA and strive to initiate an important dialogue that invites valuable, local expertise.

In keeping with the first article in this series, we use the terms vulnerability and capacity. Vulnerability refers to the conditions and factors that increase the disaster impact that a community might experience, and capacity consists of the strengths that mitigate those impacts. Importantly, vulnerability and capacity frequently intertwine and overlap. We might, for example, consider a fire station to be a site of “capacity,” but if it lies within an Emergency Planning Zone (discussed more below), an explosion at the plant could render it a vulnerability. Likewise, “vulnerable” populations such as the elderly may have special skills and local knowledge, making them a source of capacity.

Emergency Planning: Learning from Louisiana

FracTracker got in touch with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn how a community already living with Shell-owned and other petrochemical facilities manages risk and disclosure. The Emergency Manager we spoke with explained that they designate a two- and a five-mile area around each new facility in their jurisdiction, like ethane crackers, during their emergency planning process. They call these areas “ emergency planning zones ” or EPZs, and they maintain records of the vulnerabilities and sites of capacity within each zone. In case of a fire, explosion, or other unplanned event at any facility, having the EPZs designated in advance allows them to mobilize first responders, and notify and evacuate everyone living, working, and attending school within the zone. Whether they activate a two- or a five-mile EPZ depends on the type of incident, and factors like wind speed and direction.

Based on those procedures, the map below shows similar likely zones for the proposed plant in Beaver County, along with sites of vulnerability and capacity.

Ethane Cracker Hazard Map

View Map Fullscreen | How FracTracker Maps Work

The map helps us visualize the vulnerability and capacity of this area, relative to the proposed ethane cracker. It includes three main elements: the Shell site and parcels likely to be targeted for buildout of related facilities, two Emergency Planning Zones (EPZs) around the Shell facility, and infrastructure and facilities of the area that represent vulnerability and capacity.

Vacant parcels near the site

It is important to note that the proposed ethane cracker in Beaver County is merely the first of an influx of petrochemical spin-off facilities promised for the area, potentially occupying the various empty parcels indicated on the map above as “vacant properties” and presented in light gray in the screenshot left.

Each new facility would add its own risks and cumulative impacts to the equation. It would be impossible to project these additional risks without knowing what facilities will be built here, so in this article, we stick to what we do know – the risks already articulated by Shell, lessons learned from other communities hosting petrochemical industry in other parts of the country, and past disasters at similar facilities.

Vulnerability and Capacity in Beaver County

Red, blue, and green points on the map above and in the screenshot below stand in for hospitals like Heritage Valley Beaver; fire and emergency medical services like Vanport Volunteer Fire Company; police stations like the Beaver County Sheriff’s office; and daycares and schools like Center Grange Primary School.

Transportation routes, if impacted, could challenge evacuation. Potter Township Fire Chief Vicki Carlton pointed out that evacuations due to an event at this facility could also be complicated by the need to stay upwind, when evacuations would likely move in a downwind direction. This map lacks drinking water intakes and other essential features upon which lives depend, but which nonetheless also sit within this zone of vulnerability.

Points within EPZS

Vulnerability/capacity within 2-mile zone:

1 hospital
5 police stations
10 fire/EMS stations
23 schools/daycare facilities
47,717 residents*

When expanded to 5-mile zone:

2 hospitals
9 police stations
23 fire/EMS stations
40 schools/daycare facilities
120,849 residents*

*Note: For census tracts that are partly within a zone, a ratio is determined based on the percentage of land area in the tract within the zone. This ratio is then used to estimate the fraction of the population likely within the zone.

Stakeholders’ Right to Know

No person or community should be subjected to risk without the opportunity to be fully informed and to give meaningful input. Likewise, no group of people should have to bear a disproportionate share of environmental risks, particularly stakeholders who are already frequently disenfranchised in environmental decision-making. “Environmental justice” (EJ) refers to those simple principles, and DEP designates environmental justice areas based on communities of color and poverty indicators.

