This testimony was provided by Shannon Smith, FracTracker Manager of Communications & Development, at the July 23rd hearing on the control of methane & VOC emissions from oil and natural gas sources hosted by the Pennsylvania Department of Environmental Protection (DEP).
My name is Shannon Smith and I’m a resident of Wilkinsburg, Pennsylvania. I am the Manager of Communications and Development at the nonprofit organization FracTracker Alliance. FracTracker studies and maps issues related to unconventional oil and gas development, and we have been a top source of information on these topics since 2010. Last year alone, FracTracker’s website received over 260,000 users. FracTracker, the project, was originally developed to investigate health concerns and data gaps surrounding Western Pennsylvania fracking.
I would like to address the proposed rule to reduce emissions of methane and other harmful air pollution, such as smog-forming volatile organic compounds, which I will refer to as VOCs, from existing oil and gas operations. I thank the DEP for the opportunity to address this important issue.
The proposed rule will protect Pennsylvanians from methane and harmful VOCs from oil and gas sources, but to a limited extent. The proposed rule does not adequately protect our air, climate, nor public health, because it includes loopholes that would leave over half of all potential cuts to methane and VOC pollution from the industry unchecked.
Emissions of the potent greenhouse gas methane and VOC pollution harm communities by contributing to the climate crisis, endangering households and workers through explosions and fires, and causing serious health impairments. Poor air quality also contributes to the economic drain of Pennsylvania’s communities due to increased health care costs, lower property values, a declining tax base, and difficulty in attracting and retaining businesses.
Oil and gas related air pollution has known human health impacts including impairment of the nervous system, reproductive and developmental problems, cancer, leukemia, depression, and genetic impacts like low birth weight.
One indirect impact especially important during the COVID-19 pandemic in 2020, is the increased incidence and severity of respiratory viral infections in populations living in areas with poor air quality, as indicated by a number of studies.
Given the available data, FracTracker Alliance estimates that there are 106,224 oil and gas wells in Pennsylvania. Out of the 12,574 drilled unconventional wells, there have been 15,164 cited violations. Undoubtedly the number of violations would be higher with stricter monitoring.
There is a need for more stringent environmental regulations and enforcement, and efforts to do so should be applauded only if they adequately respond to the scientific evidence regarding risks to public health. These measures are only successful if there is long-term predictability that will ultimately drive investments in clean energy technologies. Emission rollbacks undermine decades of efforts to shift industries towards cleaner practices. So, I urge the DEP to close the loophole in the proposed rulemaking that exempts low-producing wells from the rule’s leak inspection requirements. Low-producing wells are responsible for more than half of the methane pollution from oil and gas sources in Pennsylvania, and all wells, regardless of production, require routine inspections.
I also ask that the Department eliminate the provision that allows operators to reduce the frequency of inspections based on the results of previous inspections. Research does not show that the quantity of leaking components from oil and gas sources indicates or predicts the frequency or quantity of future leaks.
In fact, large and uncontrolled leaks are random and can only be detected with frequent and regular inspections. Short-term peaks of air pollution due to oil and gas activities are common and can cause health impairments in a matter of minutes, especially in sensitive populations such as people with asthma, children, and the elderly. I urge the Department to close loopholes that would exempt certain wells from leak detection and repair requirements, and ensure that this proposal includes requirements for all emission sources covered in DEP’s already adopted standards for new oil and gas sources.
Furthermore, conventional operators should have to report their emissions, and the Department should require air monitoring technologies that have the capacity to detect peaks rather than simply averages. We need adequate data in order to properly enforce regulations and meet Pennsylvania’s climate goals of decreasing greenhouse gas emissions by 80% by 2050.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/08/EQT-Tioga-Wide-7.gif300800Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgShannon Smith2020-06-29 11:04:372020-06-29 11:55:12Testimony to PA DEP on Control of Methane & VOC Emissions from Oil and Natural Gas Sources
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
A drilling fluid spill from Falcon Pipeline construction near Moffett Mill Road in Beaver County, PA. Source: Pennsylvania DEP
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Figure 1. An HDD operation – Thousands of gallons of drilling fluid are used in this process, creating the potential for spills. Click to expand. Source: Enbridge Pipeline
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
Loss of circulation
Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
15 losses in Ohio – totaling 73,414 gallons
34 losses in Pennsylvania – totaling 172,116 gallons
Inadvertent return
Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
Cause: Inadvertent returns are also frequent during HDD construction and are caused by many of the same factors as losses of circulation.
Construction of the Falcon has caused at least 20 inadvertent returns, releasing at least 5,581 gallons of drilling fluid. These incidents include:
18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
2,639 gallons into water resources (streams and wetlands)
2 inadvertent returns Ohio – totaling 35 gallons
35 gallons into water resources (streams and wetlands)
However, according to the Ohio EPA, Shell is not required to submit reports for losses of circulation that are less than the definition of an inadvertent return, so many losses may not be captured in the list above. Additionally, documents reveal inconsistent volumes of drilling mud reported and discrepancies in the way releases are regulated by the Pennsylvania DEP and the Ohio EPA.
Very few of these incidents were published online for the public to see; FracTracker obtained information on them through a public records request. The map below shows the location of all known drilling fluid releases from that request, along with features relevant to the pipeline’s construction. Click here to view full screen, and add features to the map by checking the box next to them in the legend. For definitions and additional details, click on the information icon.
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
Figure 2. Losses of circulation that occurred at the SCIO-06 horizontal directional drill (HDD) site along the Falcon Pipeline in Jefferson County Ohio. Data Sources: OH EPA, AECOM
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
Figure 3. The SCIO-06 HDD site, which may be changed from an HDD crossing to an open cut trench and conventional bore to cross Wolf Run Rd, Wolf Run stream (darker blue), an intermittent stream (light blue) and a wetland (teal). Click to expand.
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.”In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Figure 4) HOU-10 HDD location on the Falcon Pipeline, where 50 gallons were released on the drill pad on 7/9/2019
Figure 5) SCIO-05 HDD location on the Falcon Pipeline, where 160 gallons were released on 6/10/19, within the pipeline’s LOD (limit of disturbance)
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/FalconPipelineFrontPage.jpg8963125Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2020-06-16 11:47:062020-06-18 12:11:30Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
California is once again a fracked state. The moratorium on well stimulations (hydraulic fracturing and acidizing) that lasted since June 26, 2019 has now come to an end. As of April 3rd, 2020, California’s oil and gas regulatory body, California Geological Energy Management Division (CalGEM), approved 24 new permits to frack new wells. The wells were permitted to the operator Aera Energy. Well types to be fracked include 22 oil and gas production wells and 2 water flood wells; 18 of which are in the South Belridge Field and 6 North Belridge Field. Locations of the wells are shown in the map in Figure 1, and are mapped with the rest of 2020’s approved well drilling and rework permits in Consumer Watchdog’s updated release on NewsomWellWatch.org. Please read our press release with Consumer Watchdog here!
Figure 1. Map of New Fracking Permits in California
Fortunately, these 24 approved well stimulation permits are not located in close proximity to communities that would be directly impacted by the negative contributions to air quality and potential groundwater quality degradation that result from drilling and stimulating oil and gas wells. Regardless of where oil and gas wells and stimulations are permitted in relation to Frontline Communities, these wells will still degrade the regional air quality of the San Joaquin Valley. The San Joaquin Valley has the worst air quality in the country. According to the U.S. EPA, oil and gas production is a main contributor of volatile organic compounds (VOC’s) and NOX in the Valley. In addition to VOC’s being carcinogens, these pollutants are precursors to the ozone and smog that cause health impacts such as asthma, chronic obstructive pulmonary disease (COPD), cardiovascular disease, and negative birth outcomes.
Geology and Spills
Additionally, the dolomite formations where these 24 stimulations were permitted have also experienced the same type of oil seeps and spills (known as surface expressions) as the Cymric Field just to the south. Readers may remember the operator Chevron spilling 1.3 million gallons of oil and wastewater in an uncontrollable seep resulting from high pressure injection wells.
Whereas Governor Newsom may have put a halt to unpermitted high-pressure injections, regulators have just approved permits for 24 new fracking operations, a.k.a well stimulations. The irony here is that risks inherent in the fracking process in California include the same risks associated withhigh pressure steam injection operations. Both techniques elevate the downhole pressure of a well to the point that the formation “source” rock is fractured. These techniques increase the likelihood of downhole communication with other surrounding wells, both active and plugged. Downhole communication events between wells, in this case known as “frack hits” are a major cause of well casing failures and blowouts, which in turn are the primary cause of surface expressions. Simply put, high pressure injections in over-developed oil fields result in spills, and in this case, these 24 permitted stimulations are within 1,500’ of over 7,000 existing wells, a distance specifically identified by CalGEM as a high-risk zone for downhole communication between wells.
Regulation
So how did these wells get approved? Here’s the story, as told by CalGEM:
In November, CalGEM requested a third-party scientific review of pending well stimulation permit applications to ensure the state’s technical standards for public health, safety and environmental protection are met prior to approval of each permit. To ensure the proposed permits comply with California law, including the state’s technical standards to protect public health, safety, and environmental protection, the Department of Conservation asked experts at the Lawrence Livermore National Laboratory (LLNL) to assess CalGEM’s permit review process. LLNL also evaluated the completeness of operators’ application materials and CalGEM’s engineering and geologic analyses.
The independent scientific review is one of Governor Newsom’s initiatives to ensure oil and gas regulations protect public health, safety, and environmental protection. This review, which assesses the completeness of each proposed hydraulic fracturing permit, is taking place as an interim measure while a broader audit is completed of CalGEM’s permitting process for well stimulation. That audit is being completed by the Department of Finance Office of Audits and Evaluation (OSAE) and will be completed and shared publicly later this year. LLNL experts are continuing evaluation on a permit-by-permit basis and conducting a rigorous technical review to verify geological claims made by well operators in the application process. Permit by permit review will continue until the Department of Finance Audit is complete later this year.
LLNL’s scientific review of the permit applications and process found that the permitting process met statutory and regulatory requirements. LLNL found, however, that CalGEM could improve its evaluation of the technical models used in the permit approval process. As a result, CalGEM now requires all operators to provide an Axial Dimensional Stimulation Area (ADSA) Narrative Report for each oilfield and fracture interval which must be validated by LLNL and conform to the new CalGEM permitting process. This will improve CalGEM’s ability to independently validate applicants’ fracture modeling.
While this sounds like a methodological approach to the permitting process, it is still flawed in several ways. First and foremost, there is still no process for community input, let alone community decision-making. Community stakeholders are not engaged at in point in this process. Furthermore the contribution of oil and gas extraction operations to the degradation of environmental quality is already well established. In the case of these 24 fracking permits, they will contribute to the further degradation of regional air quality and continue the legacy of groundwater contamination within the sacrifice zone surrounding the Belridge fields.
Fracking in the Age of Pandemics
While we are critical of Governor Newsom’s climate-changing oil extraction policies, FracTracker would like to recognize the leadership Governor Newsom has shown instituting responsible policies to keep Californians as safe as possible and protected from the threat of COVID-19. While there can still be more done to provide relief for the most financially vulnerable, such as instituting a rent moratorium for those that do not own their own homes, California leads as an example for the public health interventions that need to be instituted nation-wide. The Governors inclusion of undocumented citizens in the state’s economic stimulus program is a first step, and FracTracker Alliance fully supports increasing the amount to at least match the $1,200 provided to the rest of Californians.
Conclusion
Regardless, the threat of COVID-19 cannot be addressed in a vacuum. Threats of infection are magnified for Frontline Communities. Living near oil and gas operations exposes communities to a cocktail of volatile organic compounds that suppress the immune system, increasing the risk of contracting viral lung infections. Frontline Communities are therefore particularly vulnerable to the threat of COVID-19. California and Governor Newsom need to consider the public health implications of permitting new fracking and new oil and gas wells, particularly those permits within 2,500’ of hospitals, schools, and other sensitive sites, above all during an existing pandemic.
