On February 15, 2018, officials evacuated residents after XTO Energy’s Schnegg gas well near Captina Creek exploded in the Powhatan Point area of Belmont County, Ohio. More than two weeks later, the well’s subsequent blowout has yet to be capped, and people want to know why. Here is what we know based on various reports, our Ohio oil and gas map, and our own fly-by on March 5th.
March 19th Update: This is footage of the Powhatan Point XTO Well Pad Explosion Footage from Ohio State Highway Patrol’s helicopter camera the day after the incident:
Powhatan Point XTO well pad explosion footage from Ohio State Highway Patrol
Cause of the Explosion
The well pad hosts three wells, one large Utica formation well, and two smaller ones. XTO’s representative stated that the large Utica well was being brought into production when the explosion occurred. The shut-off valves for the other two wells were immediately triggered, but the explosion caused a crane to fall on one of those wells. The representative claims that no gas escaped that well or the unaffected well.
Observers reported hearing a natural gas hiss and rumbling, as well as seeing smoke. The Powhatan Point Fire Chief reported that originally there was no fire, but that one later developed on the well pad. To make matters worse, reports later indicated that responders are/were dealing with emergency flooding on site, as well.
As of today, the Utica well that initially exploded is still releasing raw gas.
Map of drilling operations in southeast Ohio, with the Feb 15, 2018 explosion on XTO Energy’s Schnegg gas well pad marked with a star. View dynamic map
Public Health and Safety
No injuries were reported after the incident. First responders from all over the country are said to have been called in, though the mitigation team is not allowed to work at night for safety reasons.
The evacuation zone is for any non-responders within a 1-mile radius of the site, which is located on Cat’s Run Road near State Route 148. Thirty (30) homes were originally evacuated within the 1-mile zone according to news reports, but recently residents within the outer half-mile of the zone were cleared to return – though some have elected to stay away until the issue is resolved completely. As of March 1, four homes within ½ mile of the well pad remain off limits.
The EPA conducted a number of site assessments right after the incident, including air and water monitoring. See here and here for their initial reports from February 17th and 20th, respectively. (Many thanks to the Ohio Environmental Council for sharing those documents.)
Much of the site’s damaged equipment has been removed. Access roads to the pad have been reinforced. A bridge was recently delivered to be installed over Cats Run Creek, so as to create an additional entrance and exit from the site, speaking to the challenges faced in drilling in rural areas. A portion of the crane that fell on the adjacent wellhead has been removed, and workers are continuing their efforts in removing the rest of the crane.
The above video by Earthworks is optical gas imaging that makes visible what is normally invisible pollution from XTO’s Powhatan Point well disaster. The video was taken on March 3, 2018, almost 3 weeks after the accident that started the uncontrolled release. Learn more about Earthworks’ video and what FLIR videos show.
An early estimate for the rate of raw gas being released from this well is 100 million cubic feet/day – more than the daily rate of the infamous Aliso Canyon natural gas leak in 2015/16. Unfortunately, little public information has been provided about why the well has yet to be capped or how much gas has been released to date.
Bird’s Eye View
On February 26, a two-mile Temporary Flight Restriction (TFR) was enacted around the incident’s location. The TFR was supposed to lapse during the afternoon of March 5, however, due to complications at the site the TFR was extended to the evening of March 8. On March 5, we did a flyover outside of the temporary flight restriction zone, where we managed to capture a photo of the ongoing release through a valley cut. Many thanks to LightHawk and pilot Dave Warner for the lift.
XTO Energy well site and ongoing emissions after the explosion over two weeks ago. Many are still waiting on answers as to why the well has yet to be capped. Photo by Ted Auch, FracTracker Alliance, March 5, 2018. Aerial support provided by LightHawk
Additional resources
Per the Wheeling Intelligencer – Any local residents who may have been impacted by this incident are encouraged to call XTO’s claims phone number at 855-351-6573 or visit XTO’s community response command center at the Powhatan Point Volunteer Fire Department, located at 104 Mellott St. or call the fire department at 740-312-5058.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/03/XTO-Incident-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2018-03-06 15:53:362021-04-15 15:01:25Waiting on Answers Weeks after a Well Explosion in Belmont County Ohio
The City of Arvin, with a population of about 20,000, is located in Kern County, California just 15 miles southeast of Bakersfield. Nicknamed ‘The Garden in the Sun,’ Arvin is moving forward with establishing new regulations that would limit oil and gas development within the city limits.
Setback Map
The new ordinance proposes setback distances for sensitive sites including hospitals and schools, as well as residentially and commercially zoned parcels. The proposal establishes a 300-foot buffer for new development and 600’ for new operations.
In the map below, FracTracker Alliance has mapped out the zoning districts in Arvin and mapped the reach of the buffers around those districts. The areas where oil and gas well permits will be blocked by the ordinance are shown in green, labeled “Buffered Protected Zones.” The “Unprotected Zones” will still allow oil and gas permits for new development.
There are currently 13 producing oil and gas wells within the city limits of Arvin, 11 of them are located in the protected zones. Those within the protected zones are operated by Sun Mountain Oil and Gas and Petro Capital Resources. They were all drilled prior to 1980, and are shown in the map below.
Information on the public hearings and proposals can be found in the Arvin city website, where the city posts public notices. As of January 24, 2018, these are the current documents related to the proposed ordinance that you will find on the webpage:
In December of 2016, Committee for a Better Arvin, Committee for a Better Shafter, and Greenfield Walking Group, represented by Center for Race, Poverty and the Environment, sued Kern County. The lawsuit was filed in coordination with EarthJustice, Sierra Club, Natural Resources Defense Council, and the Center for Biological Diversity.
The Importance of Local Rule
Self-determination by local rule is fundamental of United States democracy, but is often derailed by corporate industry interests by the way of state pre-emption. There is a general understanding that local governments are able to institute policies that protect the interests of their constituents, as long as they do not conflict with the laws of the state or federal government. Typically, local municipalities are able to pass laws that are more constrictive than regional, state, and the federal government.
Unfortunately, when it comes to environmental health regulations, states commonly institute policies that preserve the rights of extractive industries to access mineral resources. In such cases, the state law “pre-empts” the ability of local municipalities to regulate. Local laws can be considered the mandate of the people, rather than the influence of outside interest on representatives. Therefore, when it comes to land use and issues of environmental health, local self-determination must be preserved so that communities are empowered in their decision making to best protect the health of their citizens.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/01/Arvin_bakersfield_re.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2018-01-30 11:59:072021-04-15 15:01:28Arvin, CA – a City in the Most Drilled County in the Country – files for a Setback Ordinance
Pipelines are categorized by what they carry — natural gas, oil, or natural gas liquids (NGLs) — and where they go — interstate or intrastate. The regulatory system is complicated. This primer is a quick guide to the agencies that may be involved in Falcon’s permit reviews.
Regulating Pipelines
The siting of natural gas pipelines crossing state or country boundaries is regulated by the Federal Energy Regulatory Commission (FERC). Meanwhile, determination of the location of natural gas routes that do not cross such boundaries are not jurisdictional to FERC, instead determined by the owner pipeline company. Hazardous liquids and NGL pipelines are not regulated for siting by FERC regardless of their location and destination. However, FERC does have authority over determining rates and terms of service in these cases. The U.S. Army Corps of Engineers gets involved when pipelines cross navigable waters such as large rivers and state Environmental Protection Agencies.
Pipeline design, operation, and safety regulations are established by the Pipeline and Hazardous Materials Safety Administration (PHMSA), but these regulations may vary state-by-state as long as minimal federal standards are met by the pipeline project. Notably, PHMSA’s oversight of safety issues does not determine where a pipeline is constructed as this is regulated by the different agencies mentioned above – nor are PHMSA’s safety considerations reviewed simultaneously in siting determinations done by other agencies.
An excerpt from the U.S. Army Corps’ EIS of the Atlantic Sunrise pipeline
An EIS is based on surveying and background research conducted by the company proposing the project, then submitted to agencies as an Environmental Impact Assessment (EIA). An EIS can exceed hundreds of pages and can go through many drafts as companies are asked to refine their EIA in order to qualify for approval.
An excerpt from the PA DEP’s review of water crossings for the Mariner East 2 pipeline
Pipeline proposals are also evaluated by state and local agencies. In Pennsylvania, for instance, the PA DEP is responsible for assessing how to minimize pipeline impacts. The DEP’s mission is to protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment. The PA Fish and Boat Commission oversees the avoidance or relocation of protected species. Local township zoning codes can also apply, such as to where facilities are sited near zoned residential areas or drinking reservoirs, but these can be overruled by decisions made at the federal level, especially when eminent domain is granted to the project.
