Porterville incident map
Karen Edelstein

Mysterious leak near Porterville Compressor Station, NY

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Last month, FracTracker Alliance featured a blog entry and map exploring the controversy around National Fuel’s proposed Northern Access Pipeline (NAPL) project, shown in the map below. The proposed project, which has already received approval from the Federal Energy Regulatory Commission (FERC), is still awaiting another decision by April 7, 2017 — Section 401 Water Quality Certification. By that date, the New York State Department of Environmental Conservation (NYS DEC) must give either final approval, or else deny the project.

Northern Access Pipeline Map

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The NAPL project includes the construction of 97-mile-long pipeline to bring fracked Marcellus gas through New York State, and into Canada. The project also involves construction of a variety of related major infrastructure projects, including a gas dehydration facility, and a ten-fold expansion of the capacity of the Porterville Compressor Station located at the northern terminus of the proposed pipeline, in Erie County, NY.

On three consecutive days in early February, 2017, the New York State Department of Environmental Conservation (NYS DEC) held hearings in Western New York to gather input about the NAPL project. On February 7th, the day of the first meeting at Saint Bonaventure University in Allegany County, NY, an alarming — and yet to be fully reported — incident widely considered to be a gas leak, occurred at, or near, the Porterville Compressor Station (also known locally as the “Elma Compressor Station”). The incident is thought to be connected to the planned upgrades to the facility, but was not even mentioned as a concern during the public meetings relating to the Northern Access Pipeline in the subsequent hours and days.

What follows is a story of poor communication between the utility company, first responders, and local residents, resulting in confusion and even panic, and has yet to be conclusively explained to the general public.

Incident Description

Area of incident

Area of incident in NY State

We know that a little past 10 AM on February 7th, people in the villages of Elma and East Aurora, within about a mile of the Porterville Compressor Station, reported strong odors of gas. They filed complaints with the local gas utility (National Fuel), and the local 911 center, which referred the calls to the local Elma Fire Department. The fire department went to the Porterville Compressor station to investigate, remembering a similar incident from a few years earlier. At the compressor station, representatives from National Fuel, the operator of the compressor station, assured the fire company that they were conducting a routine flushing of an odorant line, and the situation was under control, so the fire company departed.

Residents in the area became more alarmed when they noticed that the odor was stronger outside their buildings than inside them. National Fuel then ordered many residents to evacuate their homes. The East Aurora police facilitated the evacuation and instructed residents to gather in the East Aurora Library not far from those homes. Nearby businesses, such as Fisher Price, headquartered in East Aurora, chose to send their employees home for the day, due to the offensive odor and perceived risks.

Around 11:30 in the morning, up to 200 clients at Suburban Adult Services, Inc. (SASi), were evacuated to the Jamison Road Fire Station, where they remained until around 3 PM that afternoon. Over 200 reports were received, some from as far away as Orchard Park, eight miles down-wind of the compressor station.

After East Aurora elementary and middle schools placed complaints, National Fuel told them to evacuate students and staff from their buildings. Realizing that the smell was stronger outside than inside the building, school leaders revised their plans, and started to get buses ready to transport student to the high school, where there had not been reports of the odor. Before the buses could load, however, the police department notified the school that the gas leak had been repaired, and that there was no need to evacuate. School officials then activated the school’s air circulation system to rid the building of the fumes.

Perplexingly, according to one report, National Fuel’s Communications Manager Karen Merkel said “that the company did not reach out into the community to tell people what was going on because the company cannot discourage anyone from making an emergency gas call.”

Merkel noted further, “You never know if the smell being reported is related to work we are doing or another gas leak,” she said. “This wouldn’t be determined until we investigate it.”

That smell…

Some background on gas leaks & odorant additives

Ethyl mercaptan molecule

Ethyl mercaptan molecule

An odorant, such as ethyl mercaptan, is often added to natural gas in order to serve as an “early warning system” in the event of a leak from the system. Odorants like mercaptan are especially effective because the humans can smell very low concentrations of it in the air. According to the National Center for Biotechnology Information, “The level of distinct odor awareness (LOA) for ethyl mercaptan odorant is 1.4 x10-4 ppm,” or 0.00014 parts per million. That translates to 0.000000014 percent by volume.

Not all natural gas is odorized, however. According to Chevron Phillips, “mercaptans are required (by state and federal regulations) to be added to the gas stream near points of consumption as well as in pipelines that are near areas with certain population density requirements, per Department of Transportation regulations… Not all gas is odorized, though; large industrial users served by transmission lines away from everyday consumers might not be required to use odorized gas.” Also, because odorants tend to degrade or oxidize when gas is travelling a long distance through transmission lines, they are not always added to larger pipeline systems.

The explosion and flammability concentration limit for natural gas refers to the percentage range at which a gas will explode. At very low concentrations, the gas will not ignite. If the concentration is too high, not enough oxygen is present, and the gas is also stable. This is why gas in non-leaky pipelines does not explode, but when it mixes with air, and a spark is present, the result can be disastrous. Methane, the primary component of natural gas, has a lower explosive level (LEL) of 4.4% and an upper explosive limit (UEL) (above which it will not ignite) of 16.4%. Nonetheless, levels above 1% are still worrisome, and may still be good cause for evacuation.

Therefore, the margin of safety between when natural gas is detectable with an odorant present, and when it may explode, is very broad. This may help to explain why the smell of gas was detected over such a broad distance, but no explosion (very fortunately) took place.

Local memories of gas explosion in East Aurora

Many East Aurora residents have had first-hand experience with the dangers posed by gas lines in their community. Less than 25 years ago, in  September 1994, a high-pressure pipeline owned by National Fuel ruptured in an uninhabited area between East Aurora and South Wales along Olean Rd. The blast left a 10-foot-deep, 20-foot-wide crater, and tree limbs and vegetation were burned as far as 50 feet away.

Porterville first-hand accounts and inquiries

FracTracker spoke extensively with one resident of East Aurora, Jennifer Marmion, about her experiences, and efforts to understand what had actually happened the day of this incident.

When personnel from the Jamison Fire Company — who are assumed to be first responders to emergencies of this sort — arrived at the Porterville Compressor Station, they were told by National Fuel that there was no hazard and that their services were not needed. Consequently, these crews left the site. The East Aurora Police Department was given a different explanation by National Fuel; there was a valve malfunction somewhere along Two Rod Road in Marilla. Still later, National Fuel indicated that the pipeline changeover occurred closer to the compressor station itself. The closest distance between anywhere on Two Rod Road and the compressor station, itself, is a mile and a half. And Ms. Marmion was given a still different story by a National Fuel engineer: that the odor, indeed, resulted during the replacement of a 100-foot-long section of aging pipeline at the Porterville (“Elma”) Compressor Station.

Key locations in incident report

Key locations in incident report

Some reports indicated an alternate explanation: that the odor originated at the East Aurora Town Hall (J. Marmion, pers. comm., via Channel 7 News), or a leaky valve along a pipeline near Marilla (J. Marmion, pers. comm, via East Aurora Police Department dispatcher). A member of the East Aurora Fire Department surmised that the leak might have been closer to Olean Road, south of the village, where there was a history of other leaks. The day after the incident, National Fuel indicated that the odor originated from the compressor station, and was the result of a routine, scheduled “blowdown” by National Fuel — wherein gas lines at the compressor station are cleared as part of routine maintenance. However, when pressed for more details, they did not provide them.

In need of follow up

More than six weeks have passed since the incident, and there is still no definitive explanation available. Clearly, there was considerable confusion about what the correct, and safe, procedure needed to be, as well as how this information needed to flow to the public. Ultimately, a representative from National Fuel’s Government Affairs office agreed that he would alert the local towns and fire departments when maintenance activities would be occurring. It is surprising that this was not already standard practice.

Although Ms. Marmion is continuing to be a determined citizen activist, she has been met with a frustrating array of ambiguous and often conflicting descriptions, phone calls that go un-answered, voice mailboxes at offices that are either full or not set up to receive messages. Furthermore, although National Fuel has told Marmion that there is an Action Plan to be followed in the event of an emergency, they have been unable to provide her with a written or electronic version of this document, because “the action plan is just known.”