By Kyle Ferrar, MPH, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/04/Map-of-New-2020-Fracking-Permits-in-California.jpg11382370Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgKyle Ferrar, MPH2020-05-07 12:48:132020-05-07 14:34:54California, Back in Frack
In the 2018 The Sky’s Limit report by Oil Change International (OCI),4 FracTracker’s analysis showed that 8,493 active or newly permitted oil and gas wells were located within a 2,500’ buffer of sensitive sites including occupied dwellings, schools, hospitals, and playgrounds. At the time, it was estimated that over 850,000 Californians lived within the setback distance of at least one of these oil and gas wells.
An assessment of the number of California citizens living proximal to active oil and gas production wells was also conducted for the CCST State Bill 4 Report on Well Stimulation in 2016.5 The analysis calculated the number of California residents living within 2,500’ of an active (producing) oil and gas well, and based estimates of demographic percentages on 2015 ACS data at the census block level. The report found that:
859,699 individuals in California live within 2,500’ of an active oil and gas well
Of this, a total of 385,067 are “Non-white” (45%)
Of this, a total of 341,231 are “Hispanic” (40%) *[as defined by the U.S. Census Bureau]
Population counts within the setbacks were calculated for smaller census designated areas including counties and census tracts. The results of the calculations are presented in Table 1 and the analysis is shown in the maps in Figure 1 and Figure 2 below.
Data for the City of Los Angeles was also aggregated. Results showed:
215,624 individuals in the City of Los Angeles live within 2,500’ of an active oil and gas well
Of this, a total of 114,593 are “Non-white” (53%)
Of this, a total of 119,563 are “Hispanic” (55%) *[as defined by the U.S. Census Bureau]
Table 1. Population Counts by County. The table presents the counts of individuals living within 2,500’ of an active oil and gas well, aggregated by county. The top 12 counties with the highest population counts are shown. “Impacted Population” is the count of individuals estimated to live within 2,500’ of an oil and gas well. The “% Non-white” and “% Hispanic” columns report the estimated percentage of the impacted population of said demographic.
County
Total Pop.
Impacted Pop.
Impacted % Non-white
Impacted % Hispanic
Los Angeles
9,818,605
541,818
0.54
0.46
Orange
3,010,232
202,450
0.25
0.19
Kern
839,631
71,506
0.34
0.43
Santa Barbara
423,895
8,821
0.44
0.71
Ventura
823,318
8,555
0.37
0.59
San Bernardino
2,035,210
6,900
0.42
0.59
Riverside
2,189,641
5,835
0.46
0.33
Fresno
930,450
2,477
0.34
0.50
San Joaquin
685,306
2,451
0.55
0.42
Solano
413,344
2,430
0.15
0.15
Colusa
21,419
1,920
0.39
0.70
Contra Costa
1,049,025
1,174
0.35
0.30
Figure 1. Map of impacted census tracts for a 2,500’ setback in California. The map shows areas of California that would be impacted by a 2,500’ setback from active oil and gas wells in California.
Figure 2. Map of impacted census tracts for a 2,500’ setback in Los Angeles. The map shows areas of California that would be impacted by a 2,500’ setback from active oil and gas wells in Los Angeles.
From the analysis we find that the majority of California citizens living near active production wells are located in Los Angeles County. This amounts to 61% of the total count of individuals within 2,500’ in the full state. Additionally, the well sample population is limited to only wells that are reported with an “active” status. Including wells identified as idle or support wells such as Class II injection or EOR wells would increase both the total numbers and the demographical percentages because of the high population density in Los Angeles.
Well Counts – Updated Data
Using California Geologic Energy Management Division (CALGEM) data published March 1, 2020, we find that there are 105,808 wells reported as Active/Idle/New in California. There are 16,690 are located within 2,500′ of a sensitive receptor (15.77%). Of the 74,775 active wells in the state, 9,835 fall within the 2,500’ setback distance.6
There are 6,558 idle wells that fall within the 2500’ setback distance, of nearly 30,000 idle wells in the state. Putting these idle wells back online would be blocked if they required reworks to ramp up production. For the most part operators do not intend for most idle wells to come back online. Rather they are just avoiding the costs of plugging.
Of the 3,783 permitted wells not yet in production, or “new wells,” 298 are located within the 2,500’ buffer zone (235 in Kern County).
In Los Angeles, Rule 1148.2 requires operators to notify the South Coast Air Quality Management District of activities at well sites, including permit approvals for stimulations and reworks. Of the 1,361 reports made to the air district since the beginning of 2018 through April 1, 2019; 634 (47%) were for wells that would be impacted by the setback distance; 412 reports were for something other than “well maintenance” of which 348 were for gravel packing, 4 for matrix acidizing, and 65 were for well drilling.
We also analyzed data reported to DOGGR under the well stimulation requirements of SB4. From 1/1/2016 to 4/1/19 there were 576 well stimulation treatment permits granted under the SB4 regulations. Only 1 hydraulic fracturing event, permitted in Goleta, would have been impacted by a 2,500’ setback.
Production
Also part of the OCI The Sky’s Limit report,4 we approximated the amount of oil produced from wells within 2,500’ of sensitive receptors. Using the API numbers of wells identified as being within the buffer area, we pulled production data for each well from the Division of Oil, Gas, and Geothermal Resources (DOGGR) database. The results are based on 2016 production data, the latest complete data available at the time of the analysis. The data indicated that 12% of statewide production came from wells within the buffer zone in 2016. Looking at the production data for a full 6 year period (2010 – 2016), production from wells within the buffer zone was 10% on average statewide. Limiting the analysis to only Kern County, the result was actually smaller. About 5% of countywide production in 2016 (6.1 million barrels) was found to come from wells in the buffer zone.
Low Income Communities
FracTracker conducted an analysis in Kern County for the California Environmental Justice Alliance’s 2018 Environmental Justice Agency Assessment.7 We assessed the proportions of wells near sensitive receptors that are located in low-income communities (at or below 80% of the Kern County Average Median Income). We found that 5,229 active/idle/new oil and gas wells were within 2,500’ from sensitive receptors in low-income communities, including 3,700 active, 1,346 idle, and 183 newly permitted “new” oil and gas wells. The maps in Figures 3 and 4 below show these areas of Kern County and specifically Bakersfield, California.
FracTracker’s analysis of low income communities in Kern County showed the following:
There are 16,690 active oil and gas production wells located in census blocks with median household incomes of less than 80% of Kern’s area median income (AMI).
Therefore about 25% (16,690 out of 67,327 total) of Kern’s oil and gas wells are located within low-income communities.
Of these 16,690 wells, 5,364 of them are located within the 2,500′ setback distance from sensitive receptor sites such as schools and hospitals (32%), versus 13.1% for the rest of the state.
Figure 3. Map of Kern County census tracts with wells impacted by a 2,500’ setback, with median income brackets.
Figure 4. Map of Kern County census tracts with wells impacted by a 2,500’ setback, with median income brackets.
Schools and Environmental Justice
FracTracker conducted an environmental justice analysis to investigate student demographics in schools near oil and gas drilling in California.8 The school enrollment data is from 2013 and the oil and gas wells data is from June 2014. For the analysis we used multiple distances, including 0.5 miles (about 2,500’). Based on the statistical comparisons in the report, we made the following conclusions:
Students attending school near at least one active oil and gas well are 10.5% more likely to be Hispanic.
Students attending school near at least one active oil and gas well are 6.7% more likely to be a minority.
There are 61,612 students who attend school within 1 mile of a stimulated oil or gas well, and 12,362 students who attend school within 0.5 miles of a stimulated oil or gas well.
School districts with greater Hispanic and non-white student enrollment are more likely to house wells that have been hydraulically fractured.
Schools campuses with greater Hispanic and non-white student enrollment are more likely to be closer to more oil and gas wells and wells that have been hydraulically fractured.
Students attending school within 1 mile of oil and gas wells are predominantly non-white (79.6%), and 60.3% are Hispanic.
The top 11 school districts with the highest well counts are located the San Joaquin Valley with 10 districts in Kern County and the other just north of Kern in Fresno County.
The two districts with the highest well counts are in Kern County: Taft Union High School District, host to 33,155 oil and gas wells; and Kern Union High School District, host to 19,800 oil and gas wells.
Of the schools with the most wells within a 1 mile radius, 8/10 are located in Los Angeles County.
There are 485 active/new oil and gas wells within 1 mile of a school and 177 active/new oil and gas wells within 0.5 miles of a school. This does not include idle wells.
There are 352,784 students who attend school within 1 mile of an oil or gas well, and 121,903 student who attend school within 0.5 miles of an oil or gas well. This does not include idle wells
Permits
In collaboration with Consumer Watchdog,9 we counted permit applications that were approved in 2018 during Governor Brown’s administration, as well as in 2019 and 2020 under Governor Newsom. The analysis included permits for drilling new wells, well reworks, deepening wells and well sidetracks. Almost 10% of permits issued during the first two months of 2020 have been issued within 2,500’ of sensitive receptors including homes, hospitals, schools, daycares, and nursing facilities. This is slightly lower than the average for all approved permits in 2019 (12.2%). In 2018, Governor Brown approved 4,369 permits, of which 518 permits (about 12%) were granted within the proposed 2,500’ setback.
Conclusion
FracTracker Alliance’s body of work in California provides a summary of the population demographics of communities most impacted by oil and gas extraction. It is clear that communities of color in Los Angeles and Kern County make up the majority of Frontline Communities. New oil and gas wells are not permitted in equitable locations and setbacks from currently active oil and gas extraction sites are an environmental justice necessity. Putting a ban on new permits and shutting down existing wells located within 2,500’ of sensitive receptors such as schools, hospitals, and homes would have a very small impact on overall production of oil in California. It is clear that the public health and environmental equity benefits of a 2,500’ setback far outweigh any and all drawbacks. We hope that the resources summarized in this article provide a useful source of condensed information for those that feel similarly.
References
Hays J, Shonkoff SBC. 2016. Toward an Understanding of the Environmental and Public Health Impacts of Unconventional Natural Gas Development: A Categorical Assessment of the Peer-Reviewed Scientific Literature, 2009-2015. PLOS ONE 11(4): e0154164. https://doi.org/10.1371/journal.pone.0154164Ferrar, K.
COVID-19 and the oil and gas industry are at odds. Air pollution created by oil and gas activities make people more vulnerable to viruses like COVID-19. Simultaneously, the economic impact of the pandemic is posing major challenges to oil and gas companies that were already struggling to meet their bottom line. In responding to these challenges, will our elected leaders agree on a stimulus package that prioritizes people over profits?
Air pollution from oil and gas development can come from compressor stations, condensate tanks, construction activity, dehydrators, engines, fugitive emissions, pits, vehicles, and venting and flaring. The impact is so severe that for every three job years created by fracking in the Marcellus Shale, one year of life is lost due to increased exposure to pollution.
Yes, air quality has improved in certain areas of China and elsewhere due to decreased traffic during the COVID-19 pandemic. But despite our eagerness for good news, sightings of dolphins in Italian waterways does not mean that mother earth has forgiven us or “hit the reset button.”
Significant environmental health concerns persist, despite some improvements in air quality. During the 2003 SARS outbreak, which was caused by another coronavirus, patients from areas with the high levels of air pollution were twice as likely to die from SARS compared to those who lived in places with little pollution.
On March 8th, Stanford University environmental resource economist Marshall Burke looked at the impacts of air quality improvements under COVID-19, and offered this important caveat:
“It seems clearly incorrect and foolhardy to conclude that pandemics are good for health. Again I emphasize that the effects calculated above are just the health benefits of the air pollution changes, and do not account for the many other short- or long-term negative consequences of social and economic disruption on health or other outcomes; these harms could exceed any health benefits from reduced air pollution. But the calculation is perhaps a useful reminder of the often-hidden health consequences of the status quo, i.e. the substantial costs that our current way of doing things exacts on our health and livelihoods.”
This is an environmental justice issue. Higher levels of air pollution tend to be in communities with more poverty, people of color, and immigrants. Other health impacts related to oil and gas activities, from cancer to negative birth outcomes, compromise people’s health, making them more vulnerable to COVID-19. Plus, marginalized communities experience disproportionate barriers to healthcare as well as a heavier economic toll during city-wide lockdowns.
Financial Instability of the Oil & Gas Industry in the Face of COVID-19
The COVID-19 health crisis is setting off major changes in the oil and gas industry. The situation may thwart plans for additional petrochemical expansion and cause investors to turn away from fracking for good.