Regulating the Falcon
For the Falcon pipeline, an interstate pipeline that will transport ethane (an NGL), FERC will likely have authority over determining rates and terms of service, but not siting. Construction permitting will be left state agencies and PHMSA will retain its federal authority with the Pennsylvania Public Utilities Commission (PUC) acting as PHMSA’s state agent to ensure the project complies with federal safety standards and to investigate violations. The Army Corps will almost certainly be involved given that the Falcon will cross the Ohio River. As far as we know, the Falcon will not have eminent domain status because it supplies a private facility and, thus, does not qualify as a public utility project.
Questioning Impact Assessments
The contents of EIAs vary, but are generally organized along the lines of the thematic categories that we have created for assessing the Falcon data, as seen above. However, there is also much that EISs fail to adequately address. The Army Corp’s assessment of the Atlantic Sunrise is a good example. The final EIS resulting from the operators EIA includes considerations for socioeconomic impacts, such effects on employment and environmental justice, as seen in the excerpt below. But potential negative impact in these areas are not necessarily linked to laws requiring special accommodations. For instance, federal regulations mandate achieving environmental justice by “identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects” of projects subject to NEPA’s EIS requirement. However, there are no laws that outline thresholds of unacceptable impact that would disallow a project to proceed.
An excerpt from the Atlantic Sunrise EIS addressing environmental justice concerns
Furthermore, the narratives of EIAs are almost always written by the companies proposing the project, using sources of data that better support their claims of minimal or positive impact. This is again seen in the Atlantic Sunrise EIS, where several studies are cited on how pipelines have no affect on property values or mortgages, with no mention of other studies that contradict such findings. Other factors that may be important when considering pipeline projects, such as concerns for sustainability, climate change, or a community’s social well-being, are noticeably absent.
Complicating matters, some pipeline operators have been successful in skirting comprehensive EIAs. This was seen in the case of the Mariner East 2 pipeline. Despite being the largest pipeline project in Pennsylvania’s history, a NEPA review was never conducted for ME2.
In this segment of the Falcon Public EIA Project we begin to explore the different ways that pipelines are assessed for potential risk to populated areas. We outline a methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called Class Locations. This methods identifies occupied structures in proximity to a pipeline.
Quick Falcon Facts
67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3.
More than 557 single family residences and 20 businesses within 660ft of the pipeline.
Three recreational parks and a planned luxury housing development also at risk.
Map of Falcon Class Locations
The following map will serve as our guide in breaking down the Falcon’s Class Locations. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.
Pipeline “Class locations” determine certain aspects of how a pipeline is constructed. Essentially, a pipeline’s route is segmented into lengths that are each given different classifications as outlined in PHMSA guidelines. In general terms, a segment’s Class is established by first calculating a buffer that extends 220 yards (660ft) on either side of the pipeline’s center in 1-mile continuous lengths. This buffer area is then analyzed for how many building structures are present. Classes are then assigned to each 1-mile segment using the follow criteria:
Class 1: a segment with 10 or fewer buildings intended for human occupancy
Class 2: a segment with more than 10, but less than 46 buildings intended for human occupancy
Class 3: a segment with 46 or more buildings intended for human occupancy, or where the pipeline lies within 100 yards of any building, or small well-defined outside area occupied by 20 or more people on at least 5 days a week for 10 weeks in any 12-month period (i.e. schools, businesses, recreation areas, churches)
Class 4: a segment where buildings with four or more stories aboveground are prevalent
The finer details of these calculations and their adjustments are complex, however. For instance, Class locations can be shortened to less than 1-mile lengths if building densities change dramatically in an certain area. The example image below shows one of the ways available to operators for doing this, called the “continuous sliding” method:
Calculating Class Locations
(source: PHMSA)
Class location designations may also be adjusted over time as densities change. For instance, if new homes were built in proximity to a previously constructed pipeline, the operator may be required to reduce their operating pressure, strengthen the pipeline, or conduct pressure tests to ensure the segment would technically meet the requirements of a higher Class. Alternatively, operators can apply for a special permit to avoid such changes.
What Class Locations Dictate
Pipeline segments with higher Classes must meet more rigorous safety standards, which are enforced either by PHMSA or by their state equivalent, such as the Pennsylvania Utility Commission. These include:
Soil depth: Class 1 locations must be installed with a minimum soil depth of 30 inches (18 inches in consolidated rock). Class 2, 3, and 4 locations require a minimum soil depth of 36 inches (24 inches in consolidated rock)
Shut-off valves: Class locations determine the maximum distance from shut-off valves to populated areas, as follows: Class 1 (10 miles), Class 2 (7.5 miles), Class 3 (4 miles), and Class 4 (2.5 miles).
Operating pressure: Classes also regulate the maximum allowable operating pressure (MAOP) of pipeline segments
Structural integrity: Classes determine where thicker walled materials must be used to withstand higher pressures, as well as different structural testing methods used in safety inspections
By replicating the 600 foot buffer from the Falcon’s centerline (used as the standard distance for determining Class Locations) we found that 67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3. These are represented on our interactive maps as green, yellow, and orange segments, respectively. An additional segment is marked as having an “unknown” Class on our maps (shaded in gray). This is the stretch crossing the Ohio River, where Shell’s Class location analysis has not been updated to reflect the route change that occurred in the summer of 2017.
Residential Structures
In total, there are 557 single family residences, 20 businesses, and a church within the 660ft buffer. Shell’s data also identify non-occupied structures along the route, such as sheds, garages, and other outbuildings. There are 535 such structures, but we did not have the time to replicate the locations of these sites. It is also important to note that the points on our interactive map represent only those identified by Shell, which we believe is an incomplete assessment of occupied structures based on our quick review of satellite maps.
Three residential structures lie directly within the 50-foot right-of-way. One of these homes, located in a Class 2 segment in Independence Township, is shown below. The Falcon will come as close as 20 feet to the edge of the structure and surround the home on three sides.
An occupied residence in the right-of-way
Neighborhoods in the following five communities account for the entirety of Falcon’s Class 3 locations. These would be considered the most “at risk” areas along the route in terms of proximity to the number of occupied structures. For instance, below is a satellite view of the Class 3 section of Raccoon Township.
Rumley Township, Harrison OH
Knox Township, Jefferson County OH
Raccoon Township, Beaver County PA
Independence Township, Beaver County PA
Mount Pleasant Township, Washington County PA
Raccoon Township residences & Municipal Park in a Class 3
Recreational Areas
In the above image we also see the location of Raccoon Township Municipal Park (in purple), home to a number of ballfields. Two similar recreation areas are located in the 660ft Class Location buffer: Mill Creek Ballpark, in Beaver County PA, and Clinton Community Park, in Allegheny County PA.
However, the Raccoon Township park is notable in that the Falcon cuts directly through its property boundary. Shell intends to bore under the park using HDD techniques, as stated in their permit applications, “to avoid disturbance to Beaver County baseball field/recreational park,” also stating that, “this HDD may be removed if the recreational group will allow laying the pipeline along the entrance roadway.”
New Housing Developments
One discovery worth attention is that the Falcon runs straight through an under-construction luxury housing development. Located in Allegheny County, PA, its developer, Maronda Homes, bills this growing community as having “picturesque landscapes, waterfront views and a peaceful collection of homes.” Shell mentions this development in their permit applications, stating:
Maronda Homes is in the planning and design stage of a very large housing development and SPLC [Shell Pipeline LC] worked closely with the developer and the Project was rerouted to avoid most of the housing sites.
It stands to reason that this neighborhood will eventually rank as one of the densest Class 3 areas along the Falcon route. Whether or not the pipeline is updated with higher safety standards as a result remains to be seen. The image below illustrates where the Falcon will go relative to lots marked for new homes. This property lots diagram was obtained from Shell’s GIS data layer and can be viewed on the FracTracker interactive map as well.
The Falcon intersects a luxury home development
1/31/18 Note: the Pittsburg Post-Gazette obtained newer lot line records for a portion of the Maronda Farms during their investigation into this story. These new records appear to have some alterations to the development, as seen below.
Maronda Farms, updated lot lines
Issues with Setbacks
There are no setback restrictions for building new homes in proximity to a pipeline. Parcels will eventually be sectioned off and sold to home buyers, begging the question of whether or not people in this community will realize a hazardous liquid pipeline runs past their driveways and backyards. This is a dilemma that residents in a similar development in Firestone, Colorado, are now grappling with following a recent pipeline explosion that killed two people, seen below, due to inadequate building setbacks.