National Fuel points to the weather

National Fuel maintains that the only factor that was out of the ordinary was that during the event, a combination of unusual weather factors caused the released gas to travel in an unusual manner and also not dissipate as quickly as expected. National Fuel also indicated that the strong odor (created by the additive mercaptan) was a benefit to the local community, added to natural gas so that residents would be alerted to problems. It’s important to note that the largest gas transmissions pipelines, like the nearby 26” diameter Tennessee Gas Pipeline to the east of Elma and East Aurora, as well other pipelines that will run to the greatly expanded Porterville Compressor Station as part of the Northern Access Pipeline project, will be without the odorant.

Here’s what FracTracker could verify, based on National Weather Service, and Weather Underground historical data. In the morning and afternoon of February 7th, the wind was uncharacteristically blowing from the east/northeast — atypical for western New York, when winds normally come from the west. Wind speeds were recorded between 10-15 mph. Humidity was also uncharacteristically high for February — topping out at 93% that day. Warm air aloft, combined with freezing rain, created a temperature inversion. The moist air then trapped the odor, which lingered across the region.

weather_feb72017

feb72017_wind-data

Screen captures of weather statistics on February 7, 2017 (Source: wunderground.com). Note dominant wind direction from ENE, as well as high humidity, during morning and early afternoon, when incident took place.

Who monitors air quality in Western New York?

Calls by FracTracker for clarification from the New York State DEC’s Division of Air Resources have gone unanswered. The only station at which the DEC monitors methane is located more than 275 miles away to the southeast, in the Bronx. In Erie County, where the incident took place, there are only four permanent ambient air pollution monitoring stations. These include stations in:

  • Amherst: Continuous monitoring of ozone, NO2. Manual monitoring of PM5, acid deposition.
  • Buffalo: Continuous monitoring of SO2, NOx, NO, NO2, NOy, CO, CPM5. Manual monitoring of PM2.5, PM10, toxics
  • Brookside Terrace/Tonawanda: Continuous monitoring of SO2, CPM5. Manual monitoring of toxics and carbonyls
  • Grand Island (special purpose only): Continuous monitoring of CPM5. Manual monitoring of toxics and carbonyls

“PM” refers to particulate matter diameter. PM5, for example, denotes particulate matter 5 microns in diameter, and smaller.

The East Aurora and Elma fire departments lack the appropriate air quality detection instruments to make their own judgements on the explosive nature of these gas plumes. Instead, small towns rely on the expertise of National Fuel to arrive on the scene after a call has been made, so that National Fuel can take measurements and then respond to the community. Some residents waited over three hours for an assessment, but by this time the plume had drifted away two hours ago.

National Fuel, however, has not disclosed any of the air quality data measurements they made on February 7th when they responded to this complicated incident. Ms. Marmion and others still want to know what levels of methane were measured in the communities involved in this incident, or the specific quantity of gas that entered the air that day.

What’s next?

While National Fuel did not notify the residents or the school district administration in advance of the scheduled “blowdown,” their Government Affairs Representative indicated that in the future, town governments, community leaders, and the local fire companies would be alerted to the upcoming releases and maintenance work. Nonetheless, weeks after the odor incident, National Fuel has neither contacted the local community leaders, nor local law enforcement, to provide complete and detailed answers as to what actually happened on February 7th.

By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance. Special thanks to East Aurora resident Jennifer Marmion, for her insights and comments. 

For schools and hospitals analysis, 2017
Ted Auch, PhD

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

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A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities


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Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

Utica Class II Injection
Well Distance (Miles) Schools Medical Facilities Schools Medical Facilities
0.5 3 1 9 0
0.5-1 19 (22) 9 (10) 16 (25) 13 (13)
1-2 79 (101)  41 (51) 88 (113) 79 (92)
2-3 84 (185) 49 (100) 165 (278) 122 (214)
3-4 85 (270) 79 (179) 168 (446) 112 (326)
4-5 92 (362) 63 (242) 196 (642) 166 (492)
5-10 388 (750) 338 (580) 796 (1,438) 584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.

Ohio’s oil production in 2011
Ohio’s oil production in 2011
Ohio’s oil production in Q3-2014
Ohio’s oil production in Q3-2014

Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).

Ohio schools by grade level
Ohio schools by grade level
Ohio schools across school type
Ohio schools across school type

Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

Utica Class II Injection
Well Distance (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 3 1,360 453 7 3,312 473
<1 21 7,910 377 19 7,984 420
<2 96 35,390 376 90 41,565 462
<3 169 67,713 401 215 104,752 487
<4 241 97,448 404 350 176,067 503
<5 317 137,911 435 505 254,406 504
<10 600 280,330 467 1,126 569,343 506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.

Softball field and Injection well
Softball field and Injection well
Guernsey County Schools and Utica/Injection wells
Guernsey County Schools and Utica/Injection wells
Ed Lyons Class II SWD WEll and baseball field
Ed Lyons Class II SWD WEll and baseball field

Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

Utica Class II Injection
Distance from Well (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 . . . 1 . .
<1 . . . 2 25 13
<2 2 22 11 9 186 21
<3 7 874 125 30 4,460 149
<4 12 1,912 159 45 6,303 140
<5 21 2,471 118 61 9,610 158
<10 60 6,727 112 135 20,836 154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools


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Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.

figure6

Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

Marcellus Class II Injection
Distance from Well (Miles) # Sum Avg # Sum Avg
0.5 19 5,674 299 1 . .
<1 52 (71) 16,992 (22,666) 319 5 (6) 1,544 257
<2 169 (240) 52,737 (75,403) 314 16 (22) 5,032 (6,576) 299
<3 133 (373) 36,112 (111,515) 299 18 (40) 6,132 (12,708) 318
<4 88 (461) 25,037 (136,552) 296 21 (61) 5,235 (17,943) 294
<5 56 (517) 15,685 (152,237) 295 26 (87) 8,913 (26,856) 309
<10 118 (635) 37,131 (189,368) 298 228 (315) 69,339 (96,195) 305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.

Conclusion

A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

  1. their role in induced seismicity,
  2. potential water and air quality issues, and
  3. concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Koontz Class II Injection Well, Trumbull County, Ohio, (41.22806065, -80.87669281) with 260,278 barrels (10,020,704 gallons) of fracking waste having been processed between Q3-2010 and Q3-2012 (Note: Q1-2016 volumes have yet to be reported!).
Ted Auch, PhD

Ohio Shale Activity, Waste Disposal, and Public Water Supplies

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Ohio is unique relative to its Appalachian neighbors in the Marcellus and Utica Shale Basins in that The Buckeye State chose to “diversify” when it came to planning for the hydraulic fracturing revolution. One of the first things financial advisers tell their clients is to “diversify, diversify, diversify.” However, this strategy is usually meant to buffer investors when certain sectors of the economy underperform. Columbus legislators took this strategy to mean that we should drill and hydraulically fracture our geology to extract oil and gas (O&G), as well as taking in vast quantities of liquid and solid O&G waste from Pennsylvania and West Virginia.

Accepting significant quantities of out-of-state waste raises several critical questions, however. How will these materials will be contained? Will such volumes require more and larger waste landfills? And will the injection of liquid brine waste into our geology (photo below) make Ohio the “Oklahoma of Appalachia” with respect to induced seismicity?


Above: Example Class II salt water disposal (SWD) wells in Ohio

Risks to Public Water Supplies

There are also mounting concerns about public water supply (PWS) security, quality, and resilience. These concerns stem from the growing uncertainty surrounding the containment of hydraulically fractured and Class II injection wells.

To begin to assess the risks involved in locating these wells near PWS’s, we compiled and incorporated as many of the state’s PWS’s into our primary Ohio maps. In this post, we explore PWS proximity to Utica drilling activity and Class II salt water disposal (SWD) wells in Ohio.

Waste Disposal & Drilling Near PWS’s

Public water chartJust how close are public water supplies to Class II waste disposal wells and permitted Utica wells? As of January 15, 2017, there are 13 PWS’s within a half-mile of Ohio’s Class II SWD wells, and 18 within a half-mile of permitted Utica wells. These facilities serve approximately 2,000 Ohioans each, with an average of 112-153 people per PWS (Tables 1 and 5). Within one mile from these wells there are 64 to 66 PWSs serving 18 to 61 thousand Ohioans. That’s an average of 285-925 residents.

