Overhead view of injection well

The Hidden Inefficiencies and Environmental Costs of Fracking in Ohio

Ohio continues to increase fracked gas production, facilitated by access to freshwater and lax radioactive waste disposal requirements.

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Map: Ohio Quarterly Utica Oil and Gas Production along with Quarterly Wastewater Disposal

Well Volumes

A little under a year ago, FracTracker released a map and associated analysis, “A Disturbing Tale of Diminishing Returns in Ohio,” with respect to Utica oil and gas production, highlighting the increasing volume of waste injected in wastewater disposal wells, and trends in lateral length in fracked wells from 2010 to 2018. In this article, I’ll provide an update on Ohio’s Utica oil and gas production in 2018 and 2019, the demands on freshwater, and waste disposal. After looking at the data, I recommend that we holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste in order to minimize negative externalities.

Recently, I’ve been inspired by the works of Colin Woodward[1] and Marvin Harris, who outline the struggle between liberty and the common good. They relate this to the role that commodities and increasing resource intensity play in maintaining or enhancing living standards. This quote from Harris’s “Cannibals and Kings” struck me as the 122 words that most effectively illustrate the impacts of the fracking boom that started more than a decade ago in Central Appalachia:

“Regardless of its immediate cause, intensification is always counterproductive. In the absence of technological change, it leads inevitably to the depletion of the environment and the lowering of the efficiency of production since the increased effort sooner or later must be applied to more remote, less reliable, and less bountiful animals, plants, soils, minerals, and sources of energy. Declining efficiency in turn leads to low living standards – precisely the opposite of the desired result. But this process does not simply end with everybody getting less food, shelter, and other necessities in return for more work. As living standards decline, successful cultures invent new and more efficient means of production which sooner or later again lead to the depletion of the natural environment.” From Chapter 1, page 5 of Marvin Harris’ “Cannibals and Kings: The Origins of Cultures, 1977

In reflecting on Harris’s quote as it pertains to fracking, I thought it was high time I updated several of our most critical data sets. The maps and data I present here speak to intensification and the fact that the industry is increasingly leaning on cheap water withdrawals, landscape impacts, and waste disposal methods to avoid addressing their increasingly gluttonous ways. To this point, the relationship between intensification and resource utilization is not just the purview of activists, academics, and journalists anymore; industry collaborators like IHS Markit admitting as much in their latest analysis pointing to the fact that oil and gas operators “will have to drill substantially more wells just to maintain current production levels and even more to grow production”. Insert Red Queen Hypothesis analogy here!

Oil and Gas Production in Ohio

The four updated data sets presented here are: 1) oil, gas, and wastewater production, 2) surface and groundwater withdrawal rates for the fracking industry, 3) freshwater usage by individual Ohio fracked wells, and 3) wastewater disposal well (also referred to as Class II injection wells) rates.

Below are the most important developments from these data updates as it pertains to intensification and what we can expect to see in the future, with or without the ethane cracker plants being trumpeted throughout Appalachia.

From a production standpoint, total oil production has increased by 30%, while natural gas production has increased by 50% year over year between the last time we updated this data and Q2-2019 (Table 1).

According to the data we’ve compiled, the rate of growth for wastewater production has exceeded oil and is nearly equal to natural gas at 48% from 2017 to 2018.  On average the 2,398 fracked wells we have compiled data for are producing 27% more wastewater per well now than they did at the end of 2017.

————–2017————– ————–2019————–
Oil (million barrels) Gas (million Mcf) Brine (million barrels) Oil (million barrels) Gas (million Mcf) Brine (million barrels)
Max 0.51 12.92 0.23 0.62 17.57 0.32
Total 83.14 5,768.47 76.01 108.15 8,679.12 112.28
Mean 0.40 2.79 0.37 0.45 3.62 0.47

Table 1. Summary statistics for 2,398  fracked wells in Ohio from a production perspective from 2017 to Q2 2019.

 

Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.

Figure 1. Total fracked gas produced per quarter and average fracked gas produced per well in Ohio from 2013 to Q2-2019.