A pipeline explodes in a Colorado home development
(source: InsideEnergy, CO)
Interestingly, we researched these same Maronda Farms parcels in FracTracker’s Allegheny County Lease Mapping Project only to discover that Maronda Homes also auctioned off their mineral rights for future oil and gas drilling. New homeowners would become victims of split-estate, where drilling companies can explore for oil and gas without having to seek permission from property owners, amplifying their level of risk.
In this segment of the Falcon Public EIA Project we continue to explore the different ways that pipelines are assessed for potential risk – in this case, relative to population centers, drinking water systems, and sensitive habitats. We outline methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called “high consequence areas” (HCAs) and how they determine potential impact zones for highly volatile liquid (HVL) pipelines. These methods are then applied to the Falcon to understand its possible dangers.
Quick Falcon Facts
An estimated 940-foot potential impact radius (PIR)
60 of 97 pipeline miles qualifying as High Consequence Areas (HCA)
More than 8,700 people living in the “vapor zone”
5 schools, 6 daycare centers, and 16 emergency response centers in “vapor zone”
In proximity to 8 source-water (drinking water) protection areas
Affecting habitats populated by 11 endangered, protected, or threatened species
Map of Falcon High Consequence Areas
The following map will serve as our guide in breaking down the Falcon’s High Consequence Areas. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.
Two considerations are used when determining pipeline proximity to population centers:
High Population Areas – an urbanized area delineated by the Census Bureau as having 50,000 or more people and a population density of at least 1,000 people per square mile; and
Other Populated Areas – a Census Bureau designated “place” that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or other designated residential or commercial area – including work camps.
USAs: Drinking Water
PHMSA’s definition of drinking water sources include things such as:
Community Water Systems (CWS) – serving at least 15 service connections and at least 25 year-round residents
Non-transient Non-community Water Systems (NTNCWS) – schools, businesses, and hospitals with their own water supplies
Source Water Protection Areas (SWPA) for a CWS or a NTNCWS
Wellhead Protection Areas (WHPA)
Sole-source karst aquifer recharge areas
These locations are typically supplied by regulatory agencies in individual states.
With the exception of sole-source aquifers, drinking water sources are only considered if they lack an alternative water source. However, PHMSA is strict on what alternative source means, stating that they must be immediately usable, of minimal financial impact, with equal water quality, and capable of supporting communities for at least one month for a surface water sources of water and at least six months for a groundwater sources.
One very important note in all of these “drinking water” USA designations is that they do not include privately owned groundwater wells used by residences or businesses.
USAs: Ecological Resource
Ecological resource areas are established based on any number of qualities with different variations. In general terms, they contain imperiled, threatened, or endangered aquatic or terrestrial species; are known to have a concentration of migratory waterbirds; or are a “multi-species assemblage” area (where three or more of the above species can be found).
Calculating HCAs
Like Class locations, HCAs are calculated based on proximity. The first step in this process is to determine the pipeline’s Potential Impact Radius (PIR) — the distance beyond which a person standing outdoors in the vicinity of a pipeline rupture and fire would have a 99% chance of survival; or in which death, injury, or significant property damage could occur. PIR is calculated based on the pipeline’s maximum allowable operating pressure (MAOP), diameter, and the type of gas. An example of this calculation is demonstrated in FracTracker’s recent article on the Mariner East 2 pipeline’s PIR.
Once the PIR is known, operators then determine HCAs in one of two ways, illustrated in the image below:
Method 1: A Class 3 or Class 4 location, or a Class 1 or Class 2 location where “the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy”; or a Class 1 or Class 2 location where “the potential impact circle contains an “identified site.”
Method 2: An area within PIR containing an “identified site” or 20 or more buildings intended for human occupancy.
Calculating HCAs
(source: PHMSA)
In these definitions, “identified sites” include such things as playgrounds, recreational facilities, stadiums, churches, office buildings, community centers, hospitals, prisons, schools, and assisted-living facilities. However, there is a notable difference in how HCAs are calculated for natural gas pipelines vs. hazardous liquid pipelines.
Beyond just looking at what lies within the PIR, pipelines that contain gasses such as ethane potentially impact a much broader area as vapors flow over land or within a river, stream, lake, or other means. A truly accurate HCA analysis for an ethane pipeline leak requires extensive atmospheric modeling for likely vapor dispersions, such as seen in the example image below (part of a recent ESRI GIS conference presentation).
HCAs determine if a pipeline segment is included in an operator’s integrity management program (IMP) overseen by PHMSA or its state equivalent. IMPs must include risk assessments that identify the most likely impact scenarios in each HCA, enhanced management and repair schedules, as well as mitigation procedures in the event of an accident. Some IMPs also include the addition of automatic shut-off valves and leak detection systems, as well as coordination plans with local first responders.
The Falcon Risk Zones
Shell’s permit applications to the PA DEP state the pipeline:
…is not located in or within 100 feet of a national, state, or local park, forest, or recreation area. It is not located in or within 100 feet of a national natural landmark, national wildlife refuge, or federal, state, local or private wildlife or plant sanctuaries, state game lands. It is also not located in or within 100 feet of a national wild or scenic river, the Commonwealth’s Scenic Rivers System, or any areas designated as a Federal Wilderness Area. Additionally, there are no public water supplies located within the Project vicinity.
This is a partial truth, as “site” and “vicinity” are vague terms here. A number of these notable areas are within the PIR and HCA zones. Let’s take a closer look.
The PIR (or “Blast Zone”)
Shell’s permit applications state a number of different pipeline dimensions will be used throughout the project. Most of the Falcon will be built with 12-inch steel pipe, with two exceptions: 1) The segment running from the Cadiz, OH, separator facility to its junction with line running from Scio, OH, will be a 10-inch diameter pipe; 2) 16-inch diameter pipe will be used from the junction of the Falcon’s two main legs located four miles south of Monaca, PA, to its end destination at the ethane cracker. We also know from comments made by Shell in public presentations that the Falcon’s maximum allowable operating pressure (MOAP) will be 1,440 psi. These numbers allow us to calculate the Falcon’s PIR which, for a 16″ ethane pipeline at 1,440psi, is about 940 feet. We’ve termed this the “blast zone” on our maps.
The HCA (or “Vapor Zone”)
Shell’s analysis uses an HCA impact radius of 1.25 miles. This much larger buffer reflects the fact that vapors from hazardous liquid pipelines can travel unpredictably at high concentrations for long distances before ignition. This expanded buffer might be called the “vapor zone,” a term we used on our map. Within the HCA “vapor zone” we find that 60 of the Falcon’s 97 miles qualify as high consequence areas, with 35 miles triggered due to their proximity to drinking water sources, 25 miles trigger for proximity to populated areas, and 3 miles for proximity to ecological areas.
Populated Areas
Shell’s HCA buffer intersects 14 US Census-designated populated areas, shown in the table below. Falcon’s right-of-way directly intersects two of these areas: Cadiz Village in Harrison County, Ohio, and Southview CDP (Census Designated Place) in Washington County, PA. These areas are listed below. Additionally, we included on the FracTracker map the locations of public facilities that were found inside the HCA buffer. These include 5 public schools, 6 daycare centers, 10 fire stations, and 6 EMS stations.
Area
Population
State
HCA
Pittsburgh Urbanized Area
High
PA
Indirect
Weirton-Steubenville Urbanized Area
High
WV/OH/PA
Indirect
Scio Village
Other
OH
Indirect
Cadiz Village*
Other
OH
Direct
Amsterdam Village
Other
OH
Indirect
Shippingport Borough
Other
PA
Indirect
Industry Borough
Other
PA
Indirect
Hookstown Borough
Other
PA
Indirect
Midway Borough
Other
PA
Indirect
Clinton CDP
Other
PA
Indirect
Imperial CDP
Other
PA
Indirect
Southview CDP*
Other
PA
Direct
Hickory CDP
Other
PA
Indirect
Westland CDP
Other
PA
Indirect
* Indicates an area the Falcon’s right-of-way will directly intersect
While it is difficult to determine the actual number of people living in the PIR and HCA vapor zone, there are ways one can estimate populations. In order to calculate the number of people who may live within the HCA and PIR zones, we first identified U.S. Census blocks that intersect each respective buffer. Second, we calculated the percentage of that census block’s area that lies within each buffer. Finally, we used the ratio of the two to determine the percentage of the block’s population that lies within the buffer.
Based on 2010 Census data, we estimate that 2,499 people live within a reasonable projection of the Falcon’s PIR blast zone. When expanded to the HCA vapor zone, this total increases to 8,738 people. These numbers are relatively small compared to some pipelines due to the fact that a significant portion of the Falcon runs through fairly rural areas in most places.