Above: Photos of SWD wells from the sky

While PWSs on the 5-mile perimeter of our analysis don’t immediately conjure up water quality/quantity concerns, they may in the future; the rate of Utica and Class II permitting is likely to accelerate under a new White House administration more friendly to industry and averse to enforcing or enhancing regulatory hurdles.

A total of 960 and 699 PWSs are currently within five miles of Ohio Class II and Utica wells. These facilities service roughly 1.5 million and one-half million Ohioans each day, which is ~13% and 4% of the state, respectively. The average PWS within range of Class II wells is 37% to 330 times the average PWS within range of Utica wells.

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Fifty-eight (58%) to 69% of the PWSs within range of Class II wells are what the Ohio EPA calls Transient Non-Community (TNC) (Table 2). TNC’s are defined by the OH EPA and OH Department of Agriculture as serving[1]:

…at least 25 different persons over 60 days per year. Examples include campgrounds, restaurants and gas stations. In addition, drinking water systems associated with agricultural migrant labor camps, as defined by the Ohio Department of Agriculture, are regulated even though they may not meet the minimum number of people or service connections.

Meanwhile 60-89% of PWS’s in the shadow of Ohio’s permitted Utica wells are of the TNC variety. Even larger percentages of these PWS’s are either Groundwater or Purchased Groundwater types. Most of the PWS’s within the range gradient we looked at are privately owned, with only handful owned by federal or state agencies (Table 6).

Above: Example Class II salt water disposal (SWD) wells in Ohio

Of the 24 hydrologic unit codes (HUCs)/watersheds that contain Class II SWD wells, the lion’s share of PWS’s within the shadow of injection wells are the Tuscarawas, Mahoning, and Walhonding (Table 3). Even the Cuyahoga River, which feeds directly in the Great Lakes, is home to up to 138 PWS’s within 5 miles of Class II SWD wells. Conversely, only 13 HUCs currently contain Ohio’s Utica wells. Like Class II-affected HUCs, we see that the Mahoning, Tuscarawas, and Cuyahoga PSW’s contain most of the PWSs of interest (Table 7).

Conclusion

Watershed security/resilience concerns are growing in Eastern Ohio. Residential and agricultural water demands are increasingly coming into conflict with the drilling industry’s growing freshwater demand. Additionally, as oil and gas drilling uses more water, we will see more brine produced (Figures 1 and 2).

This, in turn, will create more demand – on top of an already exponential trend (Figure 3) – for Ohio’s existing Class II wells from across Northern Appalachia, stretching from Southeast Ohio and West Virginia to North Central Pennsylvania.

An understanding of the links between watershed security, O&G freshwater demand, brine production, and frack waste disposal is even more critical in areas like Southeast Ohio’s Muskingum River Watershed (Figure 4).

A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz, E. 2015

Figure 4. A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz and Auch 2015

This is a region of the state where we have seen new water withdrawal agreements like the one below between the Muskingum River Watershed Conservancy District (MWCD) and Antero described in last week’s Caldwell Journal-Leader, Noble County, Ohio:

The [MWCD], which oversees 10 lakes in east central Ohio, approved a second short-term water sale from Seneca Lake last week. The deal, with Antero Resources, Inc., could net the district up to $9,000 a day over about a three month period, and allows Antero to draw up to 1.5 million gallons of water a day during the months of August, September and October for a total of 135 million gallons; less than one percent of the lake’s estimated volume of 14.2 billion gallons. Antero plans to use the water in its fracking operations in the area and will pay $6 per 1000 gallons drawn.

Consol Energy's Cowgill Road Impoundment, Sarahsville, Wills Creek, Noble County, Ohio, 39.8212, -81.4061

Consol Energy’s Cowgill Road Impoundment, Sarahsville, Wills Creek, Muskingum River Watershed, Noble County, Ohio, 39.8212, -81.4061

This agreement will mean an increase in new Class II SWD permits and/or discussion about converting Ohio’s thousands of other Class II wells into SWD wells. What does this change means for communities that have already seen the industry extract the equivalent of nearly 14% – and even 25-80% in several counties – of residential water from their watersheds, only to inject it 6,000+ feet into the state’s geology is unknown? (Figure 5)

It is critical that we establish and frequently revisit the spatial relationship between oil and gas infrastructure the water supplies of Appalachian Ohio. The state of national politics, federal agency oversight and administrations, growing concerns around climate change, and the fact that Southeast Ohio is experiencing more intense and infrequent precipitation events are testaments to that fact. We will be tracking these changes to Ohio’s landscape as they develop. Stay tuned.

Kleese Disposal Class II Salt Water Disposal Well, Trumbull County, Shenango/Mahoning River, 41.244, -80.641, 3,548,104 Barrels of Waste Disposed Between 2010 and Q3-2016

Kleese Disposal Class II Salt Water Disposal well from the sky, Trumbull County, Shenango/Mahoning River, 41.244, -80.641. Data suggest 3,548,104 barrels of waste have been disposed of there between 2010 and Q3-2016.

Supplemental Tables

Public Water and Class II Wells

Table 1. Number of Ohio public water supplies and population served at several intervals from Class II Injection wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 13 1,992 153 (±120) 446
<1 66 60,539 917 (±4,702) 37,456
<2 198 278,402 1,406 (±4,374) 37,456
<3 426 681,969 1,601(±8,187) 148,000
<4 681 1,086,463 1,596 (±8,284) 148,000
<5 960 1,450,865 1,511 (±7,529) 148,000

 

Table 2. Ohio public water supplies by system type, source, and ownership at several intervals from Class II Injection wells

 

Well Distance (Miles)

 System Type† Source†† Ownership
 

NTNC

  

TNC

  

C

  

G

  

GP

  

S

  

SP

  

Private

  

Local

  

Fed

  

State
0.5 3 9 1 13 13
<1 11 47 8 65 1 61 5
<2 30 118 50 177 16 5 164 34
<3 76 245 105 385 32 8 351 75
<4 122 392 167 628 40 12 574 106 1
<5 162 564 234 878 30 32 19 823 135 1 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

Table 3. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from Class II Injection wells

 

HUC Name

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula-Chagrin, 799 1 5 18 18 22
Black-Rocky, 859 1 1 2 2 9
Cuyahoga, 832 1 8 20 92 92 138
Grand, 811 12 30 71 71 81
Hocking, 1081 4 18 18 22
Licking, 1010 1 2 17 17 29
Little Muskingum-Middle Island, 1062 1 2 2 6
Lower Maumee, 856 2 2 4
Lower Scioto, 1091 6 6 9
Mahoning, 831 9 17 48 129 129 161
Mohican, 919 1 3 3 4
Muskingum, 1006 1 3 15 15 33
Raccoon-Symmes, 1128 1
Sandusky, 862 3 19 19 27
Shenango, 815 1 2 6 10 10 11
St. Mary’s, 934 3 5 5 7
Tiffin, 837 4 4 7
Tuscarawas, 889 1 9 76 147 147 213
Upper Ohio, 901 3 15 15 23
Upper Ohio-Shade, 1120 4 8 8 9
Upper Ohio-Wheeling, 984 1 1 4 4 5
Upper Scioto, 959 5 13 13 23
Walhonding, 906 1 11 26 69 69 101
Wills, 1009 2 3 12 12 14

 

Table 4. Ohio public water supplies by county at several intervals from Class II Injection wells

 

County

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 4 9 16 19 22
Athens 1 2 2 3
Auglaize 3 5 5 7
Belmont 1 4 5 6
Carroll 2 9 20
Columbiana 1 2 6 13 20 32
Coshocton 7 8 10 13
Crawford 1
Cuyahoga 1
Delaware 1
Fairfield 4
Franklin 1 3 7
Fulton 2 4 8
Gallia 1
Geauga 8 19 33 60 71
Guernsey 2 4 10 11 11
Harrison 1 1
Henry 2 3 3
Henry 2 3
Hocking 3 10 11 13
Holmes 1 11 34 25 38 47
Jefferson 1 3 3 5
Knox 2 6 8 9
Lake 1 4 7 17 18
Licking 1 2 10 14 26
Lorain 1 4
Mahoning 3 4 13 25 37 48
Medina 1 1 1 2 5
Meigs 4 5 6 7
Morgan 1 1 1 6 17
Morrow 3 8 11 11
Muskingum 3 8 15
Noble 1 2 2 3
Perry 5 6 8
Pickaway 2 3 7 10
Portage 3 12 41 62 90 113
Seneca 1 12 17 21
Stark 1 4 20 52 121 161
Summit 2 12 26 51
Trumbull 3 7 24 32 45 61
Tuscarawas 6 10 22 24 26
Washington 1 2 4 9
Wayne 1 1 9 18 24 54
Wyandot 2 2 2 3