The increasing amount of resources and number of wells necessary to achieve marginal increases in oil and gas production is a critical factor to considered when assessing industry viability and other long-term implications. As an example, in Ohio’s Utica Shale, we see that total production is increasing, but as IHS Markit admits, this is only possibly by increasing the total number of producing wells at a faster rate. As is evidenced in Figure 1, somewhere around the Winter of 2017-2018, the production rate per well began to flatline and since then it has begun to decrease.

Water demands for oil and gas production in Ohio

Since last we updated the industry’s water withdrawal rates, the Ohio Department of Natural Resources (ODNR) has begun to report groundwater rates in addition to surface water. The former now account for nine sites in seven counties, but amount to a fraction of reported withdrawals to date (around 00.01% per year in 2017 and 2018). The more disturbing developments with respect to intensification are:

1) Since we last updated this data, 59 new withdrawal sites have come online. There are currently 569 sites in total in ODNR’s database. This amounts to a nearly 12% increase in the total number of sites since 2017. With this additional inventory, the average withdrawal rate across all sites has increased by 13% (Table 2).

2) Since 2010, the demand for freshwater to be used in fracking has increased by 15.6% or 693 million gallons per year (Figure 2).

3) We expect to see an inflection point when water production will increase to accommodate the petrochemical buildout with cracker plants in Dilles Bottom, OH; Beaver County, PA; and elsewhere. In 2018 alone, the oil and gas industry pulled 4.69 billion gallons of water from the Ohio River Valley. Since 2010, the industry has permanently removed 22.96 billion gallons of freshwater from the Ohio River Valley. It would take the entire population of Ohio five years to use the 2018 rate in their homes.[2]

As we and others have mentioned in the past, this trend is largely due to the bargain basement price at which we sell water to the oil and gas sector throughout Appalachia.[3] To increase their nominal production returns, companies construct longer laterals with orders of magnitude more water, sand, and chemicals.  At this rate, the fracking industry’s freshwater demand will have doubled to around 8.8-.9.5 billion gallons per year by around 2023.  Figure 3 demonstrates that average fracked lateral length continues to increase to the tune of +15.7-21.2% (+1,564-2,107 feet) per quarter per lateral. This trend alone is more than 2.5 times the rate of growth in oil production and roughly 24% greater than the rate of growth in natural gas production (See Table 1).

4. The verdict is even more concerning than it was a couple years ago with respect to water demand increasing by 30% per quarter per well or an average of 4.73 million gallons (Figure 4). The last time we did this analysis >1.5 years ago demand was rising by 25% per quarter or 3.84 million gallons. At that point I wouldn’t have guessed that this exponential rate of water demand would have increased but that is exactly what has happened. Very immediate conversations must start taking place in Columbus and at the region’s primary distributor of freshwater, The Muskingum Watershed Conservancy District (MWCD), as to why this is happening and how to push back against the unsustainable trend.

2017 2018
Sites 510 569
Maximum (billion gallons) 1.059 1.661
Sum (billion gallons) 18.267 22.957
Mean (billion gallons) 0.358 0.404

Table 2. Summary of fracking water demands throughout Ohio in 2017 when we last updated this data as well as how those rates changed in 2018.

Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (Million Gallons Per Year).

Figure 2. Hydraulic fracturing freshwater demand in total across 560+ sites in Ohio from 2010 to 2018 (million gallons per year).

Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (Feet).

Figure 3. Average lateral length for all of Ohio’s permitted hydraulically fractured laterals from from Q3-2010 to Q4-2019, along with average rates of growth from a linear and exponential standpoint (feet).

Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (Million Gallons).

Figure 4. Average Freshwater Demand Per Unconventional Well in Ohio from Q3-2011 to Q3-2019 (million gallons).

 

Waste Disposal

When it comes to fracking wastewater disposal, the picture is equally disturbing. Average disposal rates across Ohio’s 220+ wastewater disposal wells increased by 12.1% between Q3-2018 and Q3-2019 (Table 3). Interestingly, this change nearly identically mirrors the change in water withdrawals during the same period. What goes down– freshwater – eventually comes back up.