Persistent Negative Returns
Oil, gas, and petrochemical producers were facing financial uncertainties even before COVID-19 began to spread internationally. Now, the economics have never been worse.
In 2019, shale-focused oil and gas producers ended the year with net losses of $6.7 billion. This capped off the decade of the “shale revolution,” during which oil and gas companies spent $189 billion more on drilling and other capital expenses than they brought in through sales. This negative cash flow is a huge red flag for investors.
“North America’s shale industry has never succeeded in producing positive free cash flows for any full year since the practice of fracking became widespread.” IEEFA
Plummeting Prices
Shale companies in the United States produce more natural gas than they can sell, to the extent that they frequently resort to burning gas straight into the atmosphere. This oversupply drives down prices, a phenomenon that industry refers to as a “price glut.”
The oil-price war between Russia and Saudi Arabia has been taking a toll on oil and gas prices as well. Saudi Arabia plans to increase oil production by 2 – 3 million barrels per day in April, bringing the global total to 102 million barrels produced per day. But with the global COVID-19 lockdown, transportation has decreased considerably, and the world may only need 90 million barrels per day.
If you’ve taken Econ 101, you know that when production increases as demand decreases, prices plummet. Some analysts estimate that the price of oil will soon fall to as low as $5 per barrel, (compared to the OPEC+ intended price of $60 per barrel).
Corporate welfare vs. public health and safety
Oil and gas industry lobbyists have asked Congress forfinancial support in response to COVID-19. Two stimulus bills in both the House and Senate are currently competing for aid.
Speaker McConnell’s bill seeks to provide corporate welfare with a $415 billion fund. This would largely benefit industries like oil and gas, airlines, and cruise ships. Friends of the Earth gauged the potential bailout to the fracking industry at $26.287 billion. In another approach, the GOP Senate is seeking to raise oil prices by directly purchasing for the Strategic Petroleum Reserve, the nation’s emergency oil supply.
Speaker Pelosi’s proposed stimulus bill includes $250 billion in emergency funding with stricter conditions on corporate use, but doesn’t contain strong enough language to prevent a massive bailout to oil and gas companies.
Hopefully with public pressure, Democrats will take a firmer stance and push for economic stimulus to be directed to healthcare, paid sick leave, stronger unemployment insurance, free COVID-19 testing, and food security.
Grasping at straws
Fracking companies were struggling to stay afloat before COVID-19 even with generous government subsidies. It’s becoming very clear that the fracking boom is finally busting. In an attempt to make use of the oversupply of gas and win back investors, the petrochemical industry is expanding rapidly. There are currently plans for $164 billion of new infrastructure in the United States that would turn fracked natural gas into plastic.
The location of the proposed PTTGC Ethane Cracker in Belmont, Ohio. Go to this map.
There are several fundamental flaws with this plan. One is that the price of plastic is falling. A new report by the Institute for Energy Economics and Financial Analysis (IEEFA) states that the price of plastic today is 40% lower than industry projections in 2010-2013. This is around the time that plans started for a $5.7 billion petrochemical complex in Belmont County, Ohio. This would be the second major infrastructural addition to the planned petrochemical buildout in the Ohio River Valley, the first being the multi-billion dollar ethane cracker plant in Beaver County, Pennsylvania.
Secondly, there is more national and global competition than anticipated, both in supply and production. Natural gas and petrochemical companies have invested in infrastructure in an attempt to take advantage of cheap natural gas, creating an oversupply of plastic, again decreasing prices and revenue. Plus, governments around the world are banning single-use plastics, and McKinsey & Company estimates that up to 60% of plastic production could be based on reuse and recycling by 2050.
Sharp declines in feedstock prices do not lead to rising demand for petrochemical end products.
Third, oil and gas companies were overly optimistic in their projections of national economic growth. The IMF recently projected that GDP growth will slow down in China and the United States in the coming years. And this was before the historic drop in oil prices and the COVID-19 outbreak.
“The risks are becoming insurmountable. The price of plastics is sinking and the market is already oversupplied due to industry overbuilding and increased competition,” said Tom Sanzillo, IEEFA’s director of finance and author of the report.
Oil, gas, and petrochemical companies are facing perilous prospects from demand and supply sides. Increasing supply does not match up with decreasing demand, and as a result the price of oil and plastics are dropping quickly. Tens of thousands of oil and gas workers are being fired, and more than 200 oil and gas companies have filed for bankruptcy in North America in the past five years. Investors are no longer interested in propping up failing companies.
Natural gas accounts for 44% of electricity generation in the United States – more than any other source. Despite that, the cost per megawatt hour of electricity for renewable energy power plants is now cheaper than that of natural gas power plants. At this point, the economy is bound to move towards cleaner and more economically sustainable energy solutions.
It’s not always necessary or appropriate to find a “silver lining” in crises, and it’s wrong to celebrate reduced pollution or renewable energy achievements that come as the direct result of illness and death. Everyone’s first priority must be their health and the health of their community. Yet the pandemic has exposed fundamental flaws in our energy system, and given elected leaders a moment to pause and consider how we should move forward.
It is a pivotal moment in terms of global energy production. With determination, the United States can exercise the political willpower to prioritize people over profits– in this case, public health over fossil fuel companies.
Top photo of petrochemical activity in the Houston, Texas area. By Ted Auch, FracTracker Alliance. Aerial assistance provided by LightHawk.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/04/HoustonArea_feature.jpg8331875Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgShannon Smith2020-03-24 15:48:412020-04-01 09:56:09COVID-19 and the oil & gas industry
A recent study out of Carnegie Mellon University estimated that for every three job years created by fracking in the Marcellus Shale, one year of life is lost for a resident due to increased pollution exposure. As fracking continues to expand around the perimeter of Allegheny County, Pennsylvania — one of the top ten most polluted regions in the U.S. — we’re called to question how this industry is impacting the area’s already poor air quality. To answer this question, Southwest Pennsylvania Environmental Health Project (EHP), and FracTracker Alliance conducted a study on air quality around sites impacted by fracking development.
Over the course of this past year, we set up air monitors in seven communities in or near Allegheny County with current or proposed oil and gas infrastructure, with the goal of gathering baseline data and identifying possible public health concerns.
The sites in question are mapped and described below. Click on the arrow to scroll through maps of the different sites.
North Braddock: Merrion Oil and Gas has proposed a fracking well on the property of the Edgar Thomson Steel Works, near where North Braddock, East Pittsburgh, and North Versailles meet.
Plum Borough: Penneco has proposed to build a wastewater disposal well in Plum Borough. We placed three monitors at homes in areas where the air is likely to be impacted by construction and truck traffic should the wastewater disposal well be installed.
Economy Borough (Beaver County): We monitored around PennEnergy Resource’s B50 well pad, which recently began construction. Of particular concern to residents is the increase in truck traffic along a narrow road in a residential neighborhood that will be used to access the well pad.
Frazer Township: Monitoring took place around the Gulick, Schiller, and Bakerstown well pads.During their monitoring period, there was reported fracking activity on one well, and drilling activity on another.
Elizabeth Township: Monitoring occurred around three EQT and Olympus Energy fracked well pads listed as active; fracking reportedly occurred on one well pad during the monitoring period.
Indiana Township: Monitoring followed the construction of the Miller Jr. fracked well pad.
Stowe Township: Monitoring occurred in Stowe Township, where McKees Rocks Industrial Enterprise (MRIE) is located, and in adjacent McKees Rocks. This facility processes and transports frac sand, which operators use to frack a well by injecting it at extremely high pressures underground.
PM2.5 is a pollutant small enough to enter our lungs and bloodstream and therefore poses a great risk to human health.
The process of constructing, drilling and fracking a well releases a variety of pollutants, including particulate matter, volatile organic compounds (VOCs), and nitrous oxides (NOx).
Allegheny County has some of the worst air quality in the nation. In recent years, the air quality in the Pittsburgh metropolitan area, which had been improving since 2005, began to worsen. This is due in part to fracking activities.
There are 163 fracked wells that have been drilled in Allegheny County, all of which pose a threat to human health.
This initial air quality study by Southwest Environmental Health Project and FracTracker found that areas with proposed fracking sites are particularly vulnerable because they already have poor air quality.
Further investigations will need to monitor air quality throughout different stages of development and during different seasons in order to provide meaningful comparisons of changes in air quality that could be correlated with oil and gas development.
Allegheny’s air – from bad to worse
In recent years, the air quality in the Pittsburgh metropolitan area, which had been improving since 2005, began to worsen. According to the 2019 State of the Air report, levels of ozone and particle pollution increased over 2015-2017 (Figure 1).
This fact echoes a nationwide trend. Another study out of Carnegie Mellon University found that after several years of improvement, air pollution in the United States worsened in 2017 and 2018. The study cited several possible explanations, including increased natural gas production, more wildfires, and a rollback on Clean Air Act regulations by the EPA.
While Allegheny County’s air pollution is largely attributable to steel, coal, and chemical plants, in the last decade, the oil and gas industry has brought many new sources of pollution to the area.
As of December, 2019, operators have drilled 163 fracking wells in the county (Table 1) and constructed nine compressor stations. Additional pollution caused by the oil and gas industry is attributable to the thousands of truck trips required to frack a well.
Table 1. Fracked wells in Allegheny County by municipality
The fracking process releases emissions that can affect human health at every stage of its lifespan. Research has linked fracking to immediate health symptoms, such as burning eyes, sore throat, and headaches. Ongoing research has identified the potential for long term health impacts, such as cardiovascular disease and adverse birth outcomes.
Air pollution from the oil and gas industry does not impact everyone equally. An individual’s response to exposure varies depending on factors such as age and health conditions.
There is also a great deal of variation amongst wells and compressor stations when it comes to emissions. As such, the best way to understand someone’s exposure is to monitor the places they frequent, such as the home, school, or workplace.
Types of Pollutants
The process of drilling and fracking a well releases a variety of pollutants, including particulate matter, volatile organic compounds (VOCs), and nitrous oxides (NOx). Table 2, below, shows reported emissions from gas wells in Allegheny County for 2017.
Table 2. Reported emissions from Allegheny County gas wells in 2017, from the PA DEP
POLLUTANT
Emission Amount (Tons)
2,2,4-Trimethylpentane
0.00093
Benzene
0.10466
Carbon Dioxide
22982.68774
CO
66.20016
Ethyl Benzene
0.00053
Formaldehyde
0.02366
Methane
714.90485
n-Hexane
0.16083
Nitrous Oxide
0.2332
NOX
270.81382
PM10
8.87066
PM2.5
8.74341
SOX
0.23478
Toluene
0.04636
VOC
21.68682
Xylenes (Isomers And Mixture)
0.03487
Our study looked at particulate matter (PM) – a mix of solid particles and liquids found in the air, like dust, soot, and smoke. Specifically, the study focused on PM2.5, which are particles less than 2.5 microns in diameter (Figure 2). PM forms during construction activities, combustion processes such as those in diesel engines, and from industrial sites and facilities.
Fracking and its associated processes release hazardous chemicals into the air, which then attach to PM2.5. Additionally, combustion engines of trucks and machinery used to construct well sites and drill wells release diesel emissions, including PM2.5. Compressor stations and flaring are additional sources.
PM2.5 is small enough to enter our lungs and bloodstream and therefore poses a great risk to human health. Their health impacts include reduced lung function and cardiovascular disease, as well as short term effects such as sinus irritation.
Figure 2. Particulate matter diagram, from the US EPA
The monitors were placed at varying distances and directions from the facility in question, not exceeding 1.5 miles from the facility in question. We used Speck monitors indoors and Purple Air monitors outdoors; both types measured the concentration of particulate matter over roughly one month.
The EPA’s guideline for exposure to PM2.5 is 35 μg/m3 averaged over 24 hours. However, averaging exposure over 24 hours can obscure peaks- relatively short time spans of elevated PM2.5 concentrations. While it is normal for peaks to occur occasionally, high, long, or frequent peaks in pollution can affect people’s health, particularly with acute impacts such as asthma attacks.
Results
The graphs below show our results. On each graph, you’ll see three to five lines, one for each outdoor monitor. Lines that follow similar trends show data that is likely an accurate representation of air quality in the community. Lines that stray from the pack may represent a unique situation that only that house is experiencing.