Public Water and Hydraulically Fractured Wells

Table 5. The number of Ohio public water supplies and population served at several intervals from hydraulically fractured Utica Wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 18 2,010 112 (±72) 31
<1 64 17,879 279 (±456) 2,598
<2 235 116,682 497 (±1,237) 8,728
<3 433 257,292 594 (±2,086) 29,787
<4 572 380,939 666 (±2,404) 29,787
<5 699 496,740 711 (±2,862) 47,348

 

Table 6. Ohio public water supplies by system type, source, and ownership at several intervals from hydraulically fractured Utica Wells

 

Well Distance (Miles)

 System Type† Source†† Ownership
 

NTNC

  

TNC

  

C

  

G

  

GP

  

S

  

SP

  

Private

  

Local

  

Fed

  

State
0.5 1 16 1 17 1 18
<1 9 45 10 59 3 1 1 58 6
<2 50 137 48 216 6 3 10 206 29
<3 83 265 85 400 14 5 14 381 51 1
<4 109 352 111 534 16 7 15 504 67 1
<5 141 421 137 652 19 9 18 621 77 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

 

Table 7. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from hydraulically fractured Utica wells

 

HUC Name

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Black-Rocky, 859 1 4 4 4
Cuyahoga, 832 2 12 31 54 82
Grand, 811 1 15 18 23
Licking, 1010 2 2 3 3
Little Muskingum-Middle Island, 1062 2 5 10 11 11
Mahoning, 831 2 5 48 105 142 175
Muskingum, 1006 3 7 9 11
Shenango, 815 2 5 10 13 14
Tuscarawas, 889 8 28 87 140 178 220
Upper Ohio, 901 7 20 45 66 72 73
Upper Ohio-Wheeling, 984 1 13 23 27 28
Walhonding, 906 10 15 34 47
Wills, 1009 2 3 5 7 8

 

 

Table 8. Ohio public water supplies by county at several intervals from hydraulically fractured Utica wells

 

County

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 1 1
Belmont 1 2 7 14 15 16
Carroll 6 20 36 43 43 43
Columbiana 4 15 45 72 80 81
Coshocton 7 10 10
Geauga 14 20 25
Guernsey 1 1 2 4 5
Harrison 2 6 16 16 16 16
Holmes 5 13 31 43
Jefferson 2 3 11 22 25 25
Knox 1 1 2 2
Licking 1 1 1 1
Mahoning 2 10 32 44 55
Medina 1 4 5 7
Monroe 2 4 6 6 6
Muskingum 1 1 1 2 3
Noble 2 2 2 2
Portage 2 8 25 49 84
Stark 2 5 40 85 110 122
Summit 6 10
Trumbull 3 23 36 53 65
Tuscarawas 1 2 15 22 28 43
Washington 3 10 12 13
Wayne 5 5 7 21

Footnote

  1. Community (C) = serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. Examples include cities, mobile home parks and nursing homes; Non-Transient, Non-Community (NTNC) = serve at least 25 of the same persons over six months per year. Examples include schools, hospitals and factories.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Shell Ethane Cracker
FracTracker Alliance

A Formula for Disaster: Calculating Risk at the Ethane Cracker

/by

by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project

On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.

As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?

Known Ethane Cracker Risks

A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.

disaster-risk-infographic-websize

Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.

williams-geismar-explosion-websize

U.S. Chemical Safety and Hazard Investigation Board, Williams Geismar Case Study, No. 2013-03-I-LA, October 2016.

We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.

For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.

The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.

Potential Risks & Shell’s Mixed Messages

Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”

However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.

Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)

Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.

 

Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limited accessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.

Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?

Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.

Opening the Floodgates

In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.

Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.

Ethane Cracker Hazards Map


View map fullscreen | How FracTracker maps work

While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.

What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.

Final Calculations

As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.

The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.

Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.

Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.

The Environmental Integrity Project is a nonpartisan, nonprofit watchdog organization that advocates for effective enforcement of environmental laws. 

Map of PA drilling complaints - collaboration with Public Herald
FracTracker Alliance

PA Fracking Complaints are Increasing, Systemic

/by

The Pennsylvania Department of Environmental Protection (DEP) logs incoming complaints from residents about drilling activity in the Commonwealth, and Public Herald has spent a great deal of time aggregating and making that information public. A recent investigation by Public Herald into that data, with help from FracTracker, has highlighted a number of concerning issues related to fracking in Pennsylvania unfortunately.

Concerning Complaints

Firstly, the data they reviewed indicate that complaints from residents about unconventional drilling (how most fracked wells are designated) are more common than those about traditional wells. Secondly, it seems that complaints about fracked wells are increasing over time, even though the number of new wells has decreased.

There may be several reasons for such trends, and Public Herald discusses some of them in their new report. Are fracking wells more likely to fail, resulting in a higher proportion of complaints from nearby residents? Or has tracking simply improved in recent years? What these trends undoubtably indicate, however, is that the impacts from drilling have been systemic, according to Drs. Ingraffea and Stolz, who also reviewed the data.

Probably the most troubling finding unearthed in this investigation is that the PA DEP was not transparent about complaint data. The information they released to Public Herald differed wildly from the spreadsheets previously obtained by other requestors. Learn more about this and other issues in Public Herald’s Hidden Data Report.

Read Public Herald Report

Digging into the Data

Below we have included a map showing where those complaints originated, as well as a table that parses out the data by county.

Pennsylvania Oil & Gas Complaint Map


View map fullscreen | How FracTracker maps work

The above map by Public Herald and FracTracker Alliance shows the density of citizen complaints reported to the Department of Environmental Protection from 2004 – 2016. It includes conventional and unconventional well complaints. Clicking on a township reveals a database of complaints where viewers can download files.

In addition to the report issued by Public Herald, you can explore the data mapped above in the table below. It fleshes out how many complaints have been issued by residents, where these complaints originated, and how many are specific to water issues.

Table 1. PA Unconventional Well Complaint Statistics Logged by the PA DEP

DEP Office County Total Complaints (#) Water Complaints (#) Municipalities w/Complaints (#) Drilled Unconventional Wells, Jan 2004 – Nov 29 2016
TOTALS
PENNSYLVANIA 47 9442 4108 893 10027
SWRO 3653 1427 328 3587
NWRO 3197 1159 284 1027
NCRO (ERO) 2592 1522 281 5413
BY COUNTY
SWRO Washington 1066 460 51 1478
ERO Susquehanna 648 393 32 1326
ERO Bradford 647 468 43 1371
SWRO Greene 576 156 26 1082
NWRO McKean 550 121 21 134
SWRO Westmoreland 538 219 43 270
NWRO Warren 443 106 26 3
NWRO Butler 419 186 35 497
SWRO Armstrong 388 208 38 223
SWRO Indiana 367 153 32 48
ERO Tioga 349 212 30 907
SWRO Fayette 335 121 28 291
NWRO Mercer 276 153 31 61
NWRO Venango 273 108 25 6
NWRO Crawford 258 141 35 3
NWRO Jefferson 244 113 29 56
ERO Lycoming 242 110 32 927
SWRO Allegheny 228 30 53 100
NWRO Clarion 186 89 23 28
NWRO Forest 177 56 8 22
ERO Clearfield 175 70 34 150
ERO Wyoming 167 92 19 258
NWRO Erie 164 17 30 0
NWRO Elk 143 37 9 146
ERO Potter 108 60 25 91
ERO Sullivan 86 47 8 127
SWRO Beaver 67 44 25 62
NWRO Lawrence 64 32 12 71
SWRO Somerset 44 16 18 26
SWRO Cambria 43 20 13 7
ERO Clinton 40 16 8 107
ERO Bedford 36 25 7 1
ERO Centre 33 10 9 65
ERO Luzerne 19 1 10 2
ERO Wayne 14 4 7 5
ERO Lackawanna 6 3 3 2
ERO Columbia 5 1 2 3
ERO Blair 4 3 2 6
ERO Cameron 4 2 2 64
ERO Huntingdon 2 2 1 1

SWRO = Southwest Regional Office; NWRO = Northwest Regional Office; NCRO (ERO) = North Central/Eastern Regional Office. Find your office here.