Across all of Ohio’s wastewater disposal wells, total volumes increased by nearly 22% between 2018 and the second half of 2019. However, the more disturbing trend is the increasing focus on the top 20 most active wastewater disposal wells, which saw  an annual increase of 17-18%. These wells account for nearly 50% of all waste and the concern here is that many of the pending wastewater disposal well permits are located on these sites, within close proximity, and/or are proposed by the same operators that operate the top 20.

When we plot cumulative and average disposal rates per well, we see a continued exponential increase. If we look back at the last time, we conducted this analysis, the only positive we see in the data is that at that time, average rates of disposal per well were set to double by the Fall of 2020. However, that trend has tapered off slightly — rates are now set to double by 2022.

Each wastewater disposal well is seeing demand for its services increase by 2.42 to 2.94 million gallons of wastewater per quarter (Figure 5). Put another way, Ohio’s wastewater disposal wells are rapidly approaching their capacity, if they haven’t already.  Hence why the oil and gas industry has been frantically submitting proposals for additional waste disposal wells. If these wells materialize, it means that Ohio will continue to be relied on as the primary waste receptacle for the fracking industry throughout Appalachia.

Variable ——————-All Wells——————- ——————-Top 20——————-
To Q3-2018 To Q3-2019 % Change To Q3-2018 To Q3-2019 % Change
Number of Wells 223 243 +9.0 ——- ——- ——-
Max (MMbbl) 1.12 1.20 +7.1 ——- ——- ——-
Sum (MMbbl) 203.19 247.05 +21.6 101.43 119.31 +17.6
Average (MMbbl) 0.91 1.02 +12.1 5.07 5.97 +17.8

Table 3. Summary Statistics for Ohio’s Wastewater Disposal Wells (millions of barrels (MMbbl)).

Average Fracking Waste Disposal across all of Ohio’s Class II Injection Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (Million Barrels).

Figure 5. Average Fracking Waste Disposal across all of Ohio’s Wastewater Disposal Wells and the cumulative amount of fracking waste disposed of in these wells from Q3-2010 to Q2-2019 (million barrels).

Using the Pennsylvania natural gas data merged with the Ohio wastewater data, we were able to put a finer point on how much wastewater would be produced with a 100,000 barrel ethane cracker like the one PTT Global Chemical has proposed for Dilles Bottom, Ohio. The following are our best estimate calculations assuming 1 barrel of condensate is 20-40% ethane. These calculations required that we take some liberties with the merge of the ratio of gas to wastewater in Ohio with the ratio of gas to condensate in Pennsylvania:

  1. For 2,064 producing Ohio fracked wells, the ratio of gas to wastewater is 64.76 thousand cubic feet (Mcf) of gas produced per barrel of wastewater.
  2. Assuming 40% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 320.08 Mcf of gas per barrel of ethane condensate. For 100,000 barrels of ethane needed per cracker per day, that would result in 494,285 barrels (20.76 million gallons) of brine per day.
  3. Assuming 20% ethane, the ratio of gas to condensate in Washington County, PA wells for the first half of 2019 was 640.15 Mcf per barrel of ethane condensate = For 100,000 barrels of ethane needed per cracker per day that would result in 988,571 barrels/41.52 million gallons of wastewater per day.

But wait, here is the real stunner:

  1. The 40% assumption result is 3.81 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 5.37 times the daily rates of brine taken in by the top 20 wells (Note: the top 20 wastewater disposal wells account for 71% of all wastewater  waste taken in by all of the state’s disposal wells).
  2. The 20% assumption result is 7.62 times the daily rates of wastewater taken in by our current inventory of wastewater disposal wells and 10.74 times the daily rates of wastewater taken in by the top 20 wells.

Therefore, we estimate the fracked wells supplying the proposed PTTGC ethane cracker will generate between 20.76 million and 41.52 million gallons of wastewater per day. That is 3.8 to 7.6 times the amount of wastewater currently received by Ohio’s wastewater disposal wells.