In addition to graphing the results, EHP used the following parameters to analyze the data:
Frequency of peaks
Duration of peaks
Time between peak exposures
Baseline (level of particles generally found outside when peaks are not occurring)
Total sum (or quantity) of peak exposure
These five parameters were compared to EHP’s data gathered from roughly 400 sites in Ohio, West Virginia, New York, and Pennsylvania. This database compiles air quality data from locations that have no infrastructure present as well as nearby sites such as well pads, compressor stations, frac-sand terminals, processing facilities, etc.
In the table below, numbers in green indicate values that are better than EHP’s averages, while red values show values that are worse than the average of EHP’s dataset. Black numbers show values that are average.
Table 3. EHP/FracTracker sites of air quality investigation in Allegheny County
*The proposed well is near the intersection of East Pittsburgh, North Braddock, and North Versailles
**Monitors were also placed in neighboring McKees Rocks
~In homes where baseline levels of PM2.5 are low, such as in Frazer and Economy, peaks are more easily registered in our analysis, but they typically have a smaller magnitude compared to homes that have high baselines.
Discussion
Communities with proposed sites
In North Braddock and Plum Borough, the outdoor air monitors collected data around sites of future and/or proposed activity. This baseline monitoring helps us understand what the air is like before oil and gas activity and is essential for understanding the future impact of oil and gas development in a community.
In these neighborhoods, we found worse than average values for total accumulation of PM2.5. This may be due to other patterns of PM2.5 movement in the area related to weather and surrounding sources of pollution. North Braddock is an urban environment, and therefore has pollution from traffic and buildings. Another source is the Edgar Thomson Steel Works, one of the county’s top polluters. While Plum Borough is more rural, it also contains an active fracking well pad and is near a coal-fired power plant and a gas power plant.
If constructed, the proposed fracking well and the proposed wastewater disposal well will add additional pollution from construction, truck traffic, and in North Braddock’s case, emissions from the well itself. This may pose a significant health risk, especially in vulnerable populations like children and those with preexisting health conditions.
Communities with constructed well pads
Emissions vary across the timeline of drilling and fracking a well. Figure 2 below shows reported emissions of PM2.5 and VOCs from different components of a fracking operation. PM2.5 emissions are highest during drilling (when the well bore is formed) and completion (when the well is fracked by injecting high volumes of water, sand, and chemicals at tremendous pressure). For a step by step outline of the fracking process, check out FracTracker’s fracking operation virtual tour.
Figure 2. 2017 emissions from Allegheny County gas wells at different stages in the fracking process, reported to the PA DEP
Our monitoring in Economy Borough, where construction on PennEnergy Resources’ B50 well pad had just begun, showed air quality that is better than EHP’s averages. However, if the wells on the well pad are drilled and fracked, EHP hopes to provide monitors again to track changes in air quality. In addition to emissions from the fracking well, which is close to the Chestnut Ridge housing development, residents are concerned about truck traffic along Amsler Ridge Road.
In Indiana, while residents reported truck traffic to the site, the wells were not fracked during the monitoring period. The measurements were average or slightly above the average EHP typically sees near homes. Looking at these results, peak duration was flagged, and the total sum of particulate matter was slightly elevated compared to our average suggesting that the long durations may ignite a health response in sensitive individuals. Other sources that could be contributing to pollution include the PA Turnpike and the Redland Brick manufacturer.
In Frazer, there was reported fracking activity on one well and drilling activity on another; these time periods were only slightly elevated on the hourly average charts. Monitors were left at two households in Frazer because there was an indication that fracking would start soon.
In Elizabeth Township, air quality measurements were generally better compared to the rest of EHP’s data, but there were clear peaks that all monitors registered which generated a similar, if not potentially higher, amounts of accumulated PM2.5.
Frac sand facility
Finally, monitors around MRIE, the frac sand processing facility in Stowe Township, showed air quality that may pose a health risk. The peaks in these neighborhoods generated a higher amount of accumulated PM2.5 and lasted longer compared to the rest of our data. In addition to pollution from MRIE and its associated trucks and trains, the neighborhood has many sources of pollution, including highways and industrial facilities on Neville Island.
Limitations
This study is limited in that PM2.5 was the only pollutant that the Purple Air and Speck monitors captured. To understand the complete burden of air pollution residents are exposed to, other pollutants such as VOCs, must be monitored.
Additionally, monitoring occurred over a short time period. Further investigations will need to monitor air quality throughout different stages of development and during different seasons in order to provide meaningful comparisons of changes in air quality that could be correlated with oil and gas development. EHP will continue to monitor around certain active sites to watch for changes in the data.
Get Involved
If you’re concerned about health or environmental impacts from a well in your neighborhood, make sure to document the issue by taking notes, photos, and videos, and file a complaint with the state’s Department of Environmental Protection. To report an environmental health concern, reach out to the Department of Health by phone at 1-877 PA Health (1-877-724-32584) or email (RA-DHENVHEALTH@pa.gov). If you’re an employer or worker and have health or safety concerns, reach out to your area’s OSHA office or call 1-800-321-OSHA (6742).
While cleaning up the air in your community is difficult, there are steps you can take to protect the air in your home. With the average American spending 90% of their time indoors, the air inside can greatly impact your health. For this project, we also set up air monitors in residents’ homes so participants could better understand these risks. Visit EHP’s resources under the section “What You Can Do” to learn more about protecting your indoor air quality. To learn more about how fracking is impacting residents in southwest Pennsylvania, explore the Environmental Health Channel.
Finally, help us crowdsource new data on the impacts and status of oil and gas development in your community by reporting what you see, hear, smell, and question on the FracTracker mobile app (also available from your computer!). Those living near oil and gas infrastructure are the best source of knowledge when it comes to understanding the impacts of this industry. With your help, we want to make sure all of these impacts are being documented to inform decision makers and residents about the risks of fracking.
Many thanks to the Southwest Environmental Health Project for including us as collaborators on this study.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/12/drilling-rig.jpg16673750Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgErica Jackson2019-12-18 10:56:062020-03-13 13:43:56Allegheny County Air Quality Monitoring Project
Pennsylvania’s fracking industry is producing record amounts of toxic waste — where does it all go?
Drilling for methane and other fossil fuels is an energy-intensive process with many associated environmental costs. In addition to the gas that is produced through high volume hydraulic fracturing (“unconventional drilling,” or “fracking”), the process generates a great deal of waste at the drill site. These waste products may include several dozen tons of drill cutting at every well that is directionally drilled, in addition to liner materials, contaminated soil, fracking fluid, and other substances that must be removed from the site.
In 2018, Pennsylvania’s oil and gas industry (including both unconventional and conventional wells) produced over 2.9 billion gallons (nearly 69 million barrels) of liquid waste, and 1,442,465 tons of solid waste. In this article, we take a look at where this waste (and its toxic components) end up and how waste values have changed in recent years. We also explore how New York State, despite its reputation for being anti-fracking, isn’t exempt from the toxic legacy of this industry.
Waste that comes back to haunt us
According to a study by Physicians, Scientists and Engineers, over 80% of all waste from oil and gas drilling stays within the state of Pennsylvania. But once drilling wastes are sent to landfills, is that the end of them? Absolutely not!
Drilling waste also gets into the environment through secondary means. According to a recent report by investigative journalists at Public Herald, on average, 800,000 tons of fracking waste from Pennsylvania is sent to Pennsylvania landfills. When this waste is sent to landfills, radioactivity and other chemicals can percolate through the landfill, and are collected as leachate, which is then shipped to treatment plants.
Public Herald documented how fourteen sewage treatment plants in Pennsylvania have been permitted by Pennsylvania’s Department of Environmental Protection (PA DEP) to process and discharge radioactive wastes into more than a dozen Pennsylvania waterways.
Public Herald’s article includes an in-depth analysis of the issue. Their work is supported by a map of the discharge sites, created by FracTracker.
Trends over time
Pennsylvania Department of Environmental Protection maintains a rich database of oil and gas waste and production records associated with their Oil and Gas Reporting Website. The changes in waste disposal from Pennsylvania’s unconventional drilling reveal a number of interesting stories.
Let’s look first at overall unconventional drilling waste.
According to data from the federal Energy Information Administration, gas production in Pennsylvania began a steep increase around 2010, with the implementation of high volume hydraulic fracturing in the Marcellus Shale (see Figure 1). The long lateral drilling techniques allowed industry to exploit exponentially more of the tight shale via single well than was ever before possible with conventional, vertical drilling.
Figure 1. Data summary from FracTracker.org, based on EIA data.
The more recently an individual well is drilled, the more robust the production. We see an overall increase in gas production over time in Pennsylvania over the past decade. Paradoxically, the actual number of new wells drilled each year in the past 4-5 years are less than half of the number drilled in 2011 (see Figure 2).
Figure 2: Data summary from FracTracker.org, based on PA DEP data
Why is this? The longer laterals —some approaching 3 miles or more—associated with new wells allow for more gas to be extracted per site.
With this uptick in gas production values from the Marcellus and Utica Formations come more waste products, including copious amounts drilling waste, “produced water,” and other byproducts of intensive industrial operations across PA’s Northern Tier and southwestern counties.
Comparing apples and oranges?
When we look at the available gas production data compared with data on waste products from the extraction process, some trends emerge. First of all, it’s readily apparent that waste production does not track directly with gas production in a way one would expect.
Recall that dry gas production has increased annually since 2006 (see Figure 1). However, the reported waste quantities from industry have not followed that same trend.
In the following charts, we’ve split out waste from unconventional drilling by solid waste in tons (Figure 3) and liquid waste, in barrels (Figure 4).
Figure 3: Annual tonnage of solid waste from the unconventional oil and gas industry, organized by the state it is disposed in. Data source: PA DEP, processed by FracTracker Alliance
Figure 4: Annual volume of liquid waste from the unconventional oil and gas development, organized by state it is disposed in. One barrel is equivalent to 42 gallons. Data source: PA DEP, processed by FracTracker Alliance
Note the striking difference in disposal information for solid waste, compared with liquid waste, coming from Pennsylvania.
“Disposal Location Unknown”
Until just the last year, often more than 50% of the known liquid waste generated in PA was disposed of at unknown locations. The PA DEP waste report lists waste quantity and method for these unknown sites,depending on the year: “Reuse without processing at a permitted facility,” “Reuse for hydraulic fracturing,” “Reuse for diagnostic purposes,” “Reuse for drilling or recovery,” “Reuse for enhanced recovery,” and exclusively in more recent years (2014-2016), “Reuse other than road-spreading.”
In 2011, of the 20.5 million barrels of liquid waste generated from unconventional drilling, about 56% was allegedly reused on other drilling sites. However, over 9 million barrels—or 44% of all liquid waste—were not identified with a final destination or disposal method. Identified liquid waste disposal locations included “Centralized treatment plant for recycle,” which received about a third of the non-solid waste products.
In 2012, the quantity of the unaccounted-for fracking fluid waste dropped to about 40%. By 2013, the percentage of unaccounted waste coming from fracking fluid dropped to just over 21%, with nearly 75% coming from produced fluid, which is briny, but containing fewer “proprietary”—typically undisclosed—chemicals.
By 2017, accounting had tightened up further. PA DEP data show that 99% of all waste delivered to undisclosed locations was produced fluid shipped to locations outside of Pennsylvania. By 2018, all waste disposal was fully accounted for, according to DEP’s records.
In looking more closely at the data, we see that:
Prior to 2018, well drillers did not consistently report the locations at which produced water was disposed of or reused. Between 2012 and 2016, a greater volume of unconventional liquid waste went unaccounted for than was listed for disposal in all other locations, combined.
In Ohio, injection wells, where liquid waste is injected into underground porous rock formations, accounted for the majority of the increase in waste accepted there: 2.9 million barrels in 2017, and 5.7 million barrels in 2018 (a jump of 97%).
West Virginia’s acceptance of liquid waste increased significantly in 2018 over 2017 levels, a jump of over a million barrels, up from only 55,000. This was almost entirely due to unreported reuse at well pads.
In 2018, reporting, in general, appears to be more thorough than it was in previous years. For example, in 2017, nearly 692,000 barrels of waste were reused at well pads outside PA, but those locations were not disclosed. Almost 7000 more barrels were also disposed of at unknown locations. In 2018, there were no such ambiguities.