PIR est. pop.
HCA est. pop.
OHIO
Carroll County
11
47
Harrison County
274
915
Jefferson County
334
1,210
Total
619
2,172
WEST VIRGINIA
Hancock County
242
1,155
Total
242
1,155
PENNSYLVANIA
Allegheny County
186
969
Beaver County
990
3,023
Washington County
461
1,419
Total
1,637
5,410
Grand Total
2,499
8,738
Drinking Water Sources
Shell’s data identified a number of drinking water features considered in their HCA analysis. Metadata for this information show these sites were obtained from the Ohio Division of Drinking and Ground Waters, the West Virginia Source Water Assessment and Wellhead Protection Program, and the Pennsylvania DEP Wellhead Protection Program. The exact locations of public drinking water wells and intake points are generally protected by states for safety reasons. However, we duplicated the 5-mile buffer zones used on Shell’s map around these points, presumably denoting the boundaries of source water protection areas, wellhead protection areas, or intake points.
Drinking water buffers in Shell’s HCA analysis
As shown on FracTracker’s interactive map, five of these areas serve communities in the northern portions of Beaver County, shown in the image above, as well as the Cadiz and Weirton-Steubenville designated populated areas. Recall that HCA drinking water analysis only requires consideration of groundwater wells and not surface waters. This is an important distinction, as the Ambridge Reservoir is within the HCA zone but not part of Shell’s analysis — despite considerable risks outlined in our Falcon article on water body crossings.
Ecological Areas
Shell’s permits state that they consulted with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), and the Pennsylvania Department of Conservation and Natural Resources (DCNR) on their intended route in order to determine potential risks to protected species and ecologically sensitive areas.
DCNR responded that the pipeline had the potential to impact six sensitive plant species: Vase-vine Leather-Flower, Harbinger-of-spring, White Trout-Lily, Purple Rocket, Declined Trillium, and Snow Trillium. PFBC responded that the project may impact the Southern Redbelly Dace, a threatened temperate freshwater fish, within the Service Creek watershed. PGC responded that the pipeline had potential impact to habitats used by the Short-Eared Owl, Northern Harrier, and Silver-Haired Bat. Finally, the USFWS noted the presence of freshwater mussels in a number of water features crossed by the Falcon.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/01/Falcon_header_HCA.jpg200900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2018-01-24 10:39:082021-04-15 15:02:00The Falcon: High Consequence Areas & Potential Impact Zones
In this final section of the Falcon Public EIA Project, we explore the Falcon pipeline’s entanglements with a region already impacted by a long history of energy development. Featured in this article are where the Falcon pipeline intersects underground mining facilities, strip mines, other hazardous pipelines, active oil and gas wells, as well as a very large compressor station. We utilize this information to locate spaces where cumulative development also has the potential for compounded risk.
Quick Falcon Facts
20 miles of the Falcon run through under-mined areas; 5.6 miles through active mines
18 miles of the Falcon run through surface-mined areas; also coal slurry waste site
Shares a right-of-way with Mariner West pipeline for 4 miles in Beaver County
11 well pads, as well as a compressor station, are within the potential impact radius
Map of Falcon relative to mined areas and other energy-related development
The following map will serve as our guide in breaking down where the Falcon intersects areas that have experienced other forms of energy development. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional features of the map are not shown by default, but can be turned on in the “layers” tab. These include information on geological features, water tables, soil erosion characteristics, as well as drinking reservoir boundaries. Click the “details” tab in full-screen mode to read how the different layers were created.
The Falcon pipeline intersects a surprising number of active and inactive/abandoned mine lands. While the location of active mines is fairly easy to obtain from mine operators, finding data on abandoned mines is notoriously difficult. State agencies, such as the Pennsylvania Department of Environmental Protection (DEP), have digitized many legacy maps, but these resources are known to be incomplete and inaccurate in many locations.
AECOM’s engineers used data layers on active and abandoned mine lands maintained by state agencies in OH, WV, and PA. FracTracker obtained this data, as well, as shown on the interactive map. Shell states in their permits that AECOM’s engineers also went through a process of obtaining and digitizing paper maps in areas with questionable mine maps.
Shell states that their analysis shows that 16.8 miles of the Falcon pipeline travel through under-mined areas. Our analysis using the same dataset suggests the figure is closer to 20 miles. Of these 20 miles of pipeline:
5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine).
More than 18 miles run through areas that have been historically surface-mined (some overlapping under-mined areas).
Of those 18 miles, 1.5 miles run through an active surface mine located in Cadiz Township, OH, managed by Oxford Mining Company.
Beaver Valley Mine
The Beaver Valley Mine in Greene Township, PA, appeared to be of particular importance in Shell’s analysis. Of the three active mines, Shell maintained an active data layer with the mine’s underground cell map for reference in selecting routes, seen in the image below. Note how the current route changed since the map was originally digitized, indicating that a shift was made to accommodate areas around the mine. The FracTracker interactive map shows the mine based on PA DEP data, which is not as precise as the mine map AECOM obtained from Rosebud Mining.
Digitized map of Beaver Valley Mine
Rosebud Mining idled its Beaver Valley Mine in 2016 due to declining demand for coal. However, Rosebud appears to be expanding its workforce at other mines in the area due to changing economic and political circumstances. We don’t know exactly why this particular mine was highlighted in Shell’s analysis, or why the route shifted, as it is not directly addressed in Shell’s permit applications. Possibilities include needing to plan around areas that are known to be unfit for the pipeline, but also perhaps areas that may be mined in the future if the Beaver Valley Mine were to restart operations.
Coal Slurry Site, Imperial PA
As discussed in other segments of the Falcon Public EIA Project, Shell intends to execute 19 horizontal directional drilling (HDD) operations at different sites along the pipeline. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations. A 2003 DEP report commented on this region, stating:
All of the coal has been underground mined. Most of the coal ribs and stumps (remnants from the abandoned underground mine) have been surface mined… The extensive deep mining, which took place from the 1920’s through the 1950’s, has had a severe effect on groundwater and surface water in this watershed.
Shell’s applications note that AECOM did geotechnical survey work in this and other surface-mined areas co-located with proposed HDD operations, concluding that the ”majority of rock encountered was shale, sandstone, limestone, and claystone.” However, at one proposed HDD (called “HOU-06”) the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large Palustrine Emergent (PEM) wetland along Potato Garden Run, seen below.
A Falcon HDD crossing under a wetland and coal slurry site
Foreign Pipelines
In addition to its entanglements with legacy coal mining, the Falcon will be built in a region heavily traveled by oil and gas pipelines. More than 260 “foreign pipelines” carrying oil, natural gas, and natural gas liquids, were identified by AECOM engineers when selecting the Falcon’s right-of-way (note that not all of these are directly crossed by the Falcon).
Owners of these pipelines run the gamut, including companies such as Williams, MarkWest, Columbia, Kinder Morgan, Energy Transfer Partners, Momentum, Peoples Gas, Chesapeake, and Range Resources. Their purposes are also varied. Some are gathering lines that move oil and gas from well pads, others are midstream lines connecting things like compressor stations to processing plants, others still are distribution lines that eventually bring gas to homes and businesses. FracTracker took note of these numbers and their significance, but did not have the capacity to document all of them for our interactive map.
Shared Rights-of-Way
However, we did include one pipeline, the Mariner West, because of its importance in the Falcon’s construction plans. Mariner West was built in 2011-2013 as part of an expanding network of pipelines initially owned by Sunoco Pipeline but now operated by Energy Transfer Partners. The 10-inch pipeline transports 50,000 barrels of ethane per day from the Separator plant in Houston, PA, to processing facilities in Canada. Another spur in this network is the controversial Mariner East 2.
Mariner West is pertinent to the Falcon because the two pipelines will share the same right-of-way through a 4-mile stretch of Beaver County, PA, as shown below.
The Falcon and Mariner West sharing a right-of-way
Reuse of existing rights-of-way is generally considered advantageous by pipeline operators and regulatory agencies. The logistics of sharing pipelines can be complicated, however. As noted in Shell’s permit applications:
Construction coordination will be essential on the project due to the numerous parties involved and the close proximity to other utilities. Accurate line location was completed; however, verification will also be key, along with obtaining proper crossing design techniques from the foreign utilities. A meeting with all of pipeline companies will be held to make sure that all of the restrictions are understood prior to starting construction, and that they are documented on the construction alignment sheets/bid documents for the contractor(s). This will save a potential delay in the project. It will also make working around the existing pipelines safe.