What does this means in terms of truck traffic? We can assume that  at least 80% of the trucks that transport wastewater are the short/baby bottle trucks which haul 110 barrels per trip. This means that our wastewater estimates would require between 4,493 and 8,987 truck trips per day, respectively. The pressures this amount of traffic will put on Appalachian roads and communities will be hard to measure and given the current state of state and federal politics and/or oversight it will be even harder to measure the impact inevitable spills and accidents will have on the region’s waterways.

Conclusion

There is no reason to believe these trends will not persist and become more intractable as the industry increasingly leans on cheap waste disposal and water as a crutch. The fracking industry will continue to present shareholders with the illusion of a robust business model, even in the face of rapid resource depletion and precipitous production declines on a per well basis.

I am going to go out on a limb and guess that unless we more holistically price our water resources and the ways in which we dispose of the industry’s radioactive waste, there will be no other supply-side signal that we could send that would cause the oil and gas industry to change its ways. Until we reach that point, we will continue to compile data sets like the ones described above and included in the map below, because as Supreme Court Justice Louis Brandeis once said, “Sunlight is the best disinfectant!”

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison

[1] Colin Woodward’s “American Character: A history of the epic struggle between individual liberty and the common good” is a must read on the topic of resource utilization and expropriation.

[2] https://pubs.er.usgs.gov/publication/cir1441

[3] In Ohio the major purveyor of water for the fracking industry is the Muskingum Watershed Conservancy District (MCWD) and as we’ve pointed out in the past they sell water for roughly $4.50 to $6.50 per thousand gallons. Meanwhile across The Ohio River the average price of water for fracking industry in West Virginia in the nine primary counties where fracking occurs is roughly $8.38 per thousand gallons.

Data Downloads

Quarterly oil, gas, brine, and days in production for 2,390+ Unconventional Utica/Point Pleasant Wells in Ohio from 2010 to Q2-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/Production_To_Q2_2019_WithExcel.zip

Ohio Hydraulic Fracturing Freshwater and Groundwater Withdrawals from 2010 to 2018

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_WaterWithdrawals_2010_2018_WithExcel.zip

Lateral length (Feet) for 3,200+ Fracked Utica/Point Pleasant Wells in Ohio up to and including wells permitted in December, 2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/01/OH_Utica_December_2019_StatePlane_Laterals.zip

Freshwater Use for 2,700+ Unconventional Wells in Ohio from Q3-2011 to Q3-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_FracFocus_December_2019_WithExcel.zip

Quarterly Volume Disposal (Barrels) for 220+ Ohio Class II Salt Water Disposal Wells from 2010 to Q4-2019

https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/OH_ClassII_Loc_Vols_10_Q4_2019_WithExcel.zi

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Fracking in Pennsylvania: Not Worth It

Despite the ever-increasing heaps of violations and drilling waste, Pennsylvania’s fracked wells continue to produce an excess supply of gas, driving prices down. To cut their losses, the oil and gas industry is turning towards increased exports and petrochemical production. Continuing to expand fracking in Pennsylvania will only increase risks to the public and to the climate, all for what may amount to another boom and bust cycle that is largely unprofitable to investors.

Let’s take a look at gas production, waste, newly drilled wells, and violations in Pennsylvania in the past year to understand just how precarious the fracking industry is.

Production

Fracked hydrocarbon production continues to rise in Pennsylvania, resulting in an increase in waste production, violations, greenhouse gas emissions, and public health concerns. There are three types of hydrocarbons produced from wells in Pennsylvania: gas, condensate, and oil. Gas is composed mostly of methane, the most basic of the hydrocarbons, but in some parts of Pennsylvania, there can be significant quantities of ethane, propane, and other so-called “natural gas liquids” (NGLs) mixed in. Each of these NGLs are actually gaseous at atmospheric conditions, but operators try to separate these with a combination of pressure and low temperatures, converting them to a liquid phase. Some of these NGLs can be separated on-site, and this is typically referred to as condensate. Fracked wells in Pennsylvania also produce a relatively tiny amount of oil.

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For those of you wondering why we are looking at the November, 2018 through October, 2019 time frame, this is simply a reflection of the available data. In this 12-month period, 9,858 fracked Pennsylvania wells, classified as “unconventional,” reported producing 6.68 trillion cubic feet of gas (Tcf), 4.89 million barrels of condensate, and just over 70,000 barrels of oil.