A closer look at Pennsylvania’s fracking waste shipped to New York State
Despite a reputation for being resistant to the fracking industry, for most of this decade, the state of New York has been accepting considerable amounts of fracking waste from Pennsylvania. The greatest percentage shipped to New York State is in the form of drilling waste solids that go to a variety of landfills throughout Central and Western New York.
Looking closely at the bar charts above, it’s easy to notice that the biggest recipients of Pennsylvania’s unconventional liquid drilling waste are Pennsylvania itself, Ohio, as well as a significant quantity of unaccounted-for barrels between 2011 and 2016 (“Disposal location unknown”). The data for disposal of solid waste in New York tells a different story, however. In this case, Pennsylvania, Ohio, and New York State all play a role. We’ll take a look specifically at the story of New York, and illustrate the data in the interactive map that follows.
In this map, source locations in Pennsylvania are symbolized with the same color marker as the facility in New York that received the waste from the originating well pad. In the “Full Screen” view, use the “Layers” drop down menu to turn on and off data from separate years.
From the early days of unconventional drilling in Pennsylvania, New York State’s landfills provided convenient disposal sites due to their proximity to the unconventional drilling occurring in Pennsylvania’s Northern tier of counties. Pennsylvania and Ohio took the majority of solid wastes from unconventional drilling waste from Pennsylvania. New York State, particularly between 2011-2015, was impacted far more heavily than all other states, combined (Figure 5, below).
Figure 5: Known disposal locations (excluding PA and OH) of Pennsylvania’s solid waste. Data source: PA DEP, processed by FracTracker Alliance
Here’s the breakdown of locations in New York to where waste was sent. Solid waste disposal into New York’s landfills also dropped by half, following the state’s ban on unconventional drilling in 2014. Most of the waste after 2012 went to the Chemung County Landfill in Lowman, New York, 10 miles southeast of Elmira.
Figure 6: Solid waste from unconventional drilling, sent to facilities in NYS. Data source: PA DEP, processed by FracTracker Alliance
Is waste immobilized once it’s landfilled?
The fate of New York State’s landfill leachate that originates from unconventional drilling waste is a core concern, since landfill waste is not inert. If drilling waste contains radioactivity, fracking chemicals, and heavy metals that percolate through the landfill, and the resulting leachate is sent to municipal wastewater treatment plants, will traditional water treatment methods remove those wastes? If not, what will be the impact on public and environmental health in the water body that receives the “treated” wastewater? In Pennsylvania, for example, a case is currently under investigation relating to pollution discharges into the Monongahela River near Pittsburgh. “That water was contaminated with diesel fuels, it’s alleged, carcinogens and other pollutants,” said Rich Bower, Fayette County District Attorney.
Currently, a controversial expansion of the Hakes Landfill in Painted Post, New York is in the news. Sierra Club and others were concerned about oversight of radium and radon in the landfill’s leachate and air emissions, presumably stemming from years of receiving drill cuttings. The leachate from the landfill is sent to the Bath Wastewater Treatment plant, which is not equipped to remove radioactivity. “Treated” wastewater from the plant is then discharged into the Cohocton River, a tributary of the Chesapeake Bay. In April 2019, these environmental groups filed a law suit against Hakes C&D Landfill and the Town of Campbell, New York, in an effort to block the expansion.
Similar levels of radioactivity in leachate have also been noted in leachate produced at the Chemung County Landfill, according to Gary McCaslin, President of People for a Healthy Environment, Inc.
In recent years, much of the solid unconventional waste arriving in New York State has gone to the Chemung County Landfill (see Figure 6, above). Over the course of several years, this site requested permission to expand significantly from 180,000 tons per year to 417,000 tons per year. However, by 2016, the expansion was deemed unnecessary, and according, the plans were put on hold, in part “…because of a decline in the amount of waste being generated due to a slower economy and more recycling than when the expansion was first planned years ago.” The data in Figure 5 above also parallel this story, with unconventional drilling waste disposed in New York State dropping from over 200,000 tons in 2011 to just over 20,000 tons in 2018.
Liquid waste transported to New York State
The story about liquid unconventional drilling waste exported from Pennsylvania to states other than Ohio is not completely clear (see Figure 7, below). Note that the data indicate more than a 2000% increase in waste liquids going from Pennsylvania to West Virginia after 2017. While it has not been officially documented, FracTracker has been anecdotally informed that a great deal of waste was already going to West Virginia, but that the record-keeping prior to 2018 was simply not strongly enforced.
Figure 7: Known disposal locations (excluding Pennsylvania and Ohio) of Pennsylvania’s liquid waste. Data source: PA DEP, processed by FracTracker Alliance
Beginning in the very early years of the Pennsylvania unconventional fracking boom, a variety of landfills in New York State have also accepted liquid wastes originating in Pennsylvania, including produced water and flowback fluids (see Figure 8, below).
Figure 8: Liquid waste from unconventional drilling, sent to facilities in New York State. Data source: PA DEP, processed by FracTracker Alliance
In addition, while this information doesn’t even appear in the PA DEP records (which are publicly available back to 2010), numerous wastewater treatment plants did accept some quantity, despite being fully unequipped to process the highly saline waste before it was discharged back into the environment.
One such facility was the wastewater treatment plant in Cayuga Heights, Tompkins County, which accepted more than 3 million gallons in 2008. Another was the wastewater treatment plant in Auburn, Cayuga County, where the practice of accepting drilling wastewater was initially banned in July 2011, but the decision was reversed in March 2012 to accept vertical drilling waste, despite strong public dissent. Another wastewater treatment plant in Watertown, Jefferson County, accepted 35,000 gallons in 2009.
Fortunately, most New York State wastewater treatment plant operators were wise enough to not even consider adding a brew of unknown and/or proprietary chemicals to their wastewater treatment stream. Numerous municipalities and several counties banned fracking waste, and once the ban on fracking in New York State was instituted in 2014, nearly all importation of liquid unconventional drilling waste into the state ceased.
Nevertheless, conventional, or vertical well drilling also generates briny produced water, which the New York State Department of Environmental Conservation (DEC) permits communities in New York to accept for ice and dust control on largely rural roads. These so-called “beneficial use determinations” (BUDs) of liquid drilling waste have changed significantly over the past several years. During the height of the Marcellus drilling in around 2011, all sorts of liquid waste was permitted into New York State (see FracTracker’s map of affected areas) and was spread on roads. As a result, the chemicals—many of them proprietary, of unknown constituents, or radioactive—were indirectly discharged into surface waters via roadspreading.
Overall, in the years after the ban in 2014 on high volume hydraulic fracturing was implemented, restrictions on Marcellus waste coming into New York have strengthened. Very little liquid waste entered New York’s landfills after 2013, and what did come in was sent to a holding facility owned by Environmental Services of Vermont. This facility is located outside Syracuse, New York.
New York State says “no” to this toxic legacy
Fortunately, not long after these issues of fracking fluid disposal at wastewater treatment facilities in New York State came to light, the practice was terminated on a local level. The 2014 ban on fracking in New York State officially prevented the disposal of Marcellus fluids in municipal wastewater treatment facilities and required extra permits if it were to be road-spread.
In New York State, the State Senate—after 8 years of deadlock—in early May 2019, passed key legislation that would close a loophole that had previously allowed dangerous oil and gas waste to bypass hazardous waste regulation. Read the press release from Senator Rachel May’s office here. However, despite strong support from both the Senate, and the Assembly, as well as many key environmental groups, the Legislature adjourned for the 2019 session without bringing the law to a final vote. Said Elizabeth Moran, of the New York Public Interest Research Group (NYPIRG), “I want to believe it was primarily a question of timing… Sadly, a dangerous practice is now going to continue for at least another year.”
See Earthworks’ recent three part in-depth reporting on national, New York, and Pennsylvania oil and gas waste, with mapping support by FracTracker Alliance.
All part of the big picture
As long as hydrocarbon extraction continues, the issues of waste disposal—in addition to carbon increases in the atmosphere from combustion and leakage—will result in impacts on human and environmental health. Communities downstream and downwind will bear the brunt of landfill expansions, water contamination, and air pollution. Impacts of climate chaos will be felt globally, with the greatest impacts at low latitudes and in the Arctic.
Transitioning to net-zero carbon emissions cannot be a gradual endeavor. Science has shown that in order to stay under the 1.5 °C warming targets, it must happen now, and it requires the governmental buy-in to the Paris Climate Agreement by every economic power in the world.
No exceptions. Life on our planet requires it.
We have, at most, 12 years to make a difference for generations to come.
Guest Blog by Josh Eisenfeld, Director of Marketing with Fair Shake Environmental Legal Services
Fair Shake Environmental Legal Services looks maps the origin of their intake calls and reflects on their geographic distribution as it relates to areas with heavy environmental burdens.
Over the last five years, Fair Shake Environmental Legal Services has worked in Ohio and Pennsylvania to promote environmental justice by providing legal services at income-based rates. Our service area has a long history of extraction, from timbering, conventional drilling for oil, multiple forms of mining, and unconventional drilling for natural gas. Because of our proximity to these resources, we also have a long history of industrial manufacturing, which can be evidenced by the many oil refineries, steel production facilities, power plants, cement factories, factory farms, and chemical production facilities. Fair Shake offers counsel and representation in environmental law with accessible, sliding scale fees, and we receive a continuous stream of phone calls from those on the front lines. We were curious to see if our intake calls correlated with geographic areas with heavy environmental burdens in order to allocate our limited resources to those regions most efficiently.
With the help of Ted Auch from FracTracker Alliance we collected zip codes from nearly 600 of intake calls received by Fair Shake and placed them on the map below.
In general, our intakes in Pennsylvania mirror the Marcellus Shale formation. Over the last decade and a half, technical advancements in drilling have transformed the Marcellus Shale formation from a nonproducing region to the largest producing natural gas formation by volume in the world. Entering 2005, only 13 “unconventional” wells had been drilled in the Marcellus Shale region of Pennsylvania, where today there are roughly 12,000 wells according to FracTracker’s PA Shale Viewer Map. Reduced regulations for unconventional drilling and infrastructure have facilitated this rush for production, resulting in an influx of compressor stations, gathering lines, pump stations, processing plants, wastewater impoundments, wastewater treatment facilities, wastewater injection wells, and more.
We believe that this map indicates that these 12,000 wells place a significant burden on residents living within this region. Speaking broadly, reduced regulation has left loopholes in major environmental laws that have to get justice when their rights have been violated and, even more concerning, when harm has occurred.
One of the most prominent manifestations of this burden is the contamination of private drinking water sources near drilling and wastewater sites. Our region’s history of extraction and industrial enterprise and the pollution associated with these industries makes it extremely difficult to prove, in court, that drilling activity is the sole cause of damage to private wells. The fact is that our groundwater (and therefore private drinking wells) has been contaminated over and over again. Polluters use this to their advantage, leaning on the uncertainty of what caused the contaminants in question to get there. Simply put, water contamination is not a question of whether contaminants exist (they do) it’s a question of how can you prove that it was a given industry when there are many other possible culprits.
One thing we do know is that the number of reports for well contamination has increased in conjunction with the increase in drilling activity. The graph below, created by FracTracker and The Public Herald, shows the correlation of wells drilled, complaints to the Department of Environmental Protection, and complaints specifically about water.
Upon closer examination of the intake map, we saw a higher density of cases in more populated areas of Allegheny County, which actually has very little fracking activity (less than 170 drilled wells). But Allegheny is also one of the most polluted counties in America. The American Lung Association gave the county all F’s on its air quality and ranked it as 7th worst air quality in the nation according to the association’s state of the air. Allegheny County is also home to two of the most polluted rivers in our country: the Monongahela and the Ohio. Over a century of industrial activity and coal mining have impaired the water but most recently sewer overflows from the city of Pittsburgh have sent dangerous levels of raw sewage into the surrounding waterways.
The population density combined with the very poor air and water quality could be the explanation for the anomaly. Furthermore, Allegheny County is also where our Pittsburgh office is located, which is perhaps the reason that we see so many cases in this region and not in other regions of high population density such as Philadelphia, Harrisburg, or Scranton.