Shell’s attention to coordinating with other utility companies is no doubt important, as is their recognition of working near existing pipelines as a safety issue. There are elevated risks with co-located pipelines when they come into operation. This was seen in a major pipeline accident in Salem Township, PA, in 2016. One natural gas line exploded, destroying nearby homes, and damaged three adjacent pipelines that took more than a year to come back online. These findings raise the question of whether or not Class Location and High Consequence Area assessments for the Falcon should factor for the exponential risks of sharing a right-of-way with Mariner West.
Oil & Gas Extraction
The remaining features included on our map relate to oil and gas extraction activities. The Falcon will carry ethane from the three cryogenic separator plants at the pipeline’s source points. But the wet, fracked gas that supplies those plants also comes from someplace, and these are the many thousands of unconventional gas wells spread across the Marcellus and Utica shale.
We found 11 unconventional oil and gas pads, hosting a combined 48 well heads, within the Falcon’s 940-foot PIR. We also found a large compressor station operated by Range Resources, located in Robinson Township, PA. This is shown below, along with a nearby gas pad.
A well pad and compressor station in Falcon’s PIR
We noted these well pads and the compressor station because Class Location and HCA risk analysis may account for proximity to occupied businesses and homes, but does not always consider a pipeline’s proximity to other high-risk industrial sites. Nevertheless, serious incidents have occurred at well pads and processing facilities that could implicate nearby hazardous liquid pipelines. By the same measure, an accident with the Falcon could implicate one of these facilities, given they are all within the Falcon’s blast zone.
Oil and gas operators are polluting groundwater in Colorado, and the state and U.S. EPA are granting them permission with exemptions from the Safe Drinking Water Act.
FracTracker Alliance’s newest analysis attempts to identify groundwater risks in Colorado groundwater from the injection of oil and gas waste. Specifically, we look at groundwater monitoring data near Class II underground injection control (UIC) disposal wells and in areas that have been granted aquifer exemptions from the underground source of drinking water rules of the Safe Drinking Water Act (SDWA). Momentum to remove amend the SDWA and remove these exemption.
Aquifer exemptions are granted to allow corporations to inject hazardous wastewater into groundwater aquifers. The majority, two-thirds, of these injection wells are Class II, specifically for oil and gas wastes.
The results of this assessment provide insight into high-risk issues with aquifer exemptions and Class II UIC well permitting standards in Colorado. We identify areas where aquifer exemptions have been granted in high quality groundwater formations, and where deep underground aquifers are at risk or have become contaminated from Class II disposal wells that may have failed.
Of note: On March 23, 2016, NRDC submitted a formal petition urging the EPA to repeal or amend the aquifer exemption rules to protect drinking water sources and uphold the Safe Drinking Water Act. Learn more
Research shows injection wells do fail
Class II injection well in Colorado explodes and catches fire. Photo by Kelsey Brunner for the Greeley Tribune.
Disposal of oil and gas wastewater by underground injection has not yet been specifically researched as a source of systemic groundwater contamination nationally or on a state level. Regardless, this issue is particularly pertinent to Colorado, since there are about 3,300 aquifer exemptions in the US (view map), and the majority of these are located in Montana, Wyoming, and Colorado. There is both a physical risk of danger as well as the risk of groundwater contamination. The picture to the right shows an explosion of a Class II injection well in Greeley, CO, for example.
Applicable and existing research on injection wells shows that a risk of groundwater contamination of – not wastewater – but migrated methane due to a leak from an injection well was estimated to be between 0.12 percent of all the water wells in the Colorado region, and was measured at 4.5 percent of the water wells that were tested in the study.
A recent article by ProPublica quoted Mario Salazar, an engineer who worked for 25 years as a technical expert with the EPA’s underground injection program in Washington:
In 10 to 100 years we are going to find out that most of our groundwater is polluted … A lot of people are going to get sick, and a lot of people may die.
Also in the ProPublic article was a study by Abrahm Lustgarten, wherein he reviewed well records and data from more than 220,000 oil and gas well inspections, and found:
Structural failures inside injection wells are routine.
Between 2007-2010, one in six injection wells received a well integrity violation.
More than 7,000 production and injection wells showed signs of well casing failures and leakage.
…groundwater contamination problems related to the subsurface disposal of liquid wastes by deep-well injection have been reviewed in the literature since 1950 (Morganwalp, 1993) and groundwater contamination accordingly is a serious problem.
According to his textbook, a 1974 U.S. EPA report specifically warns of the risk of corrosion by oil and gas waste brines on handling equipment and within the wells. The potential effects of injection wells on groundwater can even be reviewed in the U.S. EPA publications (1976, 1996, 1997).
As early as 1969, researchers Evans and Bradford, who reported on the dangers that could occur from earthquakes on injection wells near Denver in 1966, had warned that deep well injection techniques offered temporary and not long-term safety from the permanent toxic wastes injected.
Will existing Class II wells fail?
For those that might consider data and literature on wells from the 1960’s as being unrepresentative of activities occurring today, of the 587 wells reported by the Colorado’s oil and gas regulatory body, COGCC, as “injecting,” 161 of those wells were drilled prior to 1980. And 104 were drilled prior to 1960!
Wells drilled prior to 1980 are most likely to use engineering standards that result in “single-point-of-failure” well casings. As outlined in the recent report from researchers at Harvard on underground natural gas storage wells, these single-point-of-failure wells are at a higher risk of leaking.
It is also important to note that the U.S. EPA reports only 569 injection wells for Colorado, 373 of which may be disposal wells. This is a discrepancy from the number of injection wells reported by the COGCC.
Aquifer Exemptions in Colorado
According to COGCC, prior to granting a permit for a Class II injection well, an aquifer exemption is required if the aquifer’s groundwater test shows total dissolved solids (TDS) is between 3,000 and 10,000 milligrams per liter (mg/l). For those aquifer exemptions that are simply deeper than the majority of current groundwater wells, the right conditions, such as drought, or the needs of the future may require drilling deeper or treating high TDS waters for drinking and irrigation. How the state of Colorado or the U.S. EPA accounts for economic viability is therefore ill-conceived.
Data Note: The data for the following analysis came by way of FOIA request by Clean Water Action focused on the aquifer exemption permitting process. The FOIA returned additional data not reported by the US EPA in the public dataset. That dataset contained target formation sampling data that included TDS values. The FOIA documents were attached to the EPA dataset using GIS techniques. These GIS files can be found for download in the link at the bottom of this page.
Map 1 above shows the locations of aquifer exemptions in Colorado, as well as the locations of Class II injection wells. These sites are overlaid on a spatial assessment of groundwater quality (a map of the groundwater’s quality), which was generated for the entire state. The changing colors on the map’s background show spatial trends of TDS values, a general indicator of overall groundwater quality.
In Map 1 above, we see that the majority of Class II injection wells and aquifer exemptions are located in regions with higher quality water. This is a common trend across the state, and needs to be addressed.
Our review of aquifer exemption data in Colorado shows that aquifer exemption applications were granted for areas reporting TDS values less than 3,000 mg/l, which contradicts the information reported by the COGCC as permitting guidelines. Additionally, of the 175 granted aquifer exemptions for which the FOIA returned data, 141 were formations with groundwater samples reported at less than 10,000 mg/l TDS. This is half of the total number (283) of aquifer exemptions in the state of Colorado.
When we mapped where class II injection wells are permitted, a total of 587 class II wells were identified in Colorado, outside of an aquifer exemption area. Of the UIC-approved injection wells identified specifically as disposal wells, at least 21 were permitted outside aquifer exemptions and were drilled into formations that were not hydrocarbon producing. Why these injection wells are allowed to operate outside of an aquifer exemption is unknown – a question for regulators.
You can see in the map that most of the aquifer exemptions and injection wells in Colorado are located in areas with lower TDS values. We then used GIS to conduct a spatial analysis that selected groundwater wells within five miles of the 21 that were permitted outside aquifer exemptions. Results show that groundwater wells near these sites had consistently low-TDS values, meaning good water quality. In Colorado, where groundwater is an important commodity for a booming agricultural industry and growing cities that need to prioritize municipal sources, permitting a Class II disposal well in areas with high quality groundwater is irresponsible.
In Map 2, above, the locations of groundwater wells in Colorado are shown. The colors of the dots represent the concentration of TDS on the right and well depth on the left side of the screen. By sliding the bar on the map, users can visualize both. This feature allows people to explore where deep wells also are characterized by high levels of TDS. Users can also see that areas with high quality low TDS groundwater are the same areas that are the most developed with oil and gas production wells and Class II injection wells, shown in gradients of purple.