By means of comparison, Pennsylvania consumed about 1.46 Tcf of gas across all sectors in 2018, of which just 253 billion cubic feet (Bcf) was used in the homes of Pennsylvania’s 12.8 million residents. In fact, the amount of gas produced in Pennsylvania exceeds residential consumption in the entire United States by almost 1.7 Tcf. However, less than 17% of all gas consumed in Pennsylvania is for residential use, with nearly 28% being used for industrial purposes (including petrochemical development), and more than 35% used to generate electricity.

Fracked Gas Production and Consumption in Pennsylvania from 2013 through 2018

Figure 1. Fracked gas production compared to all fracked gas consumption and residential gas consumption in Pennsylvania from 2013 through 2018. Data from ref. Energy Information Administration.

 

While gas production has expansive hotspots in the northeastern and southwestern portions of the state, the liquid production comes from a much more limited geography. Eighty percent of all condensate production came from Washington County, while 87% of all fracked oil came from wells in Mercer County.

Because the definition of condensate has been somewhat controversial in the past (while the oil export ban was still in effect), I asked the Department of Environmental Protection (DEP) for the definition, and was told that if hydrocarbons come out of the well as a liquid, they should be reported as oil. If they are gaseous but condense to a liquid at standard temperature and pressure (60 degrees Fahrenheit and pressure 14.7 PSIA) on-site, then it is to be reported as condensate. Any NGLs that remain gaseous but are removed from the gas supply further downstream are reported as gas in this report. For this reason, it is not really possible to use the production report to find specific amounts of NGLs produced in the state, but it certainly exceeds condensate production by an appreciable margin.

The one-year volume withdrawal of gas from unconventional wells in Pennsylvania is equal to the volume of 3.2 Mount Everests

The volume of gas withdrawn from fracked wells in Pennsylvania in just one year is equal to the volume of 3.2 Mount Everests!

 

Waste

Hydrocarbons aren’t the only thing that come out of the ground when operators drill and frack wells in Pennsylvania. Drillers also report a staggering amount of waste products, including more than 65 million barrels (2.7 billion gallons) of liquid waste and 1.2 million tons of solid waste in the 12-month period.

Waste facilities have significant issues such as inducing earthquakes, toxic leachate, and radioactive sediments in streambeds.

Waste Type Liquid Waste (Barrels) Solid Waste (Tons)
Basic Sediment 63
Brine Co-Product 247
Drill Cuttings 1,094,208
Drilling Fluid Waste 1,439,338 11,378
Filter Socks 143
Other Oil & Gas Wastes 2,236,750 6,387
Produced Fluid 61,376,465 41,165
Servicing Fluid 17,196 3,250
Soil Contaminated by Oil & Gas Related Spills 25,505
Spent Lubricant Waste 1,104
Synthetic Liner Materials 21,051
Unused Fracturing Fluid Waste 7,077 1,593
Waste Water Treatment Sludge 35,151
Grand Total 65,078,240 1,239,831

Figure 2. Oil and gas waste generated by fracked wells as reported by drillers from November 1, 2018 through October 31, 2019. Data from ref: PA DEP.

Some of the waste is probably best described as sludge, and several of the categories allow for reporting in barrels or tons. Almost all of the waste was in the well bore at one time or another, although there are some site-related materials that need to be disposed of, including filter socks which separate liquid and solid waste, soils contaminated by spills, spent lubricant, liners, and unused frack fluid waste.

Where does all of this waste go? We worked with Earthworks earlier this year to take a deep dive into the data, focusing on these facilities that receive waste from Pennsylvania’s oil and gas wells. While the majority of the waste is dealt with in-state, a significant quantity crosses state lines to landfills and injection wells in neighboring states, and sometimes as far away as Idaho.

Please see the report, Pennsylvania Oil & Gas Waste for more details.