Presented as blue fields on the map and shown in the screenshot below, several state-designated EJ areas fall partially or entirely within the 2- and 5-mile EPZs (a portion of two EJ areas home to 2,851 people, and when expanded to five miles, two entire EJ areas and a portion of seven more, home to 18,679 people, respectively).

EJ Areas and Emergency Planning Zones around the Site

The basic ideas behind environmental justice have major bearing in emergency scenarios. For example, those living below the poverty line tend to have less access to information and news sources, meaning they might not learn of dangerous unexpected emissions plumes coming their way. They also may not have access to a personal vehicle, rendering them dependent upon a functioning public transportation system to evacuate in an emergency. Living below poverty level may also mean fewer resources at home for sheltering-in-place during a disaster, and having less financial resources, like personal savings, may lead to more difficult post-disaster recovery.

Local expertise

FracTracker recently consulted with the Emergency Management Director for Beaver County, Eric Brewer, and with Potter Township Fire Chief Vicki Carlton. Both indicated that their staff have already begun training exercises with Shell -including a live drill on site that simulated a fire in a work trailer. But when asked, neither reported that they had been consulted in the permit approval process. Neither had been informed of the chemicals to be held on site, and both referred to emergency planning considerations as something to come in the future, after the plant was built.

Unfortunately, the lack of input from public safety professionals during the permit approval stage isn’t unique to Beaver County. Our emergency management contact in Louisiana pointed to the same disturbing reality: Those who best understand the disaster implications of these dangerous developments and who would be mobilized to respond in the case of a disaster are not given a say in their approval or denial. This valuable local expertise – in Louisiana and in Beaver County – is being overlooked.

All Beaver County first responders who spoke with FracTracker clearly showed their willingness to perform their duties in any way that Shell’s new facility might demand, hopefulness about its safety, and a generally positive relationship with the company so far. Chief Carlton believes that the ethane cracker will be an improvement over the previous facility on the same site, the Horsehead zinc smelter, though a regional air pollution report characterizes this as a trade off of one type of dangerous pollution for another. Director Brewer pointed to the existing emergency plans for the county’s nuclear facility as giving Beaver County an important leg-up on preparedness.

But the conversations also raised concern about what the future relationship between the community and the industry will look like. Will funds be allocated to these first responders for the additional burdens brought on by new, unprecedented facilities, in what amount, and for how long into the future? Chief Carlton pointed out that until Shell’s on-site fire brigade is in place two or three years from now, her all-volunteer department would be the first line of defense in case of a fire or other incident. In the meantime, her fire company has ordered a much-needed equipment upgrade to replace a 30-year old, outdated tanker at a cost of $400,000. They are formally requesting all corporate businesses in the township, including Shell, to share the cost. Hopefully, the fire company will see this cost covered by their corporate neighbors who use their services. But further down the road? Once all is said and done, and Shell has what they need to operate unfettered, Chief Carlton wonders, “where do we stand with them?”

Waiting for disclosure of the risks

Emergency preparedness and planning should be a process characterized by transparency and inclusion of all stakeholders. However, when it comes to the Shell ethane cracker, those who will share a fence line with such operations have not yet been granted access to the full picture. Currently, the DEP allows industrial operations like the proposed ethane cracker to wait until immediately before operations begin to disclose emergency planning information, in the form of Preparedness, Prevention, and Contingency (PPC) plans. In other words, when permits are up for approval or denial prior to construction, permit applicants are not currently required to provide PPC plans, and the public and emergency managers cannot weigh the risks or provide crucial input.