Statistical analysis of this spatial data gives a clearer picture of which regions are of particular concern; see below in Map 3.
In Map 3, above, the data visualized in Map 2 were input into a hot-spots analysis, highlighting where high and low values of TDS and depth differ significantly from the rest of the data. The region of the Front Range near Denver has significantly deeper wells, as a result of population density and the need to drill municipal groundwater wells.
The Front Range is, therefore, a high-risk region for the development of oil and gas, particularly from Class II injection wells that are necessary to support development.
Methods Notes: The COGCC publishes groundwater monitoring data for the state of Colorado, and groundwater data is also compiled nationally by the Advisory Committee on Water Information (ACWI). (Data from the National Groundwater Monitoring Network is sponsored by the ACWI Subcommittee on Ground Water.) These datasets were cleaned, combined, revised, and queried to develop FracTracker’s dataset of Colorado groundwater wells. We cleaned the data by removing sites without coordinates. Duplicates in the data set were removed by selecting for the deepest well sample. Our dataset of water wells consisted of 5,620 wells. Depth data was reported for 3,925 wells. We combined this dataset with groundwater data exported from ACWI. Final count for total wells with TDS data was 11,754 wells. Depth data was reported for 7,984 wells. The GIS files can be downloaded in the compressed folder at the bottom of this page.
Site Assessments – Exploring Specific Regions
Particular regions were further investigated for impacts to groundwater, and to identify areas that may be at a high risk of contamination. There are numerous ways that groundwater wells can be contaminated from other underground activity, such as hydrocarbon exploration and production or waste injection and disposal. Contamination could be from hydraulic fracturing fluids, methane, other hydrocarbons, or from formation brines.
From the literature, brines and methane are the most common contaminants. This analysis focuses on potential contamination events from brines, which can be detected by measuring TDS, a general measure for the mixture of minerals, salts, metals and other ions dissolved in waters. Brines from hydrocarbon-producing formations may include heavy metals, radionuclides, and small amounts of organic matter.
Wells with high or increasing levels of TDS are a red flag for potential contamination events.
Methods
Groundwater wells at deep depths with high TDS readings are, therefore, the focus of this assessment. Using GIS methods we screened our dataset of groundwater wells to only identify those located within a buffer zone of five miles from Class II injection wells. This distance was chosen based on a conservative model for groundwater contamination events, as well as the number of returned sample groundwater wells and the time and resources necessary for analysis. We then filtered the groundwater wells dataset for high TDS values and deep well depths to assess for potential impacts that already exist. We, of course, explored the data as we explored the spatial relationships. We prioritized areas that suggested trends in high TDS readings, and then identified individual wells in these areas. The data initially visualized were the most recent sampling events. For the wells prioritized, prior sampling events were pulled from the data. The results were graphed to see how the groundwater quality has changed over time.
Case of Increasing TDS Readings
If you zoom to the southwest section of Colorado in Map 2, you can see that groundwater wells located near the injection well 1 Fasset SWD (EPA) (05-067-08397) by Operator Elm Ridge Exploration Company LLC were disproportionately high (common). Groundwater wells located near this injection well were selected for, and longitudinal TDS readings were plotted to look for trends in time. (Figure 1.)
The graphs in Figure 1, below, show a consistent increase of TDS values in wells near the injection activity. While the trends are apparent, the data is limited by low numbers of repeated samples at each well, and the majority of these groundwater wells have not been sampled in the last 10 years. With the increased use of well stimulation and enhanced oil recovery techniques over the course of the last 10 years, the volumes of injected wastewater has also increased. The impacts may, therefore, be greater than documented here.
This area deserves additional sampling and monitoring to assess whether contamination has occurred.
Figures 1a and 1b. The graphs above show increasing TDS values in samples from groundwater wells in close proximity to the 1 Fassett SWD wellsite, between the years 2004-2015. Each well is labeled with a different color. The data for the USGS well in the graph on the right was not included with the other groundwater wells due to the difference in magnitude of TDS values (it would have been off the chart).
Groundwater Contamination Case in 2007
We also uncovered a situation where a disposal well caused groundwater contamination. Well records for Class II injection wells in the southeast corner of Colorado were reviewed in response to significantly high readings of TDS values in groundwater wells surrounding the Mckinley #1-20-WD disposal well.
When the disposal well was first permitted, farmers and ranchers neighboring the well site petitioned to block the permit. Language in the grant application is shown below in Figure 2. The petitioners identified the target formation as their source of water for drinking, watering livestock, and irrigation. Regardless of this petition, the injection well was approved. Figure 3 shows the language used by the operator Energy Alliance Company (EAC) for the permit approval, which directly contradicts the information provided by the community surrounding the wellsite. Nevertheless, the Class II disposal well was approved, and failed and leaked in 2007, leading to the high TDS readings in the groundwater in this region.
Figure 2. Petition by local landowners opposing the use of their drinking water source formation for the site of a Class II injection disposal well.
Figure 3. The oil and gas operation EAC claims the Glorietta formation is not a viable fresh water source, directly contradicting the neighboring farmers and ranchers who rely on it.
Figure 4. The COGCC well log report shows a casing failure, and as a result a leak that contaminated groundwater in the region.
Areas where lack of data restricted analyses
In other areas of Colorado, the lack of recent sampling data and longitudinal sampling schemes made it even more difficult to track potential contamination events. For these regions, FracTracker recommends more thorough sampling by the regulatory agencies COGCC and USGS. This includes much of the state, as described below.
Southeastern Colorado
Our review of the groundwater data in southeastern Colorado showed a risk of contamination considering the overlap of injection well depths with the depths of drinking water wells. Oil and gas extraction and Class II injections are permitted where the aquifers include the Raton formation, Vermejo Formation, Poison Canyon Formation and Trinidad Sandstone. Groundwater samples were taken at depths up to 2,200 ft with a TDS value of 385 mg/l. At shallower depths, TDS values in these formations reached as high as 6,000 mg/l, and 15 disposal wells are permitted in aquifer exemptions in this region. Injections in this area start at around 4,200 ft.
In Southwestern Colorado, groundwater wells in the San Jose Formation are drilled to documented depths of up to 6,000 feet with TDS values near 2,000 mg/l. Injection wells in this region begin at 565 feet, and those used specifically for disposal begin at below 5,000 feet in areas with aquifer exemptions. There are also four disposal wells outside of aquifer exemptions injecting at 5,844 feet, two of which are not injecting into active production zones at depths of 7,600 and 9,100 feet.
Western Colorado
In western Colorado well Number 1-32D VANETA (05-057-06467) by Operator Sandridge Exploration and Production LLC’s North Park Horizontal Niobara Field in the Dakota-Lokota Formation has an aquifer exemption. The sampling data from two groundwater wells to the southeast, near Coalmont, CO, were reviewed, but we can’t get a good picture due to the lack of repeat sampling.
In Northwestern Colorado near Walden, CO and the McCallum oil field, two groundwater wells with TDS above 10,000 ppm were selected for review. There are 21 injection wells in the McCallum field to the northwest. Beyond the McCallum field is the Battleship field with two wastewater disposal wells with an aquifer exemption. West of Grover, Colorado, there are several wells with high TDS values reported for shallow wells. Similar trends can be seen near Vernon. The data on these wells and wells from along the northern section of the Front Range, which includes the communities of Fort Collins, Greeley, and Longmont, suffered from the same issue. Lack of deep groundwater well data coupled with the lack of repeat samples, as well as recent sampling inhibited the ability to thoroughly investigate the threat of contamination.
Trends and Future Development
Current trends in exploration and development of unconventional resources show the industry branching southwest of Weld County towards Fort Collins, Longmont, Broomfield and Boulder, CO.
These regions are more densely populated than the Front Range county of Weld, and as can be seen in the maps, the drinking water wells that access groundwaters in these regions are some of the deepest in the state.
This analysis shows where Class II injection has already contaminated groundwater resources in Colorado. The region where the contamination has occurred is not unique; the drinking water wells are not particularly deep, and the density of Class II wells is far from the highest in the state.
Well casing failures and other injection issues are not exactly predictable due to the variety of conditions that can lead to a well casing failure or blow-out scenario, but they are systemic. The result is a hazardous scenario where it is currently difficult to mitigate risk after the injection wells are drilled.
Allowing Class II wells to expand into Front Range communities that rely on deep wells for municipal supplies is irresponsible and dangerous.