When we started this project, we thought we would discover a correlation between intakes and regions with the heaviest environmental burdens. This could allow us to allocate our limited resources to those regions most efficiently. Unfortunately, the problem is not so simple.
As evidenced by the intake map, resource extraction in Ohio and Pennsylvania is spread over a very large area. That is troubling because the bigger the problem geographically the harder it becomes to deal with. We need to devote far more resources to protecting individuals who face spills, emissions, erosion, impacts to wetland, etc. By speaking more openly about how pervasive these environmental risks are, and how that risk plays into the bigger picture of the climate emergency, we hope we can incite folks to give their time, effort, and resources to defending their health and environment.
By Josh Eisenfeld, Marketing Director at Fair Shake Environmental Legal Services
Records Show Widespread Use of Secret Fracking Chemicals Poses Risks to Water Supplies, Health in the Buckeye State
Photo from the U.S. Environmental Protection Agency showing a fire on June 28-29, 2014 at the Eisenbarth Well operated by Statoil in Monroe County, Ohio. The photographer is not listed.[i]
Ohio’s Secret Fracking Chemicals:
Records Show Widespread Use of Secret Fracking Chemicals Poses Risks to Water Supplies, Health in the Buckeye State
A Research Report by Dusty Horwitt, J.D.
Partnership for Policy Integrity
September 16, 2019
This report, by Partnership for Policy Integrity, with mapping and data analysis by FracTracker Alliance, shows that Ohioans may be unknowingly exposed to toxic secret drilling and fracking chemicals through multiple pathways including leaks, spills, air emissions and underground migration at oil and gas production wells.
Evidence compiled by the U.S. Environmental Protection Agency (EPA) including data released in response to a Freedom of Information Act request indicate that these chemicals could have serious health effects including blood toxicity, developmental toxicity, liver toxicity and neurotoxicity.
Click on this link to jump to the Call to Action section of this page
On this page, you can read the report, use the interactive map to locate oil and gas wells fracked with secret chemicals, and write a letter of concern to first responders in your Ohio county.
average number of gallons used to frack a single well (2018)
70000
fish died after tens of thousands of gallons of chemicals spilled into a tributary from a natural gas well in Monroe County (2014)
Take Action
If you are concerned about the findings presented in the Ohio’s Secret Fracking Chemicals report, please consider taking action today. Multiple first responders, and grassroots organizations working on environmental and public health issues in Ohio ask that you complete the form below to send a letter to first responders in your county. If you do not live in Ohio, your letter will be sent to first responders Franklin County, Ohio.
Halt the Harm Network and FracTracker Alliance will send a paper copy of your letter to the appropriate first responder location(s). See below for a map of these locations by Ohio county.
EXAMPLE LETTER
You may compose your own letter or use the example letter below as a guide.
Take Action
If you are concerned about the findings presented in the Ohio’s Secret Fracking Chemicals report, please consider taking action today. Multiple first responders, and grassroots organizations working on environmental and public health issues in Ohio ask that you complete the form below to send a letter to first responders in your county. If you do not live in Ohio, your letter will be sent to first responders in Franklin County, Ohio.
Halt the Harm Network and FracTracker Alliance will send a paper copy of your letter to the appropriate first responder location(s). See below for a map of these locations by Ohio county.
EXAMPLE LETTER
You may compose your own letter or use the example letter below as a guide.
Dear Chief,
Thanks to you and all first responders for your selfless acts of service. I am reaching out because I am concerned that there are dangerous chemicals being used at fracking sites in our county and across the county. Because the identity of many of these chemicals are kept secret, any spills or accidents present a significant risk to you as a first responder as well as to the public.
The report “Ohio’s Secret Fracking Chemicals” provides research about secret fracking chemicals and maps of oil and gas wells where secret fracking chemicals were used. The report’s author also interviewed Silverio Caggiano, Battalion Chief with the Youngstown Fire Department and an original member of the Ohio Hazardous Materials and Weapons of Mass Destruction Technical Advisory Committee. The Chief, the data, and the stories paint a clear picture of Ohio’s exposure to a mix of dangerous chemicals, lack of equipment, lack of training, and inadequate information. This failure by the State and other authorities creates risks for your first responders and all of us in the community.
Please join us in the fight against secret chemicals in our community by calling for the following measures to be put in place:
Require full public disclosure of drilling and fracking chemicals in one location where information can be easily searched and sorted (e.g. citizens can locate each well in which toxic chemicals were used).
Require disclosure before drilling and fracking occurs.
Require that no Class II wells for underground fracking wastewater disposal be permitted in Ohio unless disposal companies report all of the following in their permit requests: A) Average and Maximum Volumes, B) Average and Maximum wellhead pressures, C) Groundwater/water source and rate of withdrawal, D) Egress
Require testing of groundwater and well water for a representative number of homes within 2 miles of oil and gas wells and underground injection wells by impartial third parties to guard against migration of toxic chemicals. Data should be collected monthly.
Grant communities the power to determine where, and under what conditions, drilling and fracking occur.
Demand companies that operate underground fracking wastewater injection wells pay for independent third parties to conduct groundwater monitoring and data collection about health impacts.
Require that all haulers transporting fracking wastewater, also known as brine, permitted to operate in Ohio maintain complete manifests for every truck and maintain GPS tracking for all routes into and out of the state as well as across state lines.
Require all brine haulers report the number of trucks in operation and how they go about cleaning each truck on a quarterly basis.
Require that all brine haulers list where they maintain truck yards in addition to where they are domiciled.
Require that all waste landfills in Ohio collect detailed manifest on tonnage of drill cuttings coming into their facilities, source by company and well API, and that all waste be tested for radioactivity level that the level shall not exceed 1-2 picocuries per gram.
You have my full support in requests for this information. It is important to all of us. Please let me know if you have seen the report, reviewed the chemicals, and have appropriate response, training, and equipment in place.
Sincerely,
By signing, you accept Halt the Harm Network’s Terms of Service and agree to receive occasional emails following up on your letter, about Ohio fracking, and related public health campaigns. Your information will never be sold. You can unsubscribe at any time.
Photograph of the Eisenbarth well site is from the U.S. Environmental Protection Agency. The photographer is not listed.[ii]
[i] U.S. Environmental Protection Agency. On Scene Coordinator. Eisenbarth Well Response. Fire Damage on Eisenbarth Well Pad (June 29, 2014). Accessed September 2, 2019 at https://response.epa.gov/site/image_zoom.aspx?site_id=9350&counter=221854&category=.
“The Iroquois…called Pine Creek ‘Tiadaghton’ meaning either ‘The River of Pines’ or ‘The Lost or Bewildered River’.”[i] The river’s iconic watershed in North Central Pennsylvania spans 979 square miles, spanning parts of Clinton, Lycoming, Potter, and Tioga counties, and an infamous 47-mile gorge through which the Pine Creek flows. At 87 miles in length, it is the largest tributary to the West Branch Susquehanna River.[ii]
In 1964, Congress included Pine Creek as one of 27 rivers under study for inclusion in the National Wild and Scenic River System.[iii] Four years later, the US Department of the Interior designated twelve miles of the canyon a National Natural Landmark. In 1992, Pine Creek was recognized as a Pennsylvania Scenic River.[iv] These accolades underscore its vibrant beauty, ecological value, and cultural significance.
A rugged landscape carved into the Allegheny Plateau, the watershed contains extensive public lands and the highest concentrations of exceptional value (EV) and high quality (HQ) streams anywhere in Pennsylvania. It is a prized recreational attraction in the region known as the Pennsylvania Wilds, a destination for nature-based tourism. The area has endured episodes of resource extraction – logging, coal mining, and shallow gas development – but nothing quite the same as the assault from hundreds of new unconventional gas wells and the sprawling pads, pipelines, impoundments, compressor stations, and access roads accompanying such development.
Modern extraction is heavy industry – loud, dusty, and dirty. It is incongruent with the thick forests, sensitive habitats, hushed solitude, and star-drenched skies one expects to experience in many wilderness pursuits. Threats to air, water, and wildlife are manifest. Landscape fragmentation and forest loss are collateral damage. Ecological impacts, while sometimes immediate, are often insidious as they slowly degrade environmental health over time. The Oil and Gas Program of the Pennsylvania Department of Conservation and Natural Resources (DCNR) acknowledged in a 2012 presentation: “…that Marcellus Shale will be a long-term influence on the character of Pennsylvania landscapes.”[v] To what extent remains to be determined.
Writer and conservationist Samuel P. Hayes noted “The Pennsylvania Administrative Code of 1929 identified watershed protection as the primary purpose of the state forests.”[vi] Enduring more than 10 years of fracking history, and with more planned, the Pine Creek watershed is an experiment for this tenent and overdue for the geospatial examination that follows.
According to the NOAA, a watershed is a land area that channels rainfall and snowmelt to creeks, streams, and rivers, and eventually to outflow points such as reservoirs, bays, and the ocean.
Use the time slider below to explore the changes in the Pine Creek watershed from 2008 to 2016
CONTENTS
click on the section title to jump to that section
Humans have left their mark on Pine Creek for thousands of years, but the effects of timber and fossil fuel extraction in the last 220 years are most notable. Historical accounts and agency records provide substantial documentation of these impacts.
TIMBER
In 1799, Pine Creek’s first sawmill was set up near the confluence with Little Pine Creek. By 1810, eleven saw mills were in operation. In the next 30 years, that number rose to 145. Pine Creek earned the moniker of “Lumber Capital of the World,” but by the end of the Civil War, the great pine forests along Pine Creek were depleted due to clearcutting. By the end of the Civil War, the great pine forests along Pine Creek were depleted. Underappreciated for lumber, eastern hemlocks remained, but were eventually felled as well, their bark prized for tanning leather. The advent of logging railroads accelerated the forest’s demise. By the first years of the 20th century, the trees were all but gone, “…branches and stumps littered the mountainsides and sparks from locomotives created fires of holocaustal proportions.”[vii]
Sadly, much of the wildlife was gone too. Bounties, market hunting, and habitat loss had taken a toll. The area’s last timber wolf was killed in 1875. The beaver, otter, fisher, martin, lynx, and wolverine were exterminated by the early 1900s. The remaining solitary panthers lasted until the 1930s, then “faded into oblivion.”[viii]
COAL
While not often thought of as a part of Pennsylvania’s coal country, the Pine Creek Watershed has seen its share of coal mining and related activity. Coal was first discovered along the Babb Creek portion of the watershed in 1782, and mining operations began in earnest in the 1860s. By 1990, the area was so impacted by mine drainage and other pollution that there were no fish found in Babb Creek. Efforts to rehabilitate the stream have made some progress, raising the pH of the stream and restoring fish populations, to the point where Babb Creek was officially removed from the list of impaired streams in 2016.
Within the watershed’s abandoned mine areas, 68 specific sites totaling nearly 500 acres are flagged as “containing public health, safety, and public welfare problems created by past coal mining.” This represents more than 11% of the total mined area. Only five of these 68 sites – all strip mines – have completed the reclamation process.
Table 1. Problematic coal mine areas in the Pine Creek Watershed
SITE TYPE
ABANDONED
RECLAMATION COMPLETE
TOTAL FACILITIES
TOTAL ACRES
Dry Strip Mine
31
5
36
322.0
Flooded Strip Mine
2
–
2
1.7
Spoil Pile
13
–
13
148.4
Refuse Pile
12
–
12
23.2
Known Subsidence Prone Area
2
–
2
0.4
Coal Processing Settling Basin
3
–
3
1.5
TOTAL
63
5
68
497.4
OIL & GAS
The oil and gas industry in Pennsylvania started with the Drake Well near Titusville in 1859, before the onset of the Civil War. In the years since, perhaps as many as 760,000 such wells have been drilled statewide.[ix] While the Pennsylvania Department of Environmental Protection (DEP) is the current state agency with regulatory oversight of the industry, it estimates that there could be as many as 560,000 wells drilled that they have no record of in their database. Given the lack of data for these early wells, it is not possible to know exactly how many wells have been drilled in the Pine Creek Watershed.[x]
Over a century ago, pollution was seen as the price to be paid for a job in timbering or mining. Some politicians seem to want a return to those bad old days by gutting some of our reasonable regulations that protect our air and water. Here, as in the rest of the Marcellus gas play, our politicians are not protecting our air and water as mandated in Article 1, Section 27 of our State Constitution.