Shell’s Acknowledged Risks According to public information provided by Shell	Sampling of Shell’s Disastrous Petrochemical Precedents
Fire and Explosions	Shell’s Deer Park, Texas, 1997: Blast at chemical plant
Leaks	Shell’s Deer Park, Texas refinery and chemical plant, 2013: Harmful air pollution and benzene leak
Equipment Failures	Shell’s Martinez Refinery in California, 2016: Equipment failure event; Shell’s refusal to reveal gases emitted

According to Shell, possible risks of the proposed Beaver County petrochemical facility include fire, explosion, leaks, and equipment failures. More than mere potentialities, examples of each are already on the books. The above table presents a sampling. Shell also points out the increased risk of traffic accidents, not explored in this chart. It is worth noting, however, that the proposed facility, and likely spin-off facilities, would greatly increase vehicular and rail traffic.

The ethane cracker in Beaver County plant has not yet been constructed. However, Shell operates similar operations with documented risks and their own histories of emergency events. Going forward, the various governmental agencies tasked with reviewing permit applications should require industrial operations like Shell, to make this information public as part of the review and planning process. Currently they can relegate safety information to a few vague references and get a free pass to mark it as “confidential” in permit applications. Strengthening risk disclosure requirements would be a logical and basic step toward ensuring that all stakeholders – including those with special emergency planning expertise – can have input on whether those risks are acceptable before permits are approved and site prep begins.

Until regulations are tightened, we invite Shell to fulfill its own stated objective of being a “good neighbor” by being forthcoming about what risks will be moving in next door. Shell can and should take the initiative to share information about its existing facilities, as well as lessons learned from past emergencies at those sites. Instead of waiting for the post-construction, or the “implementation” stage, all stakeholders deserve disclosure of Shell’s plans to prevent and respond to emergencies now.

In our next article, we will explore the infrastructure for the proposed Shell facility, which spans multiple states, and sort out the piecemeal approval processes of building an ethane cracker in Pennsylvania.

Sincere Appreciation

Emergency Managers and First Responders in St. Charles Parish, Louisiana and Potter Township and Center Township, PA.

Lisa Hallowell, Senior Attorney at the Environmental Integrity Project, for her review of this article series and contributions to our understanding of relevant regulations.

Kirk Jalbert, in addition to maps and analysis, for contributing key points of consideration for and expertise on environmental justice.

The International League of Conservation Photographers for sharing the feature image used in this article.

The image used on our homepage of the steam cracker at BASF’s Ludwigshafen site was taken by BASF.

By Leann Leiter, Environmental Health Fellow for FracTracker Alliance and the Southwest PA Environmental Health Project and Lisa Graves Marcucci, PA Coordinator, Community Outreach of Environmental Integrity Project

With maps and analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance

Violations and Monitoring in Pennsylvania’s Susquehanna River Basin

May 2, 2017/by Matt Kelso, BA

The Susquehanna River is a 444-mile long waterway extending from the area around Cooperstown, New York to the Chesapeake Bay. In Pennsylvania, the basin includes more than 37,000 miles of streams that feed into the river, which capture the precipitation of more than 20,000 square miles of land, and is home to over 3.3 million people.

The region has been heavily impacted by oil and natural gas extraction in recent years; more than 5,500 unconventional wells and roughly 13,500 conventional wells have been drilled in the PA segment of the basin since 2000. Unconventional wells, in particular, have brought industrial-scaled activity, pollution, and waste products to a wide area of the basin, with especially heavy development occurring in three counties along Pennsylvania’s northern tier – Bradford, Susquehanna, and Tioga.

Several governmental agencies are involved with monitoring impacts to this massive watershed. This article focuses on the Pennsylvania portion of the basin, and examines how capable agency-run monitoring efforts are in capturing oil and gas (O&G) related pollution events. The Pennsylvania Department of Environmental Protection (DEP), the US Geological Survey (USGS), and the Susquehanna River Basin Commission (SRBC) maintain a combined network of 274 monthly “grab sample” monitoring sites and 58 continuous data loggers in the Pennsylvania portion of the river basin. Meanwhile, between January 1, 2000 and February 7, 2017, the DEP logged 6,522 on the O&G violations compliance report within the same region. More than three out of every four of these violations have been assessed to unconventional wells, even though only one out of every four active wells in the basin is categorized as such.