The encroachment of extraction into these regions, coupled with the support of Class II injection wells to handle the wastewater, would put these groundwater wells at particular risk of contamination. Based on this analysis, we recommend that regulators take extra care to avoid permitting Class II wells in these regions as the oil and gas industry expands into new areas of the Front Range, particularly in areas with dense populations.
Feature Image: Joshua Doubek / WIKIMEDIA COMMONS
Article by: Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
October 31, 2017 Edit: This post originally cited the Clean Water Act instead of the Safe Drinking Water Act as the source that EPA uses to grant aquifer exemptions.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/10/kansas_wellpad.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2017-10-26 14:55:032021-04-15 15:02:07Groundwater risks in Colorado due to Safe Drinking Water Act exemptions
The River Healers have droned multiple fracking sites in the Greater Chaco Area (New Mexico) impacted by explosions, fires, spills, and methane. See what they are finding. Hear their story.
By Tom Burkett – River Healer Spokesperson, New Mexico Watchdog
The Greater Chaco region is known to the Diné (Navajo) as Dinétah, the land of their ancestors. It contains countless sacred sites that date to the Anasazi and is home of the Bisti Badlands and Chaco Culture National Historical Park, a World Heritage Site. Currently WPX Energy has rights to lease about 100,000 acres of federal, state, and Navajo allottee lands in the oil rich San Juan Basin, which includes Greater Chaco.1 WPX Energy along with other fracking companies plan to continue establishing crude oil fracking wells on these sacred lands, although the Greater Chaco community has spoken out against fracking and continue to call for more safety and oversight from New Mexico state regulatory bodies such as the EMNRD Oil Conservation Division.
The River Healers pulled EMNRD records that show over 8,300 spills in New Mexico had been reported by the the fracking industry to EMNRD between 2011-2016 (map below). This is thousands more than reported by the Environmental Protection Agency. The records also showed how quickly reports of spills, fires, and explosions were processed by the EMNRD as ‘non-emergency’ and accepted industry reports that no groundwater had been contaminated.
Zoomed in view of the River Healers’ NM fracking spills map. Learn more
Daniel Tso, Member of the Navajo Nation and Elder of the Counselor Chapter, led us to fracking sites in Greater Chaco that had reported spills and fires. Daniel Tso is one of many Navajo Nation members working on the frontlines to protect Greater Chaco, their ancestral land, and their pastoral ways of life from the expanding fracking industry. Traveling in white trucks and cars we blended in with the oil and gas trucks that dot indigenous community roads and group around fracking pads on squares federally owned land. Years of watchdogging the fracking destruction on their sacred land was communicated through Tso’s eyes looking over the landscape for new fracking disruption and a calm voice,
… the hurt on the sacred landscapes; the beauty of the land is destroyed, this affects our people’s mental, spiritual, and emotional health.
At each site our eyes were scanning the fracking sites and terrain for drone flight patterns while the native elders were slowly scanning the ground for pottery shards and signs of their ancestors. Arroyos sweep around the fracking pads and display how quickly the area can flash flood from rain that gathers on the striated volcanic ash hills of the badlands.
Fracking Regulation in NM
The EMNRD Oil Conservation Division has only 12 inspectors that are in charge of overseeing over 50,000 wells scattered throughout New Mexico.2 Skepticism around EMNRD’s ability to regulate not only comes from a short staff being stretched across 121,598 square miles of New Mexico’s terrain, but thousands of active fracking sites continue to report spills, fires, and explosions every year.3 Even more problematic is that Ken McQueen, Cabinet Secretary of EMNRD formerly served as Vice President of WPX Energy.4 Ken McQueen managed WPX Energy’s assets in the Four Corners area of New Mexico, Colorado, and in addition, part of Wyoming. New Mexico Governor, Susana Martinez’s appointment of McQueen severely compromises the state’s ability to impartially oversee WPX Energy and regulate the fracking industry. Governor Martinez has been called to clean up the EMNRD, and rid the regulatory body of cabinet members more interested in protecting the assets of WPX than the health and rights of New Mexicans. Tso remarks,
The sacrifices of indigenous communities continue for a society that thinks gasoline comes from a gas station. That thinks oil is a commodity that is unending resource. This is unfortunate, and ultimately compromises our physical health. Yet this doesn’t matter to the industry. They want every last drop of crude oil even if it is cost prohibitive.
The River Healers maintain that Governor Martinez is complicit in the exploitation of human water rights as long as the EMNRD remains a compromised and unreliable regulatory body.
New Mexico governmental assimilation with the oil and gas industry is presented to the Greater Chaco indigenous communities in the form of 90,000-lb gross weight oilfield trucks. Western Refining started rolling out trucks with larger-than-life prints of state and county law enforcements officers and military personnel at the same time water protectors at Standing Rock were being arrested and assaulted by the Morton County Sheriff’s Department in North Dakota.5 The indigenous-led movement to stop the Dakota Access Pipeline from desecrating sacred land and threatening rights to clean water has drawn greater resistance to oil and gas projects around the country.
Indigenous solidarity is felt in Greater Chaco, but Western Refining’s blatant propaganda campaign demonstrates how oil and gas corporations continue to threaten and silence the communities they extract oil from by displaying the paid power of state and federal law enforcement. The River Healers view this as a direct form of intimidation that aims to further a corporate ideology and remind native communities of the violence they experienced at the hand of the United States Federal Government in the past. The Western Refining campaign is a direct form of corporate-sponsored terrorism and should be grounds to ban their ability to use images of law enforcement officers to further their interests. Furthermore, the state should discontinue paying for officers to patrol facking roads and pads and instead use state funds to make state regulatory bodies work for the communities most impacted by the oil and gas industries.
What we are finding
Drone surveillance of fracking sites in Greater Chaco show how quickly the fracking industry has exploited a state government tied to the interests of a booming and unchecked resource extraction industry. In Greater Chaco this element of time is more deeply understood through the lens of the indigenous community.
Ultimately, the health of the fauna and flora are devastated. The adaptation of the delicate ecosystem is forever destroyed. Their recovery and healing will take years and years.
The Anasazi Kivas in Chaco Canyon took over 300 years to construct, while drill rigs such as Cyclone 32 take less than 10 days to drill 6,500 ft wells in the canyon plateau. We hiked 12 miles of the sacred Chaco Wash, pulled water samples, and saw the red palm of the Supernova Petrograph clinging to the understory of the canyon wall, clearly taking notice of what is happening above.
We deeply thank members of the Navajo Nation for inviting us into their lives, and our hearts stand with them in solidarity. Protect Greater Chaco! Dooda Fracking!
River Healers Site Videos
Site 1
Nageezi, NM
County: San Juan
Kimbeto Wash/Chaco River
GPS: 36°14’22.38”, -107°43’51.38”
This particular site caught fire on June 11th, 2016 and was allowed to burn until July 14th. The fracking fire and contaminates spread to areas north and south of the fracking pad, burning Juniper trees within 200 feet of residential buildings. This fire is not the only documented case in the Greater Chaco Area where communities were disrupted and evacuated in the middle of the night. While community members remain concerned about their health, WPX reported that the incident was not an emergency and that no damage was caused to groundwater.
Site 2
Nageezi, NM
County: San Juan
Kimbeto Wash/Chaco River
GPS: 36°13’43.23″, -107°44’28.72″
Drone surveys of this particular site show Cyclone 32, a 1500 Horsepower 755 ton drill rig manufactured in Wyoming. The drill rig is transported through Greater Chaco communities on small dusty single lane dirt roads used by the community members and school buses. The drilling is heard and seen moving from pad to pad. The rig is establishing multiple drill heads on pockets of land tucked along the Kimbeto Wash, a tributary to the Chaco River and sacred source of water security for members of the Greater Chaco Area in Nageezi, New Mexico.
Site 3
Nageezi, NM
County: San Juan
Kimbeto Wash/Chaco River
GPS: 36°13’27.51″, -107°45’3.24″
No video available
Site 4
Counselor, NM
County: Rio Arriba
Canada Larga River
GPS: 36°13’18.19″, -107°28’56.24″
Drone surveys show Lybrook Elementary School only 1600ft from a WPX Energy fracking site. The crude oil tanks of the site can be seen from the classroom windows of the school. The elementary school was moved to this location in 2006 because it was right across the highway from a large and expanding natural gas plant and had to relocate elementary students to a safe location.
Although the WPX Energy site is established on federal land, this area of Counselor, New Mexico is referred to as ‘The Checkerboard’ because of the quadrants of federal land that break up tribal land. The 5 well heads are highlighted to show that these pockets of federal land are being fracked with a high concentration of fracking wells. By drilling multiple wells in one pad location fracking companies are able to quickly drain the plays of crude oil under the the Greater Chaco Area and avoid signing contracts with the native property owners that live and attend school in the area they are fracking.