-Dick Martin Coordinator for the Pennsylvania Forest Coalition and board member of Pennsylvania Environmental Defense Foundation, PEDF
A Wealth of Public Lands & Recreational Opportunity
The Pine Creek Watershed is in the heart of the Pennsylvania Wilds, a 12-county region in North Central Pennsylvania focused on nature-based tourism. “Adventure to one of the largest expanses of green between New York City and Chicago,” touts the initiative’s website.[xi] The area includes over two million acres of public land, and is marketed for its notorious starry skies, quaint towns, large elk herd, and other attractions, like Pine Creek.
The watershed and its trails and public lands contribute substantially to the PA Wilds estate and offerings, including:
1,666 stream miles (187.6 miles Exceptional Value and 1,011.5 miles High Quality)
Eight state parks, spanning 4,713 acres (7.36 sq. miles)
Four state forests, covering 264,771 acres (414 sq. miles)
Eight natural areas
Three wild areas
Seven state game lands, totaling 51,474 acres (80.42 sq. miles)
And 31 trails, traversing 789 miles
These largely remote and rugged spaces are relished for their idyllic and pristine qualities. Modern extraction brings discordant traffic, noise, lights, and releases of pollutants into the air and water. Stream waters – ideal for trout, anglers, and paddlers – are siphoned for the fracturing process. Trails are interrupted by pipelines and access roads. The erosion of outdoor experiences is piecemeal and pervasive.
A recent study lends credence to the concern that shale gas development is incongruent with the region’s ecotourism and recreational goals. “The Impacts of Shale Natural Gas Energy Development on Outdoor Recreation: A Statewide Assessment of Pennsylvanians” found that “only a small population of Pennsylvania outdoor recreationists were impacted by [shale natural gas energy development (SGD)] related activities. In the regions of Pennsylvania where SGD was most prominent (e.g., North Central and Southwest), outdoor recreation impacts were considerably higher.”[xii]
Weak rules favor the gas companies and allow them to waste resources, pollute our air, and destroy our climate. Continued exploitation of our public lands diminishes the value of this common good.
–Leann Leiter, OH/PA Field Advocate, Earthworks
Read more about Leann’s view on fracking in Pine Creek and using FLIR photography to expose polluting emissions. Go to this post on Earthworks’ blog.
Natural resource extraction in the Pine Creek Watershed did not stop with timber, coal, and traditional oil and gas. The drilling landscape in Pennsylvania changed dramatically around 2005, as operators began to develop the Marcellus Shale, a carbon-rich black shale that had eluded the industry for decades, because the rock formation was reluctant to release the large quantities of gas trapped within it. Based on successes in other shale formations, the Marcellus began to be drilled with a combination of horizontal drilling and high volume hydraulic fracturing – now using millions of gallons of fluids, instead of tens of thousands – and built upon multi-acre well pads. Operators were successful in releasing the gas, and this type of well, known as “unconventional” drilling, took off in vast swaths of Pennsylvania. Similar techniques were extended to other formations, notably the Utica shale formation.
The map below shows the cumulative footprint of extractive practices in Pine Creek, with the exclusion of timber.
Midstream Infrastructure
In 2018, unconventional wells in the Pine Creek Watershed produced 203 billion cubic feet of gas, which is more than the entire state of West Virginia consumed in 2017, not including electricity generation. To get all of that gas to market requires an extensive network of pipelines, and multi-acre compressor stations are required to push the gas through those pipes.
Pipeline data for the region, largely based on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) public pipeline viewer map, includes over 85 miles of pipelines in the watershed. However, this data does not include any of the gathering lines that crisscross the watershed, connecting the drilling sites to the midstream network.
Among other concerns, gas pipelines need to be placed in areas where they will not be impacted by tree roots, and so operators clear a 50-foot wide right-of-way, at minimum. This width results in the clearing of more than 6 acres per linear mile of pipe, which would be a total of 515 acres for the known pipeline routes in the region. However, the 50-foot width is a minimum, and some rights-of-way exceeding 300 feet were observed in the watershed, which would require the clearing of more than 36 acres per linear mile. These land clearing impacts are in addition to those required for well pads, access roads, and other infrastructure.
Many of the compressor stations in the Pine Creek Watershed are considered major pollution sources, and therefore require a Title V permit from the US Environmental Protection Agency (EPA). This means that they either produce at least 10 tons per year of any single hazardous air pollutant, or at least 25 tons of any combination of pollutants on the list.
Missing pipeline data is evidenced by FracTracker’s records of many compressor stations that are not along documented pipeline routes. Of the 26 compressors in the watershed that we have records for, only six are within 250 meters of known pipeline routes. Similarly, only 29 of the 594 drilled unconventional wells in the watershed are within the quarter-kilometer radius of known pipeline routes. One way or another, all compressors and well sites have to be connected to pipelines.
Table 2. Oil & Gas Well Status in the Pine Creek Watershed
Oil & Gas Well Status
# of Wells
Operator reported not drilled
404
Proposed but never materialized
111
Active (conventional)
25
Active (unconventional)
529
Other
304
TOTAL
1,374
The PA DEP has records for 1,374 oil and gas wells within the watershed, although not all of these were actually drilled. Of these wells, 404 wells have an official status of “operator reported not drilled,” while an additional 111 have a similar status of “proposed but never materialized.” Of the remaining 859 wells, 554 are currently considered active (including 25 conventional and 529 unconventional wells). An active status is given once the well is proposed — even before it is officially permitted by DEP, let alone drilled. The status remains until some other status applies.
Seventy-four wells are considered to be “regulatory inactive” (four conventional, 71 unconventional), meaning that the well has not been in production for at least a year, and must meet several other requirements. The remainder of the wells in the watershed have reached the end of their functional life, of which 168 have been plugged (119 conventional, 49 unconventional). This is done by filling the well bore with concrete, and is considered permanent, although the plugs have been known to fail from time to time. Fifty-seven additional conventional wells are considered abandoned, meaning that they are at the end of their useful life but have not been appropriately plugged, neither by the operator nor DEP. Five additional conventional wells are considered to be orphaned, which is a similar status to abandoned, but these wells are no longer linked to an operator active in the state. Given the lack of recordkeeping in the early part of the industry’s history in PA, the number of plugged, abandoned, and orphaned wells in the Pine Creek Watershed is likely significantly underrepresented.
Conventional drilling activity has essentially ceased in the watershed. A single well categorized as conventional, the Bliss 3H well, has been drilled in 2019. In fact, this well is almost certainly miscategorized. Not only does its well name follow conventions for horizontal unconventional wells, but the DEP’s formation report indicates that it is in fact drilled into the Marcellus Shale. Prior to Bliss 3H, the two most recent conventional wells were drilled in 2011.
Unconventional drilling is a different story altogether. In terms of the number of wells drilled, the peak within the Pine Creek Watershed was in 2011, with 186 wells drilled. That represented 9.5% of the statewide total that year, and Pine Creek is just one of 35 comparably sized watersheds targeted for unconventional development in Pennsylvania.
More recently, there were 16 wells drilled in the watershed in 2018, and 17 wells through the halfway point of 2019, indicating that the extraction efforts are once again on the upswing.
Table 3. Number of unconventional wells drilled in Pennsylvania and the Pine Creek Watershed
YEAR
STATEWIDE
PINE CREEK WATERSHED
PCT. TOTAL
2006
37
1
2.7%
2007
113
1
0.9%
2008
332
9
2.7%
2009
821
26
3.2%
2010
1598
114
7.1%
2011
1956
186
9.5%
2012
1351
85
6.3%
2013
1212
48
4.0%
2014
1369
30
2.2%
2015
784
11
1.4%
2016
503
20
4.0%
2017
810
29
3.6%
2018
777
16
2.1%
2019 (YTD)
366
17
4.6%
TOTAL
11999
593
5.8%
The map below shows a heavily forested section of the watershed that has been significantly damaged by unconventional oil and gas development. Notice the forest fragmentation and land disturbance that has occurred as a result of fracking activities.
Use the time slider below to explore the changes in the Pine Creek watershed from 2008 to 2016
On May 9, 2019, nearly two dozen people descended upon the Pine Creek Watershed for the purpose of chronicling the impacts that the oil and gas industry is currently wreaking on the landscape. The documentation began early in the morning at the William T. Piper Memorial Airport in the town of Lock Haven, located in Clinton County. FracTracker Alliance organized the blitz with numerous partner organizations, including EarthWorks, Sierra Club, Save Our Streams PA, Responsible Drilling Alliance, Pennsylvania Forest Coalition, Environeers, Pine Creek Headwaters Protection Group, and Lebanon Pipeline Awareness.
The massive watershed was broken up into 10 impact zones, which were mostly determined by concentrations of known sites such as well pads, compressor stations, retention ponds, and pipeline corridors.
Some people brought cameras and specialized equipment to Pine Ceek, such methane sensors and global positioning system devices. Participants were encouraged to try out the FracTracker Mobile App, which was designed to allow users to communicate and share the location of oil and gas concerns. Earthworks brought a FLIR infrared camera, which can capture volatile organic compounds and other pollutants that are typically invisible to the human eye, but that still pose significant risks to health and the environment. Others participants brought specialized knowledge of oil and gas operations from a variety of perspectives, from those who had previously interacted with the industry professionally, to those who have been forced to live in close proximity of these massive structures for more than a decade.
While we knew that it would not be possible to photograph every impact in the watershed, the results of this group effort were tremendous, including hundreds of photos, dozens of app submissions, and numerous infrared videos. All of these have been curated in the map above. In our exuberance, we documented a number of facilities that wound up not being in the Pine Creek Watershed – still impactful but beyond the scope of this project. In some cases, multiple photos were taken of the same location, and we selected the most representative one or two for each site. Altogether, the map above shows 22 aerial images, 84 app submissions, 46 additional photos, and nine infrared FLIR videos.
FracTracker also collaborated with a pilot from LightHawk, a nonprofit group that connects conservation-minded pilots with groups that can benefit from the rare opportunity to view infrastructure and impacts from the air. Together, LightHawk and FracTracker’s Ted Auch flew in a mostly clockwise loop around the watershed, producing the aerial photography highlighted in this article, and in the map below.
The benefits of being able to see these impacts from the air is incalculable. Not only does it give viewers a sense of the full scope of the impact, but in some cases, it provides access to sites and activities that would otherwise be entirely occluded to the public, such as sites with active drilling or hydraulic fracturing operations, or when the access roads are behind barriers that are posted as no trespassing zones.
It can be difficult to maintain a sense of the massive scale of these operations when looking at aerial images. One thing that can help to maintain this perspective is by focusing on easily identifiable objects, such as nearby trees or large trucks, but it is even more useful to cross-reference these aerial images with those taken at ground level.
Drilling unconventional wells requires the use of millions of gallons of water per well, sometimes as high as 100 million gallons. Unconventional drilling operations in Pennsylvania are required to self-report water, sand, and chemical quantities used in the hydraulic fracturing stage of well production to a registry known as FracFocus. Because of this, we have a pretty good idea of water used for this stage of the operation.
This does not account for all of the industry’s water consumption. The amount of water required to maintain and operate pipelines, compressor stations and other processing facilities, and to suppress dust on well pads, access roads, and pipeline rights-of-way is unknown, but likely significant. Much of the water used for oil and gas operations in this watershed is withdrawn from rivers and streams and the groundwater beneath the watershed.
Table 3. Water consumption by well in the Pine Creek Watershed
CATEGORY
GALLONS
EQUIVALENT PERSONS (ANNUAL USAGE)
Average Single Well
6,745,697
246
Maximum Single Well
13,313,916
486
All Wells (2013-2017)
850,648,219
31,074
There are 60 water-related facilities for oil and gas operations active within the watershed in 2019, including two ground water withdrawal locations, 20 surface water withdrawal locations, and 38 interconnections, mostly retention ponds. This dataset does not include limits on the 22 withdrawal locations, however, one of the surface withdrawal sites was observed with signage permitting the removal of 936,000 gallons per day. If this amount is typical, then the combined facilities in the watershed would have a daily capacity of about 20.6 million gallons, which is about 27 times the daily residential consumption within the watershed.