 

Drilled Wells

Oil and gas operators have started the drilling process for 616 fracking wells in 2019, which appear on the Pennsylvania DEP spud report. This is less than one third of the 2011 peak of 1,956 fracked wells, and 2019 is the fifth consecutive year with fewer than 1,000 wells drilled. This has the effect of making industry projections relying on 1,500 or more drilled wells per year seem rather dubious.

 

Fracked Unconventional Wells Drilled per Year in Pennsylvania from 2005 through 2019

Figure 3. Unconventional (fracked) wells drilled from 2005 through December 23, 2019, showing totals by regional office. Data from ref: PA DEP.

 

Oil and gas wells in Pennsylvania fall under the jurisdiction of three different regional offices. By looking at Figure 2, it becomes apparent that the North Central Regional Office (blue line) was a huge driver of the 2009 to 2014 drilling boom, before falling back to a similar drilling rate of the Southwest Regional Office.

The slowdown in drilling for gas in recent years is related to the lack of demand for the product. In turn, this drives prices down, a phenomenon that industry refers to as a “price glut.” The situation it is forcing major players in the regions such as Range Resources to reduce their holdings in Appalachia, and some, such as Chevron, are pulling out entirely.

Violations

Disturbingly, 2019 was the fifth straight year that the number of violations issued by DEP will exceed the total number of wells drilled.

Unconventional fracked wells drilled and violations issued from 2005 through 2019

Figure 4. Unconventional (fracked) drilled wells and issued violations from 2005 through December 2019. Data from ref: DEP.

 

Violations related to unconventional drilling are a bit unwieldy to summarize. The 13,833 incidents reported in Pennsylvania fall into 359 different categories, representing the specific regulations in which the drilling operator fell short of expectations. The industry likes to dismiss many of these as being administrative matters, and indeed, the DEP does categorize the violations as either “Administrative” or “Environmental, Health & Safety”. However, 9,998 (72%) of the violations through December 3, 2019, are in the latter category, and even some of the ones that are categorized as administrative seem like they ought to be in environmental, health, and safety. For example, let’s look at the 15 most frequent infractions:

Violation Code Incidents Category
SWMA301 – Failure to properly store, transport, process or dispose of a residual waste. 767 Environmental Health & Safety
CSL 402(b) – POTENTIAL POLLUTION – Conducting an activity regulated by a permit issued pursuant to Section 402 of The Clean Streams Law to prevent the potential of pollution to waters of the Commonwealth without a permit or contrary to a permit issued under that authority by the Department. 613 Environmental Health & Safety
102.4 – Failure to minimize accelerated erosion, implement E&S plan, maintain E&S controls. Failure to stabilize site until total site restoration under OGA Sec 206(c)(d) 595 Environmental Health & Safety
SWMA 301 – MANAGEMENT OF RESIDUAL WASTE – Person operated a residual waste processing or disposal facility without obtaining a permit for such facility from DEP. Person stored, transported, processed, or disposed of residual waste inconsistent with or unauthorized by the rules and regulations of DEP. 540 Environmental Health & Safety
601.101 – O&G Act 223-General. Used only when a specific O&G Act code cannot be used 469 Administrative
402CSL – Failure to adopt pollution prevention measures required or prescribed by DEP by handling materials that create a danger of pollution. 362 Environmental Health & Safety
78.54* – Failure to properly control or dispose of industrial or residual waste to prevent pollution of the waters of the Commonwealth. 339 Environmental Health & Safety
401 CSL – Discharge of pollutional material to waters of Commonwealth. 299 Environmental Health & Safety
102.4(b)1 – EROSION AND SEDIMENT CONTROL REQUIREMENTS – Person conducting earth disturbance activity failed to implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation. 285 Environmental Health & Safety
102.5(m)4 – PERMIT REQUIREMENTS – GENERAL PERMITS – Person failed to comply with the terms and conditions of the E & S Control General Permit. 283 Environmental Health & Safety
78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances. 256 Administrative
78a53 – EROSION AND SEDIMENT CONTROL AND STORMWATER MANAGEMENT – Person proposing or conducting earth disturbance activities associated with oil and gas operations failed to comply with 25 Pa. Code § 102. 247 Environmental Health & Safety
102.11(a)1 – GENERAL REQUIREMENTS – BMP AND DESIGN STANDARDS – Person failed to design, implement and maintain E & S BMPs to minimize the potential for accelerated erosion and sedimentation to protect, maintain, reclaim and restore water quality and existing and designated uses. 235 Environmental Health & Safety
CSL 401 – PROHIBITION AGAINST OTHER POLLUTIONS – Discharged substance of any kind or character resulting in pollution of Waters of the Commonwealth. 235 Environmental Health & Safety
OGA3216(C) – WELL SITE RESTORATIONS – PITS, DRILLING SUPPLIES AND EQUIPMENT – Failure to fill all pits used to contain produced fluids or industrial wastes and remove unnecessary drilling supplies/equipment not needed for production within 9 months from completion of drilling of well. 206 Environmental Health & Safety