Map of O&G Monitoring & Violations in PA’s Susquehanna River Basin

View Map Fullscreen | How FracTracker Maps Work

Limitations of Monitoring Efforts

Grab samples obtained from official monitoring locations are the preferred method for regulatory purposes in understanding the long-term health of the river system. Researchers can test for any number of analytes from samples that are collected in-stream, but analyzed in certified laboratories. However, samples from these locations are collected periodically – usually once per month – and therefore are very likely to miss the effects of a significant spill or issue that may impact surface water chemistry for a number of hours or days before being diluted and washing downstream.

Continuous data loggers give regulators a near real-time assessment of what is happening in selected points in the basin, usually at 15-minute intervals. While there are numerous events that contribute to fluctuations in these measurements, these data loggers would be the most likely instruments available to register an event impacting the surface water within the basin. However, there are unique issues with data loggers. For instance, available data from these data loggers are much more limited in scope, as temperature, pH, and conductivity are typically the only available analytes. In addition, because the analysis occurs on site, the results carry less weight than laboratory results would. Finally, even though data loggers collect data at rapid intervals, only some are equipped to send data real-time to agency offices. Some data loggers must be manually collected on a periodic basis by program managers.

Perhaps the greatest challenge for monitoring in the Susquehanna River Basin is that it is simply not practical to monitor in all places likely to be impacted by oil and gas operations. Testing within the jurisdiction of the Susquehanna River Basin is actually fairly extensive when compared to other regions, such as the Ohio River Basin. The Ohio River Valley Water Sanitation Commission – the equivalent of the SRBC for the Ohio River Basin – only monitors basic analytes like total dissolved solids at 29 locations, all at or near the main stem of the river. However, none of the agencies monitoring water quality in the Susquehanna River Basin have capacity to test everywhere. On average, there is one testing location for every 111 miles of rivers and streams within the basin.

Case Studies

If agency-based monitoring is so limited, then the important question is: How well do these efforts capture oil and gas-related impacts? Some violations are more likely to impact surface water quality than others. This article takes a closer look at some of the bigger problem areas within the basin, including the Dimock region in Susquehanna County, Leroy Township in Bradford County, and Bell Township in Clearfield County.

Dimock

O&G violations and water monitoring near Dimock, PA. Note that multiple violations can occur at the same location. Click to expand map.

The highest concentration of oil and gas violations in the Susquehanna Basin is located in the townships of Dimock and Springville, in Susquehanna County, PA, with a total of 591 incidents reported on the compliance report. This makes the region the highest concentration of O&G violations in the entire state. Many of these violations are related to the systemic failure of well integrity, resulting in the contamination of numerous groundwater supplies. In terms of how these might affect surface water, 443 of the violations are in areas that drain into the Thomas Creek-Meshoppen Creek subwatershed by the southern edge of Springville Township, while most of the rest of the violations drain into the parallel West Branch of Meshoppen Creek.

The USGS operates a monthly monitoring location in the middle of the cluster of violations, at the confluence of Burdick and Meshoppen creeks, just north of the Dimock’s southern border. While this location might seem ideal at first, only 180 of the 443 violations in the subwatershed are upstream of the grab sample site. There is another water monitoring location that captures all of these violations in the Meshoppen subwatershed, but it is more than 15 miles downstream. (link to EJ article about Dimock)

Leroy Township

O&G Violations and monitoring near Leroy Township, PA. Click to expand map.

Compared to the huge amount of oil and gas violations throughout the Dimock area, Leroy Township in Bradford County looks relatively quiet. It also appears to be well covered by monitoring locations, including a data logger site near the western edge of the township, a centrally located monthly monitoring location, as well as another monthly grab sample site upstream on Towanda Creek, just beyond the eastern boundary in Franklin Township.