Read Public Herald Report
Stay Tuned

Public Herald will be releasing Part 2 of their Hidden Data report soon!

FracTracker Alliance

Mariner East 2: At-Risk Schools and Populations

/by

by Kirk Jalbert, Manager of Community-Based Research & Engagement
with technical assistance from Seth Kovnant

 

In September, the Pennsylvania Department of Environmental Protection (DEP) rejected a number of permits for wetland crossings and sedimentation control that were required for Sunoco Pipeline’s proposed “Mariner East 2” pipeline. According to Sunoco, the proposed Mariner East 2 is a $2.5 billion, 350-mile-long pipeline that would be one of the largest pipeline construction projects in Pennsylvania’s history.

If built, Mariner East 2 could transport up to 450,000 barrels (18,900,000 gallons) per day of propane, ethane, butane, and other liquefied hydrocarbons from the shale fields of western Pennsylvania to export terminals in Marcus Hook, located just outside Philadelphia. A second proposed pipeline, if constructed, could carry an additional 250,000 barrels (10,500,000 gallons) per day of these same materials. Sunoco submitted revised permit applications to PADEP on Tuesday, December 6th.

The industry often refers to ethane, propane and butane collectively as “natural gas liquids.” They are classified by the federal government as “hazardous, highly volatile liquids,” but that terminology is also misleading. These materials, which have not been transported through densely populated southeast Pennsylvania previously, are liquid only at very high pressure or extremely cold temperatures. At the normal atmospheric conditions experienced outside the pipeline, these materials volatilize into gas which is colorless; odorless; an asphyxiation hazard; heavier than air; and extremely flammable of explosive. This gas can travel downhill and downwind for long distances while remaining combustible. It can collect (and remain for long periods of time) in low-lying areas; and things as ordinary as a cell phone, a doorbell or a light switch are capable of providing an ignition source.

Many who have followed the proposed Mariner East 2 project note that, while much has been written about the likely environmental impacts, insufficient investigation has been conducted into safety risks to those who live, work and attend schools in the proposed pipeline’s path. We address these risks in this article, and, in doing so, emphasize the importance of regulatory agencies allowing public comments on the project’s resubmitted permit applications.

The Inherent Risks of Artificially Liquified Gas

Resident of Pennsylvania do not need to look far for examples of how pipeline accidents pose serious risk. For instance, the 2015 explosion of the Enterprise ATEX (Appalachia to Texas) pipeline near Follansbee, WV, provides a depiction of what a Mariner East 2 pipeline failure could look like. This 20-inch diameter pipeline carrying liquid ethane is similar in many ways to the proposed Mariner East 2. When it ruptured in rural West Virginia, close to the Pennsylvania border, it caused damage in an area that extended 2,000 feet—about ½ square mile—from the place where the pipeline failed.

In another recent instance, the Spectra Energy Texas Eastern methane natural gas pipeline ruptured in Salem, PA, this April as a result of corroded welding. The explosion, seen above (photo by PA NPR State Impact), completely destroyed a house 200ft. away. Another house, 800ft. away, sustained major damage and its owner received 3rd degree burns. These incidents are not unique. FracTracker’s recent analysis found that there have been 4,215 pipeline incidents nation-wide since 2010, resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion (“incident” is an industry term meaning “a pipeline failure or inadvertent release of its contents.” It does not necessarily connote “a minor event”).

Calculating Immediate Ignition Impact Zones

It is difficult to predict the blast radius for materials like ethane, propane and butane. Methane, while highly flammable or explosive, is lighter than air and so tends to disperse upon release into the atmosphere. Highly volatile liquids like ethane, propane and butane, on the other hand, tend to concentrate close to the ground and to spread laterally downwind. A large, dispersed vapor cloud of these materials may quickly spread great distances, even under very light wind conditions. A worst-case scenario would by highly variable since gas migration and dispersion is dependent on topography, leak characteristics, and atmospheric conditions. In this scenario, unignited gas would be allowed to migrate as an unignited vapor cloud for a couple miles before finding an ignition source that causes an explosion that encompasses the entire covered area tracing back to the leak source. Ordinary devices like light switches or cell phones can serve as an ignition source for the entire vapor cloud. One subject matter expert recently testified before a Municipal Zoning Hearing board that damage could be expected at a distance of three miles from the source of a large scale release.

The federal government’s “potential impact radius” (PIR) formula, used for natural gas (methane) isn’t directly applicable because of differences in the characteristics of the material. It may however be possible to quantify an Immediate Ignition Impact Zone. This represents the explosion radius that could occur if ignition occurs BEFORE the gas is able to migrate.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) provides instructions for calculating the PIR of a methane natural gas pipeline. The PIR estimates the range within which a potential failure could have significant impact on people or property. The PIR is established using the combustion energy and pipeline-specific fuel mass of methane to determine a blast radius: PIR = 0.69*sqrt(p*d^2). Where: PIR = Potential Impact Radius (in feet), p = maximum allowable operating pressure (in pounds per square inch), d = nominal pipeline diameter (in inches), and 0.69 is a constant applicable to natural gas

The Texas Eastern pipeline can use the PIR equation as-is since it carries methane natural gas. However, since Mariner East 2 is primarily carrying ethane, propane, and butane NGLs, the equation must be altered. Ethane, propane, butane, and methane have very similar combustion energies (about 50-55 MJ/kg). Therefore, the PIR equation can be updated for each NGL based on the mass density of the flow material as follows: PIR = 0.69*sqrt(r*p*d^2). Where: r = the density ratio of hydrocarbons with similar combustion energy to methane natural gas. At 1,440 psi, methane remains a gas with a mass density 5 times less than liquid ethane at the same pressure:

ME2 PIR table 1

The methane density relationships for ethane, propane, and butane can be used to calculate an immediate-ignition blast radius for each hydrocarbon product. The below table shows the results assuming a Mariner East 2-sized 20-inch diameter pipe operating at Mariner East 2’s 1,440psi maximum operating pressure:

ME2 PIR table 2

Using these assumptions, the blast radius can be derived as a function of pressure for each hydrocarbon for the same 20in. diameter pipe:

ME2 Immediate Ignition Blast Radius

ME2 Immediate Ignition Blast Radius

Note the sharp increase in blast radius for each natural gas liquid product. The pressure at which this sharp increase occurs corresponds with the critical pressure where each product transitions to a liquid state and becomes significantly denser, and in turn, contains more explosive power. These products will always be operated above their respective critical pressures when in transport, meaning their blast radius will be relatively constant, regardless of operating pressure.

Averaging the “Immediate Ignition Blast Radius” for ethane, propane, and butane gives us a 1,300 ft (about 0.25 mile) potential impact radius. However, we must recognize that this buffer represents a best case scenario in the event of a major pipeline accident.

Additional information on these calculations can be found in the Delaware County-based Middletown Coalition for Community Safety’s written testimony to the Pennsylvania Legistlature.

Living near the Mariner East 2

FracTracker has created a new map of the Mariner East 2 pipeline using a highly-detailed GIS shapefile recently supplied by the DEP. On this map, we identify a 0.5 mile radius “buffer” from Mariner East 2’s proposed route. We then located all public and private schools, environmental justice census tracts, and estimated number of people who live within this buffer in order to get a clearer picture of the pipeline’s hidden risks.