Figure 5. Top 15 most frequently cited violations for unconventional drilling operations in Pennsylvania through December 3, 2019. Data from ref: DEP.

Of the 15 most common categories, only two are considered administrative violations. One of these is a general code, where we don’t know what happened to warrant the infraction without reading the written narrative that accompanies the data, and is therefore impossible to categorize. The only other administrative violation in the top 15 categories reads, “78.56(1) – Pit and tanks not constructed with sufficient capacity to contain pollutional substances,” which certainly sounds like it would have some real-world implications beyond administrative concerns.

Check out our Pennsylvania Shale Viewer map to see if there are violations at wells near you.

Bloated With Gas, Fraught With Trouble

To address the excess supply of gas, companies have tried to export the gas and liquids to other markets through pipelines. Those efforts have been fraught with trouble as well. Residents are reluctant to put up with an endless barrage of new pipelines, yielding their land and putting their safety at risk for an industry that can’t seem to move the product safely. The Revolution pipeline explosion hasn’t helped that perception, nor have all of the sinkholes and hundreds of leaky “inadvertent returns” along the path of the Mariner East pipeline system. In a sense, the industry’s best case scenario is to call these failures incompetence, because otherwise they would be forced to admit that the 2.5 million miles of hydrocarbon pipelines in the United States are inherently risky, prone to failure any time and any place.

In addition to increasing the transportation and export of natural gas to new markets, private companies and elected officials are collaborating to attract foreign investors to fund a massive petrochemical expansion in the Ohio River Valley. The planned petrochemical plants intend to capitalize on the cheap feedstock of natural gas.

Pennsylvania’s high content of NGLs is a selling point by the industry, because they have an added value when compared to gas. While all of these hydrocarbons can burn and produce energy in a similar manner, operators are required to remove most of them to get the energy content of the gas into an acceptable range for gas transmission lines. Because of this, enormous facilities have to be built to separate these NGLs, while even larger facilities are constructed to consume it all. Shell’s Pennsylvania Petrochemicals Complex ethane cracker being built in Beaver County, PA is scheduled to make 1.6 million metric tons of polyethylene per year, mostly for plastics.

This comes at a time when communities around the country and the world are enacting new regulations to rein in plastic pollution, which our descendants are going to finding on the beach for thousands of years, even if everyone on the planet were to stop using single-use plastics today. Of course, none of these bans or taxes are currently permitted in Pennsylvania, but adding 1.6 million metric tons per year to our current supply is unnecessary, and indeed, it is only the beginning for the region. A similar facility, known as the PTT Global Chemical cracker appears to be moving forward in Eastern Ohio, and ExxonMobil appears to be thinking about building one in the region as well. Industry analysts think the region produces enough NGLs to support five of these ethane crackers.

Despite all of these problems, the oil and gas industry still plans to fill the Ohio River Valley with new petrochemical plants, gas processing plants, and storage facilities in the hopes that someday, somebody may want what they’ve taken from the ground.

Here’s hoping that 2020 is a safer and healthier year than 2019 was. But there is no need to leave it up to chance. Together, we have the power to change things, if we all demand that our voices are heard. As a start, consider contacting your elected officials to let them know that renewing Pennsylvania’s blocking of municipal bans and taxes on plastic bags is unacceptable.

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

 

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