And yet, this area was hit hard in the early part of the decade by two significant spills. On April 19, 2011, Chesapeake Appalachia lost control of the Atlas 2H well, with thousands of gallons of flowback fluid spilling onto the countryside and into the nearby Towanda Creek.

A little over a year later on July 4, 2012, a second major spill in the township saw 4,700 gallons of hydrochloric acid hit the ground. According to the DEP compliance report, this did not make it into the waterways, despite the gas well being located only about 550 feet from Towanda Creek, and less than 300 feet from another unnamed tributary.

Both incidents were within a reasonable distance of downstream monitoring locations. However, as these are grab sample sites that collect data once per month, they can only offer a limited insight into how Towanda Creek and its tributaries were impacted by these notable O&G related spills.

Bell Township

O&G violations and monitoring near Bell Township, PA. Click to expand map.

Bell Township is a small community in Clearfield County along the banks of the West Branch Susquehanna River. The northwestern portion of the township ultimately drains to the Ohio River, but all of the violations in Bell Township are within the Susquehanna River Basin.

Two significant incidents occurred in the township in 2016. On February 18, 2016, Alliance Petroleum Corp lost control of the McGee 11 OG Well, located less than 250 feet from Deer Run. According to the oil and gas compliance report, control of the well was regained five days later, after releasing unspecified quantities of gas, produced fluid, and crude oil. On December 5^th of the same year, Exco Resources was cited for allowing 30 barrels (1,260 gallons) of produced fluid to spill at the Clyde Muth M-631 Wellpad in Bell Township.

A United States Geological Survey monthly monitoring location along the West Branch Susquehanna in nearby Greenwood Township is upstream, and could capture the effects of spills throughout much of Bell Township. However, the incident at the Clyde Muth well pad occurred in the Curry Run subwatershed, which meets up with the West Branch Susquehanna downstream of the monitoring location, so any pollution events in that area will not be reflected by monitoring efforts.

Conclusions

In the case of Dimock and Springville townships, we see how official water monitoring efforts capture only a fraction of the notorious cluster of wells that have resulted in hundreds of violations over the past decade. There could scarcely be a better candidate for systematic observation, and yet only a single grab sample site covers the immediate vicinity. Leroy Township does not have the same quantity of impacts as Dimock, but it did see one the worst blowouts in the recent history of O&G operations in Pennsylvania. The area is relatively well covered by grab samples sites, but due to the monthly sampling schedule, these locations would still be unlikely to capture significant changes in water quality. In Bell Township, much of the area is upstream of a monthly grab sample site, but the nearest downstream monitoring location to a major spill of produced fluid that occurred here is more than 17 miles away from the incident as the crow flies.

It should be noted that there are a number of industries and activities that contribute to water pollution in Pennsylvania, and as a result, the monitoring efforts are not specifically designed to capture oil and gas impacts. However, the compliance record shows heavy impacts from oil and gas wells in the basin, particularly from modern unconventional wells.

While the network of government-operated manual monitoring locations and data logger sites are fairly extensive in Susquehanna River Basin, these efforts are not sufficient to capture the full extent of oil and gas impacts in the region. Finding evidence of a small to medium sized spill at a site with monthly testing is unlikely, as contaminated water doesn’t stay in place in a dynamic river system. Data loggers also have a limited capacity, but are a useful tool for identifying substantial changes in water chemistry, and could therefore be employed to identify the presence of substantial spills. As such, it might be beneficial for additional data loggers to be distributed throughout the basin, particularly in areas that are heavily affected by the oil and gas industry. Furthermore, given resource gaps and staff cuts within agencies tasked with protecting the river basin, agencies should strongly consider utilizing networks of volunteers to augment their limited monitoring networks.

Project Info

Read more about the Susquehanna River Basin Impacts Project

By Matt Kelso, Manager of Data and Technology, FracTracker Alliance