Proposed Mariner East 2  and At-Risk Schools and Populations

View map fullscreen | How FracTracker maps work

 

Populations at Risk

In order to estimate the number of people who live within this 0.5 mile radius, we first identified census blocks that intersect the hazardous buffer. Second, we calculated the percentage of that census block’s area that lies within the buffer. Finally, we used the ratio to determine the percentage of the block’s population that lies within the buffer. In total, there are an estimated 105,419 people living within the proposed Mariner East 2’s 0.5 mile radius impact zone. The totals for each of the 17 counties in Mariner East 2’s trajectory can be found in the interactive map. The top five counties with the greatest number of at-risk residents are:

  1. Chester County (31,632 residents in zone)
  2. Delaware County (17,791 residents in zone)
  3. Westmoreland County (11,183 residents in zone)
  4. Cumberland County (10,498 residents in zone)
  5. Berks County (7,644 residents in zone)

Environmental Justice Areas

Environmental justice designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. These numbers are based on data from the U.S. Census Bureau, last updated in 2010, and by the federal poverty guidelines. Mariner East 2 crosses through four environmental justice areas:

  • Census Tract 4064.02, Delaware County
  • Census Tract 125, Cambria County
  • Census Tract 8026, Westmoreland County
  • Census Tract 8028, Westmoreland County

DEP policies promise enhanced public participation opportunities in environmental justice communities during permitting processes for large development projects. No additional public participation opportunities were provided to these communities. Furthermore, no public hearings were held whatsoever in Cambria County and Delaware County. The hearing held in Westmoreland County took place in Youngwood, nine miles away from Jeanette. Pipelines are not specified on the “trigger list” that determines what permits receive additional scrutiny, however the policy does allow for “opt-in permits” if the DEP believes they warrant special consideration. One would assume that a proposed pipeline project with the potential to affect the safety of tens of thousands of Pennsylvanians qualifies for additional attention.

At-Risk Schools

One of the most concerning aspects of our findings is the astounding number of schools in the path of Mariner East 2. Based on data obtained from the U.S. Department of Education on the locations of schools in Pennsylvania, a shocking 23 public (common core) schools and 17 private schools were found within Mariner East 2’s 0.5 mile impact zone. In one instance, a school was discovered to be only 7 feet away from the pipeline’s intended path. Students and staff at these schools have virtually no chance to exercise their only possible response to a large scale release of highly volatile liquids, which is immediate on-foot evacuation.

me2-middletown-high

Middletown High School in Dauphin County in close proximity to ME2

One reason for the high number of at-risk schools is that Mariner East 2 is proposed to roughly follow the same right of way as an older pipeline built in the 1930s (now marketed by Sunoco as “Mariner East 1.”). A great deal of development has occurred since that time, including many new neighborhoods, businesses and public buildings. It is worth noting that the U.S. Department of Education’s data represents the center point of schools. In many cases, we found playgrounds and other school facilities were much closer to Mariner East 2, as can be seen in the above photograph. Also of note is the high percentage of students who qualify for free or reduced lunch programs at these schools, suggesting that many are located in disproportionately poorer communities.

Click here to view a complete list of at-risk schools

 

Conclusion

Now that PADEP has received revised permit applications from Sunoco, presumably addressing September’s long list of technical deficiencies, the agency will soon make a decision as to whether or not additional public participation is required before approving the project. Given the findings in our analysis, it should be clear that the public must have an extended opportunity to review and comment on the proposed Mariner East 2. In fact, public participation was extremely helpful to DEP in the initial review process, providing technical and contextual information.

It is, furthermore, imperative that investigations into the potential impacts of Mariner East 2 extend to assess the safety of nearby residents and students, particularly in marginalized communities. Thus far, no indication has been made by the DEP that this will be the case. However, the Pennsylvania Sierra Club has established a petition for residents to voice their desire for a public comment period and additional hearings.

Seth Kovnat is the chief structural engineer for an aerospace engineering firm in Southeastern PA, and regularly consults with regard to the proposed Mariner East 2 pipeline. In November, Seth’s expertise in structural engineering and his extensive knowledge of piping and hazardous materials under pressure were instrumental in providing testimony at a Pennsylvania Senate and House Veterans Affairs and Emergency Preparedness Committee discussion during the Pennsylvania Pipeline Infrastructure Citizens Panel. Seth serves on the board of Middletown Coalition for Community Safety and is a member of the Mariner East 2 Safety Advisory Committee for Middletown Township, PA. He is committed to demonstrating diligence in gathering, truth sourcing, and evaluating technical information in pipeline safety matters in order to provide data driven information-sharing on a community level.

NOTE: This article was modified on 12/9/16 at 4pm to provide additional clarification on how the 1,300ft PIR was calculated, and the map was modified on 11/4/2021 to add the 1,300 ft Thermal Impact Zone Buffer, which was previously mislabeled as the half-mile Buffer

Oil and gas production on public lands
Guest Author

Interactive maps show nearness of oil and gas wells to communities in 5 states

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As an American, you are part owner of 640 million acres of our nation’s shared public lands managed by the federal government. And chances are, you’ve enjoyed a few of these lands on family picnics, weekend hikes or summer camping trips. But did you know that some of your lands may also be leading to toxic air pollution and poor health for you or your neighbors, especially in 5 western states that have high oil and gas drilling activity?

A set of new interactive maps created by FracTracker, The Wilderness Society, and partner groups show the threatened populations who live within a half mile of  federal oil and gas wells – people who may be breathing in toxic pollution on a regular basis.

Altogether, air pollution from oil and gas development on public lands threatens at least 73,900 people in the 5 western states we examined. The states, all of which are heavy oil and gas leasing areas, include Colorado, New Mexico, North Dakota, Utah and Wyoming.

Close up of threat map in Colorado

Figure 1. Close up of threat map in Colorado

In each state, the data show populations living near heavy concentrations of wells. For example just northeast of Denver, Colorado, in the heavily populated Weld County, at least 11,000 people are threatened by oil and gas development on public lands (Figure 1).

Western cities, like Farmington, New Mexico; Gillette, Wyoming; and Grand Junction, Colorado are at highest risk of exposure from air pollution. In New Mexico, especially, concentrated oil and gas activity disproportionately affects the disadvantaged and minorities. Many wells can be found near population centers, neighborhoods and even schools.

Colorado: Wells concentrated on Western Slope, Front Range

Note: The threatened population in states are a conservative estimate. It is likely that the numbers affected by air pollution are higher.

In 2014, Colorado became the first state in the nation to try to curb methane pollution from oil and gas operations through comprehensive regulations that included inspections of oil and gas operations and an upgrade in oil and gas infrastructure technology. Colorado’s new regulations are already showing both environmental and financial benefits.

But nearly 16,000 people – the majority living in the northwestern and northeastern part of the state – are still threatened by pollution from oil and gas on public lands.

Many of the people whose health is endangered from pollution are concentrated in the fossil-fuel rich area of the Western Slope, near Grand Junction. In that area, three counties make up 65% of the total area in Colorado threatened by oil and gas development.

In Weld County, just northeast of Denver, more than 11,000 residents are threatened by air pollution from oil and gas production on federal lands. But what’s even more alarming is that five schools are within a half mile radius of wells, putting children at risk on a daily basis of breathing in toxins that are known to increase asthma attacks. Recent studies have shown children miss 500,000 days of school nationally each year due to smog related to oil and gas production.

State regulations in Colorado have helped improve air quality, reduce methane emissions and promote worker care and safety in the past two years, but federal regulations expected by the end of 2016 will have a broader impact by regulating pollution from all states.

New Mexico: Pollution seen from space threatens 50,000 people

With more than 30,000 wells covering 4.6 million acres, New Mexico is one of the top states for oil and gas wells on public lands. Emissions from oil and gas infrastructure in the Four Corners region are so great, they have formed a methane hot spot that has been extensively studied by NASA and is clearly visible from space.

Nearly 50,000 people in northwestern New Mexico – 40% of the population in San Juan County – live within a half mile of a well. 

Dangerous emissions from those wells in San Juan County disproportionately affect minorities and disadvantaged populations, with about 20% Hispanic, almost 40% Native American, and over 20% living in poverty.

Another hot spot of oil and activity is in southeastern New Mexico stretching from the lands surrounding Roswell to the southern border with Texas. Wells in this region also cover the lands outside of Carlsbad Caverns National Park, potentially affecting the air quality and visibility for park visitors. Although less densely populated, another 4,000 people in two counties – with around 50% of the population Hispanic – are threatened by toxic air pollution.