Drone surveys show crude oil being fracked within 840 ft of an indigenous community in Sandoval County, NM (Greater Chaco). The fracking site is located in the path of the community water supply, which had to be routed around the wellhead and crude tanks. The underground water line remains only 110 ft from active fracking activity.
Particular communities in Greater Chaco are dependent upon pastoral industry and the health of their livestock. Horses owned by the indigenous community are seen grazing on open and unprotected fracking pads. Many of these fracking pads have recorded spills of either fracking fluid, wastewater, or crude oil and pose health risks to the livestock grazing on potentially contaminated grasses and wastewater.
A Western Refining (WPX) crude truck can be seen driving down the community road. These dirt roads were designed to support local community traffic and school buses but are now heavily used by the fracking industry. 90,000-lb gross weight oilfield trucks haul the volatile crude oil through pastoral lands, endangering livestock and community members. Fracking companies continue to level dirt roads to accommodate the weight of their crude trucks. The practice cuts roads deep into the landscape. Roads in Greater Chaco now resemble trenches and make travel dangerous, block scenic views of ancestral land, and hinder the ability to monitor livestock and fracking development.
Site 6
Nageezi, NM
County: San Juan
Kimbeto Wash/Chaco River
GPS: 36°15’20.46”, -107°41’43.14”
Drone surveys show 3 well heads, crude tanks, and compressors north of Hwy 550 in Nageezi, NM. The location is of importance because it shows how flaring is used to burn off methane caused by fracking and the transportation processes of crude oil. The River Healers droned this site when workers were not present and the flare tower was turned off for safety concerns, but the flame can usually be seen all the way from Hwy 550 tucked into the distinct hills of the Bisti Badlands. Such methane hotspots are of concern because methane causes severe health risks for individuals living near crude oil facilities. NASA has identified two large methane gas clouds in new Mexico. The methane gas is concentrated above fracking occurring in the San Juan Basin and Permian Basin and disproportionately affects the air quality of Greater Chaco, Four Corners Region, Farmington, and South East region of New Mexico.
Two unlined wastewater pits can be seen on the edge of the fracking pad near the well heads and compressors. Erosion caused by water drainage can be seen leading from the well heads and compressor areas directly to the wastewater pits. Drainages can also be seen coming directly out of the waste water pits and going into the Upper Kimbeto Wash, a tributary of the Chaco River. It is illegal for fracking companies to keep fracking wastewater in unlined pits in the state of New Mexico. The River Healers reported this possible water violation to the EMNRD Oil Conservation Division (a state regulatory body for the fracking industry). EMNRD replied that WPX Energy maintains that the wastewater is caused by stormwater runoff and contains no fracking contaminates. This is the first time we have heard of the fracking industry creating stormwater runoff pits and find the practice to be unusual. Further skepticism that these runoff pits are not contaminated comes from research about the site. In June of 2016, WPX Energy reported a spill of 600 gallons of crude oil at this site because of a fire. WPX maintains that no groundwater was impacted and marked the incident as not an emergency.
The River Healers organize anonymous watchdog operations and tactical campaigns to protect water. The artist collective is engaged in direct action through analyzing, exposing, and bringing down systematic abuses of water rights. The River Healers work to accelerate theories of water democracy, decentralize aesthetics of environmentalism, and expose corporate sponsored water terrorism. ‘Water is a commons – No one has the right to destroy’
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/09/River-healers-video-feature.jpg400900Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2017-09-21 09:30:482021-04-15 15:02:33Protect Greater Chaco: Drone surveillance of regional fracking sites in NM
This 2015 photo from West Virginia illustrates that large trucks on dirt roads create a legitimate dust problem, which impacts both air and water quality.
The application of liquid oil and gas waste from conventional wells onto roadways for dust control and road stabilization is permitted in Pennsylvania, provided that operators adhere to plans approved by the Department of Environmental Protection (DEP). There are brine spreading guidelines that operators are required to follow, but overall, DEP considers roadspreading to be a beneficial use of the liquid oil and gas waste products.
Dust suppression is a legitimate concern, particularly in areas that see a lot of heavy truck traffic on dirt roads, such rural oil and gas fields. Prolonged exposure to airborne dust contributes to a number of different health problems, ranging from temporary irritation to debilitating diseases of the heart, lungs, and kidneys. This road dust can also impact aquatic life, from plants to aquatic insects to fish.
While applying liquid waste from the oil and gas industry undoubtedly seems like a convenient solution to dusty roads, is roadspreading really advisable?
In the map above, the areas in green are municipalities where liquid waste from Pennsylvania’s conventional wells were applied to roadways in 2016. The purple areas are counties where additional quantities of the liquid waste were applied in cases where the exact municipality was not specified on the 2016 waste report. The majority of the state’s oil and gas roadspreading remains in Pennsylvania, but some of the brine is spread on roads in New York, as well.
What’s in the brine?
In Pennsylvania, the large-scale extraction efforts from deep carbon-rich shales like the Marcellus and Utica formations are classified as unconventional oil and gas, whereas the shallower formations requiring smaller amounts of hydraulic fracturing stimulation to bring the wells into production are considered to be conventional.
While the chemical components of these brines vary from formation to formation, in general they are known for containing high-salinity toxic metals, such as barium and strontium, as well as volatile organic compounds including benzene. Bromide in the brine can interact with purification processes at treatment plants to create carcinogenic compounds called trihalomethanes. These compounds actually created a problem in the early parts of the Marcellus boom in Western Pennsylvania, when large enough quantities of bromide were added to the region’s rivers and streams. And of particular concern is naturally occurring radioactive materials (NORMs), which sometimes occur at very high concentrations, even in brines from conventional wells.
The Pennsylvania Geological Survey commissioned Evan Dresel and Arthur Rose from Penn State to investigate oil and gas brine from a sample of 40 wells in 1985, although the accompanying paper wasn’t published until 2010. Their samples included dissolved solids of 343,000 milligrams per liter, and radium occurring at up to 5,300 picocuries per liter. As a point of comparison, the US Environmental Protection Agency mandates that drinking water not exceed 5 picocuries per liter, and the authors of this report express concern about the high levels shown in these brines.
Based on the six samples analyzed, radium shows a general correlation with barium and strontium and an inverse correlation with [sulfate], though the correlation is not perfect. The radium values are high enough that a possible radiation hazard exists, especially where radium could be adsorbed on iron oxides and accumulate in brine tanks.
The article’s preface, written in 2010, echoes the concern, stating, ” the very high radium contents indicate that caution should be used in handling these brines.” One imagines that the radium content might also be a concern for people walking their dogs along dirt roads where these brines are spread.
Testing for radiological contamination appears to be insufficient for liquid oil and gas waste. Ben Stout, PhD, a professor of Biology at Wheeling Jesuit University (and a FracTracker Alliance board member) sampled liquid waste from Marcellus Shale wells in 2009. Here is what he found:
In terms of radiation, 9 of the 13 samples exceeded the drinking water standard for radium. Furthermore, 7 of the 13 samples exceeded the drinking water standard for gross alpha particles, which are a strong indicator of radioactivity. Most notably, one sample from a frac pit at the Phillips #20 site in Westmoreland County, PA yielded a gross alpha reading of 4846 +/‐ 994 picocuries per liter (pCi/L), though the drinking water standard is 15 pCi/L. In fact, the same sample had combined radium readings well over 1,000 pCi/L, a multiple in excess of 200 times the (5 pCi/L) standard. It should be noted that none of the samples triggered a response from radiation meters.
What to do?
From environmental concerns of high salinity to health concerns about the toxic and radiological content of oil and gas brines, intentionally introducing this waste product to public spaces is a dubious practice. It is understandable that township supervisors would want to use readily available materials for dealing with dust control on dirt roads, but if you are concerned about the practice and your area is indicated on the map above, you may wish to contact them to find out where this waste is being spread in greater detail.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/08/Roadspreading-Hughes-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2017-08-30 11:16:492021-04-15 15:02:34Does roadspreading of brine equate to oil and gas waste dumping?
In total, there are 557 single family residences, 20 businesses, and a church within the 660ft buffer. Shell’s data also identify non-occupied structures along the route, such as sheds, garages, and other outbuildings. There are 535 such structures, but we did not have the time to replicate the locations of these sites. It is also important to note that the points on our interactive map represent only those identified by Shell, which we believe is an incomplete assessment of occupied structures based on our quick review of satellite maps.
1/31/18 Note: the 