Predictably, water withdrawals ebb and flow with fluctuations in drilling activity, with peak consumption exceeding 1.2 billion gallons in the three-month period between April and June 2014, and an aggregate total of nearly 20.4 billion gallons between July 2008 and December 2016. It is not known what fraction of these withdrawals occurred in the Pine Creek Watershed.
Violations
Between October 22, 2007, and April 24, 2019, the Pennsylvania DEP issued 949 violations to unconventional oil and gas operations within the Pine Creek Watershed.[xiii] It can be difficult to know precisely what happened in the field based on the notations in the corresponding compliance reports. For example, if an operator failed to comply with the terms of their erosion and sediment control permit, it is unclear whether there was a sediment runoff event that impacted surface waters or not. However, as these rules were put into place to protect Pennsylvania’s waterways, there is no question that the potential for negative water impacts exists. Therefore, erosion and sedimentation violations are included in this analysis.
Other violations are quite explicit, however. The operator of the Hoffman 2H well in Liberty Township, Tioga County was cited for failing to prevent “gas, oil, brine, completion and servicing fluids, and any other fluids or materials from below the casing seat from entering fresh groundwater,” and failing to “prevent pollution or diminution of fresh groundwater.” A well on the Tract 007 – Pad G well pad was left unplugged. “Upon abandoning a well, the owner or operator failed to plug the well to stop the vertical flow of fluids or gas within the well bore.”
The violation description falls into more than 100 categories for sites within the watershed. We have simplified those as follows:
Table 4. Oil and gas violations in the Pine Creek Watershed
VIOLATIONS
COUNT
WATER RELATED
Administrative
61
No
Casing / Cement Violation
31
Yes
Clean Streams Law Violation
32
Yes
Erosion & Sediment
84
Yes
Failed to Control / Dispose of Fluids
279
Yes
Failure to Comply With Permit
3
No
Failure to Plug Well
1
Yes
Failure to Prevent Pollution Event
23
Yes
Failure to Protect Water Supplies
8
Yes
Failure to Report Pollution Event
20
Yes
Failure to Restore Site
8
No
Hazardous Venting
1
No
Industrial Waste / Pollutional Material Discharge
229
Yes
Rat Hole Not Filled
7
Yes
Residual Waste Mismanagement
2
Yes
Restricted Site Access to Inspector
1
No
Site Restoration Violation
9
No
Unmarked Plugged Well
1
No
Unpermitted Residual Waste Processing
73
Yes
Unsound Impoundment
20
Yes
Unspecified Violation
48
No
Waste Analysis Not Completed
1
No
Water Obstruction & Encroachment
7
Yes
TOTAL
949
–
Altogether, 816 out of the 949 violations (86%) issued in the Pine Creek Watershed were likely to have an impact on either surface or ground water in the region. Two sites have more than 50 violations each, including the Phoenix Well Pad, with 116 violations in Duncan Township, Tioga County, and the Bonnell Run Hunting & Fishing Corp Well Pad in Pine Township, Lycoming County, with 94 violations.
Water Complaints
When things go wrong with oil and gas operations, it is often residents in the surrounding areas that are exposed to the impacts. There are limited actions that affected neighbors can take, but one thing that they can do is register a complaint with the appropriate regulatory agency, in this case the Pennsylvania DEP.
A thorough file review was conducted by Public Herald for complaints related to oil and gas operations in PA, yielding 9,442 complaints between 2004 and 2016. While this includes all oil and gas related complaints, Public Herald’s analysis show that the frequency is highly correlated with the unconventional drilling boom that occurred within that time frame, with the number of new wells and complaints both peaking in 2011.
Many of these complaints occurred in the Pine Creek Watershed. It is impossible to know the exact number, as the precise location of the events was redacted in the records provided by DEP. Most of the records do include the county and in some cases, the municipality. Altogether, there were complaints in 32 municipalities that are either partially or entirely within the watershed, for a total of 185 total complaints. Of those, 116 of (63%) specifically indicate water impacts, spread out over 25 municipalities throughout the watershed.
Additional complaints with unspecified municipalities were received by DEP in Lycoming County (n=4), Potter County (n=4), and Tioga County (n=3). These counties substantially overlap with the Pine Creek Watershed, but the data is unclear as to whether or not these impacts were noted within the watershed or not.
It is worth remembering that complaints are dependent upon observation from neighbors and other passersby. As Pine Creek is composed of rugged terrain with vast swaths of public land, it is relatively sparsely populated. It is likely that if these drilling sites were placed in more densely populated areas, the number of complaints related to these operations would be even higher.
“It was 2007, and my water well was fine. I mean, I didn’t have any problem with it. I was cooking, drinking, bathing with it and everything else. Well, then after they drilled I thought it was kind of…it didn’t taste like it did before.”[xiv]
– Judy Eckhart
A Waste-Filled Proposition
Since the Pine Creek Watershed has been the site of considerable oil and gas extraction activity, it has also been the site of significant quantities of waste generated by the industry, which is classified as residual waste in Pennsylvania. This category is supposedly for nonhazardous industrial waste, although both liquid and solid waste streams from oil and gas operations pose significant risks to people exposed to them, as well as to the environment. Oil and gas waste is contaminated with a variety of dangerous volatile organic compounds and heavy metals, which are frequently highly radioactive. There are also a large number of chemicals that are injected into the well bore that flow back to the surface, the content of which is often kept secret, even from workers who make use of them onsite.
There were 37 sites in the Pine Creek Watershed that accepted liquid waste between 2011 and 2018. Of these sites, 30 (81%) were well pads, where flowback from drilling may be partially reused. While this reduces the overall volume of waste that ultimately needs to be disposed of, it frequently increases the concentration of hazardous contaminants that are found in the waste stream, which can make its eventual disposal more challenging. Most of the sites that accept waste do reuse that waste. However, the largest quantity of waste are from the remaining seven sites.
Table 5. Disposal of liquid gas waste in the Pine Creek Watershed
CATEGORY
BARRELS
GALLONS
PCT. TOTAL
Reuse at Well Pads
2,042,662
85,791,801
23%
Other Facilities
6,701,292
281,454,261
77%
GRAND TOTAL
8,743,954
367,246,062
100%
One single site – the Hydro Recovery LP Antrim Facility in Pine Township, Lycoming County – accounted for the majority of liquid waste disposed in the watershed, with 6,622,255 barrels (278,134,704 gallons.) has This amounts to 98.8% of all liquid waste that was not reused at other well pads.
Wastewater is also spread on roads in some communities, as a way to suppress dust on dirt roads. 3,001 barrels (126,050 gallons) of liquid waste have been used for road spreading efforts in regions intersecting the watershed in Ulysses Township, Potter County, and across private lots and roads throughout Potter and Tioga counties. Note that these figures include waste generated from conventional wells, which have different legal requirements for disposal than waste from unconventional wells, despite a similar chemical profile.
There are three facilities that have accepted solid oil and gas waste in the watershed, including a small one operated by Environmental Products and Services of Vermont (55 tons), Hydro Recovery LP Antrim Facility (10,415 tons), and Phoenix Resources Landfill (900,094 tons). This includes 200,808 tons in 2018, which is close to the previous peak value of 216,873 tons accepted in 2012.
Figure 1. Tons of solid O&G waste accepted at the Phoenix Resources Landfill
Recap: How has a decade of fracking impacted the Pine Creek Watershed?
1,374 recorded oil and gas wells in the watershed
554 are currently considered active
including 25 conventional and 529 unconventional wells
949 violations to unconventional oil and gas operations within the Pine Creek Watershed, 86% of which were likely to have an impact on either surface or ground water
185 complaints in 32 municipalities that are either partially or entirely within the watershed
A minimum of 515 acres cleared for the known gas pipeline routes in the region
26 compressor stations in the watershed
850,648,219 gallons of water used to frack wells in the watershed between 2013-2017
60 water-related facilities for oil and gas operations active within the watershed active in 2019, including two ground water withdrawal locations, 20 surface water withdrawal locations, and 38 interconnections (mostly retention ponds)
37 sites in the Pine Creek Watershed that accepted liquid waste between 2011 and 2018
And When It’s Over?
In the last ice age, glaciers came from the finger lakes area into Pine Creek. This made the soil there very deep and rich– in fact, people come from all over to study that soil. The Pine Creek area could be a mecca for sustainable agriculture. There is great soil, excellent water, and plenty of space for wind and solar. Under the right leadership, this region of Pennsylvania could feed people in a time when climate resilience is so urgently needed.
–Melissa Troutman, Research & Policy Analyst, Earthworks. Director of “Triple Divide.” Journalist, Public Herald
The Pine Creek region retains a primeval grandeur – an alluring wild spirit of great pride and significance to our state. Natural gas development has – and will further – compromise the natural and experiential qualities of this special place. For the benefit of Pennsylvanians today and tomorrow, extraction must be replaced by cleaner forms of energy and conservation values made preeminent.
The Pine Creek Watershed in Pennsylvania’s Susquehanna River Basin has seen more than its fair share of industrial impacts in the centuries since European contact, from repeated timber clearcutting, to coal extraction, to the development of unconventional oil and gas resources in the 21st century. Despite all of this, Pine Creek remains one of the Commonwealth’s natural gems, a cornerstone of the famed Pennsylvania Wilds.
Many of the impacts to the watershed could be thought of as temporary, in that they would likely stop occurring when the oil and gas developers decide to pack up and leave for good. This includes things like truck traffic, with all of the dust and diesel exhaust that accompanies that, pollution from compressor stations and leaky pipe junctions, and even most surface spills.
And yet in some ways, the ability of the land to sustain this industry becomes substantially impaired, and impacts become much more prolonged. Consider, for example, that prior logging efforts have permanently changed both the flora and fauna of the region. Similarly, while there is no more active coal mining in Pine Creek, almost 500 acres of sites deemed to be problematic remain, and some streams impacted by contaminated runoff and mine drainage have yet to return to their former pristine state, even decades later.
Unconventional drilling in the watershed will have similarly permanent impacts. While there is a legal threshold for site restoration, these multi-acre drill sites will not resemble the heavily forested landscape that once stood there when they reach the end of their useful life. Access roads and gathering lines that crisscross the landscape must be maintained until all well pads in the area are out of service, and then the aging infrastructure will remain in situ. Contaminated groundwater supplies are likely to take centuries to recover, if it is even possible at all.
Thousands of feet of rock once separated the unconventional formations from the surface. That distance was a barrier not just to the gas, but also to salty brines, toxic heavy metals, and naturally occurring radioactive materials that are present at those depths. To date, 593 holes have been drilled in the Pine Creek Watershed, creating 593 pathways for all of these materials to move to the surface. The only things keeping them in place are concrete and steel, both of which will inevitably fail over the course of time, particularly in the highly saline environment of an old gas well.
Even if the industry were to leave today and properly plug all of the wells in the Pine Creek Watershed, impacts from the drilling are likely to remain for many years to come.
[v] DCNR, Bureau of Forestry. Marcellus Shale Management Field Tour, 2012. http://www.paforestcoalition.org/documents/Marcellus_Shale_Management_Field_Tour_5-14-12.pdf
[vi] Hayes, Samuel P. Wars in the Woods: The Rise of Ecological Forestry in America. Pittsburgh, PA. University of Pittsburgh Press, 2006. (2007). P 120-121.
[vii] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P.58-60.
[viii] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P.61.
[ix] Pennsylvania Department of Environmental Protection, Oil Gas Locations – Conventional Unconventional,2019. https://www.pasda.psu.edu/uci/DataSummary.aspx?dataset=1088
[xiii]Pennsylvania Department of Environmental Protection. Oil and Gas Compliance Report Viewer. 2019. http://www.depreportingservices.state.pa.us/ReportServer/Pages/ReportViewer.aspx?/Oil_Gas/OG_Compliance
All aerial photography by TedAuch with flight support by LightHawk (May 2019).
Pine Creek compressor station FLIR camera footage by Earthworks (May 2019).
Project funding provided by:
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/DSC_0624_LowRes.jpg29444496Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Fractracker-Color-Logo.jpgShannon Smith2019-08-07 09:36:032020-03-20 17:32:33Wildness Lost – Pine Creek
Photo by Ted Auch, FracTracker Alliance, with aerial support by LightHawk