Wyoming: Oil and gas emissions add to coal mining pollution

Pollution from oil and gas development in Wyoming, which has about as many wells as New Mexico, is focused in the Powder River Basin. This region in the northeast of the state provides 40% of the coal produced in the United States.

Oil and gas pollution threatens approximately 4,000 people in this region where scarred landscapes and polluted waterways are also prevalent from coal mining. 

With the Obama administration’s current pause on federal coal leasing and a review of the federal coal program underway, stopping pollution from oil and gas on public lands in Wyoming would be a major step in achieving climate goals and preserving the health of local communities.

Utah: Air quality far below federal standards

Utah has almost 9,000 active wells on public lands. Oil and gas activity in Utah has created air quality below federal standards in one-third of Utah’s counties, heightening the risk of asthma and respiratory illnesses. Especially in the Uintah Basin in northeastern Utah – where the majority of oil and development occurs – a 2014 NOAA-led study found oil and gas activity can lead to high levels of ozone in the wintertime that exceed federal standards.

North Dakota: Dark skies threatened by oil and gas activity

The geology of western North Dakota includes the Bakken Formation, one of the largest deposits of oil and gas in the United States. As a result, high oil and gas production occurs on both private and public lands in the western part of the state.

Nearly 650 wells on public lands are clustered together here, directly impacting popular recreational lands like Theodore Roosevelt National Park.

The 70,000-plus-acre park – named after our president who first visited in 1883 and fell in love with the incredible western landscape – is completely surrounded by high oil and gas activity. Although drilling is not allowed in the park, nearby private and public lands are filled with active wells, producing pollution, traffic and noise that can be experienced from the park. Due to its remote location, the park is known for its incredible night sky, but oil and gas development increases air and light pollution, threatening visibility of the Milky Way and other astronomical wonders.

You own public lands, but they may be hurting you

Pollution from oil and gas wells on public lands is only a part of a larger problem. Toxic emissions from oil and gas development on both public and private lands threaten 12.4 million people living within a half mile of wells, according to an oil and gas threat map created by FracTracker for a project by Earthworks and the Clean Air Task Force.

Now that we can see how many thousands of people are threatened by harmful emissions from our public lands, it is more important than ever that we finalize strong federal regulations that will help curb the main pollutant of natural gas – methane – from being leaked, vented, and flared from oil and gas infrastructure on public lands.

Federal oil and gas wells in western states produce unseen pollution that threatens populations at least a half mile away. Photo: WildEarth Guardians, flickr.

Federal oil and gas wells in western states produce unseen pollution that threatens populations at least a half mile away. Photo: WildEarth Guardians, flickr.

We need to clean up our air now

With U.S. public lands accounting for 1/5 of the greenhouse gas footprint in the United States, we need better regulations to reduce polluting methane emissions from the 96,000 active oil and gas wells on public lands.

Right now, the Bureau of Land Management is finalizing federal regulations that are expected by the end of 2016. These regulations are expected to curb emissions from existing sources – wells already in production – that are a significant source of methane pollution on public lands. This is crucial, since by 2018, it is estimated that nearly 90% of methane emissions will come from sources that existed in 2011.

Federal regulations by the BLM should also help decrease the risk to communities living near oil and gas wells and helping cut methane emissions by 40 to 45% by 2025 to meet climate change reduction goals.

Final regulations from the Bureau of Land Management will also add to other regulations from the EPA and guidance from the Obama administration to modernize energy development on public lands for the benefit of the American people, landscapes and the climate. In the face of a changing climate, we need to continue to monitor fossil fuel development on public lands and continue to push the government towards better protections for land, air, wildlife and local communities.

By The Wilderness Society – The Wilderness Society is the leading conservation organization working to protect wilderness and inspire Americans to care for our wild places. Founded in 1935, and now with more than 700,000 members and supporters, The Wilderness Society has led the effort to permanently protect 109 million acres of wilderness and to ensure sound management of our shared national lands.

Screenshot from Vulnerable Populations Map
Kyle Ferrar, MPH

Sensitive Receptors near Fracked Oil & Gas Wells

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EnvironmentAmerica_reportcover

Cover of Dangerous and Close report. Click to view report

FracTracker Alliance has been working with the Frontier Group and Environment America on a nationwide assessment of “fracked” oil and gas wells. The report is titled Dangerous and Close, Fracking Puts the Nation’s Most Vulnerable People at Risk. The assessment analyzed the locations of fracked wells and identified where the fracking has occurred near locations where sensitive populations are commonly located. These sensitive sites include schools and daycare facilities because they house children, hospitals because the sick are not able to fight off pollution as effectively, and nursing homes where the elderly need and deserve clean environments so that they can be healthy, as well. The analysis used data on fracked wells from regulatory agencies and FracFocus in nine states. Maps of these nine states, as well as a full national map are shown below.

No one deserves to suffer the environmental degradation that can accompany oil and gas development – particularly “fracking” – in their neighborhoods. Fracked oil and gas wells are shown to have contaminated drinking water, degrade air quality, and sicken both aquatic and terrestrial ecosystems. Additionally, everybody responds differently to environmental pollutants, and some people are much more sensitive than others. In fact, certain sects of the population are known to be more sensitive in general, and exposure to pollution is much more dangerous for them. These communities and populations need to be protected from the burdens of industries, such as fracking for oil and gas, that have a negative effect on their environment. Commonly identified sensitive groups or “receptors” include children, the immuno-compromised and ill, and the elderly.  These groups are the focus of this new research.

 

National Map

National interactive map of sensitive receptors near fracked wells


View Map Fullscreen | How Our Maps Work

State-By-State Maps in Dangerous and Close Report

Click to view interactive maps associated with each state

Arkansas

California

Colorado

New Mexico

North Dakota

Ohio

Pennsylvania

Texas

West Virginia

Approaching 10K Unconventional Wells in PA
Matt Kelso, BA

Approaching 10K Unconventional Wells in PA

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By Matt Kelso, Manager of Data & Technology

Each state has its own definition of what it means for an oil or gas well to be “fracked.” In Pennsylvania, these wells are known as “unconventional,” a definition mostly based on the depth of the target formation:

An unconventional gas well is a well that is drilled into an unconventional formation, which is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.

The count of these unconventional wells in PA stands at 9,760 as of June 14, 2016. Their distribution is widespread across the state, but is particularly focused in the northeast and southwest corners of Pennsylvania.

Unconventional oil and gas wells in Pennsylvania:

View map full screen | How FracTracker maps work

Wells Drilled

The industry is not drilling at the same torrid pace as it was between 2010 and 2012, however. The busiest month for drill rigs in the Keystone State was August 2011, with 210 unconventional wells drilled. Last month, there were just 32 such wells.

Unconventional wells in PA: Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Figure 1. Unconventional oil and gas permits, wells, and violations in Pennsylvania by quarter. Data source: Pennsylvania DEP

Permits

As Figure 1 captures, the number of permits issued per quarter is always greater than the number of wells drilled during the same time period. Even when drilling activity seems to be entering a bust phase, oil and gas operators continue to plan for future development. Altogether, there are 17,492 permitted locations, meaning there are about 7,700 permitted locations where drilling has not yet commenced.

Violations

The number of violations issued by DEP is generally follows the same trends as permits and wells. It is usually the smallest of the three numbers. In the first quarter of 2016, however, is one of a few instances on the chart above where the number of violations issued outpaced wells drilled. There could be any number of reasons for this anomaly; it could have been due to to unusual compliance issued in the field or aggressive regulatory blitzes. It could also be due to some other factor that can’t be determined by the available published data source.

Interestingly, this phenomenon has not occurred since the first quarter of 2010, when the industry was in full swing.

About VpW

One of the best ways to understand the impact of the industry is to look at violations per well (VpW). Unfortunately, there are a number of important caveats to that discussion. First of all, not all items that appear on the compliance report receive their own Violation ID number. It is clear from the DEP workload report that violations are tallied internally by the number of Violation ID numbers. This is as opposed to the number of items on the compliance report. As of June 14, 2016, there were 6,706 rows of data and 5,755 distinct Violation ID numbers that were issued to 2,080 different oil and gas wells. This discrepancy means that about 21% of unconventional wells are issued violations in Pennsylvania. Those that are cited receive an average of 2.8 to 3.2 violations per well, depending on how you count them.

Unconventional Wells in PA: Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Table 1. Violations per well (VpW) of the 20 companies with the most unconventional wells in PA.

Determining the violations per well by operator comes with additional caveats. The drilled wells data comes from the spud report, which lists the current operator of each of the wells. The compliance report, however, lists the operator that was in charge of the well at the time of the infraction. This poses a problem for analysis, however. The ownership of the wells is quite fluid when taken in aggregate, as companies fold, are bought out, or change their names to something else.

VpW Results

We calculated VpW figures for the 20 operators with the largest inventory of drilled wells wells in Pennsylvania, found in Table 1. In some instances, we were able to reunite operators with violations that were issued under a different name but are in fact the same company. Specifically, we combined Rex Energy’s violations with RE Gas Dev, CONSOL violations with CNX, and Southwestern with SWN Productions, as the company is now known.

SWN’s violation-per-well score appears to be quite low. Their statistic, however, does not take into account wells that it purchased from Chesapeake in 2014, for example. In this transaction, 435 wells changed hands, with an unknown number of those in Pennsylvania. Any violations on these wells that Chesapeake had would stay with that company even as their well count was reduced. Such a change would thereby artificially inflate Chesapeake’s VpW score. On the other hand, SWN is now in possession of a number of wells which might have been problematic during the early stages of operation. Those violations, alternatively, are not associated with SWN, making their inventory of wells appear to be less problematic.

Data Caveats and Takeaways

Alas, we do not live in a world of perfect data. As such, these results must be taken with a grain of salt. Still, we can see that there are some trends that persist among operators that have been active in Pennsylvania for many years. Chief, Cabon, and EXCO, for example, all average more than one violation per well drilled. Chevron, CNX, and RE Gas Development, on the other hand, have much better rates of compliance, on the order of one violation per every five wells drilled.

FracTracker Alliance

Drilling Bella Romero: Children at Risk in Greeley, Colorado

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By
Kirk Jalbert, Manager of Community Based Research & Engagement
Kyle Ferrar, Western Program Coordinator

Weld County, Colorado, is one of the top producing shale oil and gas regions in the United States, boasting more than 12,000 active horizontal or directional wells, which account for 50% of all horizontal or directional wells in the state. To put this into perspective, the entire state of Pennsylvania has ten times the land area with “only” 9,663 horizontal or directional wells. At the center of Weld County is the city of Greeley, population 92,889. Greeley has experienced dramatic changes in the past decade as extraction companies compete to acquire oil and gas mineral rights. Extensive housing developments on the outskirts of the city are being built to accommodate future well pads on neighboring lots. Meanwhile, a number of massive well pads are proposed within or on the border of city limits.

FracTracker visited Colorado back in November 2015 and met with regional advocacy organizations including Coloradans Against Fracking, Protect our Loveland, Weld Air and Water, and Our Longmont to determine how we could assist with data analysis, mapping, and digital storytelling. FracTracker returned in June 2016 to explore conditions unique to Weld County’s oil and gas fields. During our visit we interviewed residents of Greeley and found that one of their greatest concerns was the dangers of siting oil and gas wells near schools. While there is much more we will be publishing in coming weeks about our visit, this article focuses on one troubling project that would bring gas drilling to within 1,300ft of a public school. The proposal goes before the Weld County Commissioners on Wednesday, June 29th for final approval. As such, we will be brief in pointing out what is at stake in siting industrial oil and gas facilities near schools in Colorado and why residents of Greeley have cause for concern.

Drilling Bella Romero

On June 7th, the Weld County Planning Commission unanimously approved a proposal from Denver-based Extraction Oil & Gas to develop “Vetting 15H”—a 24-head directional well pad in close proximity to Bella Romero Academy, a middle school just outside Greeley city limits. In addition to the 24-head well pad would be a battery of wastewater tanks, separators, and vapor recovery units on an adjacent lot. The permit submitted to the Colorado Oil & Gas Conservation Commission (COGCC) also states that six more wells may be drilled on the site in the future.

As was detailed in a recent FracTracker article, Colorado regulations require a minimum setback distance of 500ft from buildings and an additional 350ft from outdoor recreational areas. In more populated areas, or where a well pad would be within 1,000ft of high occupancy buildings, schools, and hospitals, drilling companies must apply for special variances to minimize community impacts. Setbacks are measured from the well head to the nearest wall of the building. For well pads with multiple heads, each well must comply with the respective setback requirements.

bella_romero_playground

Bella Romero’s playground with Vetting 15H’s proposed site just beyond the fence.

Vetting 15H would prove to be one of the larger well pads in the county. And while its well heads remain just beyond the 1,000ft setback requirement from Bella Romero buildings, a significant portion of the school’s ballfields are within 1,000ft of the proposed site. When setbacks for the well pad and the processing facility are taken together—something not explicitly demonstrated in the permit—almost the entirety of school grounds are within 1,000ft and the school itself lies only 1,300ft from the pad. The below figures show the images supplied by Extraction Oil & Gas in their permit as well as a more detailed graphic generated by FracTracker.

 

Youth: A High Risk Population

The difference between 1,000ft and 1,300ft may be negligible when considering the risks of locating industrial scale oil and gas facilities near populated areas. The COGCC has issued 1,262 regulatory violations to drilling companies since 2010 (Extraction Oil & Gas ranks 51st of 305 operators in the state for number of violations). Some of these violations are for minor infractions such as failing to file proper paperwork. Others are for major incidents; these issues most often occur during the construction phases of drilling, where a number have resulted in explosions and emergency evacuations. Toxic releases of air and water pollution are not uncommon at these sites. In fact, the permit shows drainage and potential spills from the site would flow directly towards Bella Romero school grounds as is shown in the figure below.

Vetting 15H post-development drainage map.

Vetting 15H post-development drainage map.

A host of recent research suggests that people in close proximity to oil and gas wells experience disproportionate health impacts. Emissions from diesel engine exhaust contribute to excessive levels of particular matter, and fumes from separators generate high levels of volatile organic compounds. These pollutants decrease lung capacity and increase the likelihood of asthma attacks, cardiovascular disease, and cancer (read more on that issue here). Exposure to oil and gas facilities is also linked to skin rashes and nose bleeds.

As we’ve mentioned in our analysis of oil and gas drilling near schools in California, children are more vulnerable to these pollutants. The same amount of contaminants entering a child’s body, as opposed to an adult body, can be far more toxic due to differences in body size and respiratory rates. A child’s developing endocrine system and neural pathways are also more susceptible to chemical interactions. These risks are increased by children’s lifestyles, as they tend to spend more hours playing outdoors than adults and, when at school, the rest of their day is spent at a central location.

At the June 7th public hearing Extraction Oil & Gas noted that they intend to use pipelines instead of trucks to transport water and gas to and from Vetting 15H to reduce possible exposures. But, as residents of Greeley noted of other projects where similar promises were made and later rescinded, this is dependent on additional approvals for pipelines. Extraction Oil & Gas also said they would use electric drilling techniques rather than diesel engines, but this would not eliminate the need for an estimated 22,000 trucking runs over 520 days of construction.

Below is a table from the Vetting 15H permit that shows daily anticipated truck traffic associated with each phase of drilling. The estimated duration and operational hours of each activity are based on only 12 wells since construction is planned in two phases of 12 wells at a time. These numbers do not account for the trucking of water for completions activities, however. The figures could be much higher if pipelines are not approved, as well as if long-term trucking activities needed to maintain the site are included in the estimates.

Vetting 15H daily vehicle estimates.

Vetting 15H daily vehicle estimates from permit

 

At the Top of the Most Vulnerable List

Bella Romero Academy has the unfortunate distinction of being one of the few schools in Colorado in close proximity to a horizontal or directional well amongst 1,750 public and 90 private schools in the state. Based on our analysis, there are six public schools within 1,000ft of a horizontal or directional well. At 2,500ft we found 39 public schools and five private schools. Bella Romero is presently at the top of the list of all schools when ranked by number of well heads located within a 1,000ft buffer. An 8-head well pad is only 800ft across the street from its front door. If the Vetting 15H 24-head well pad was to be constructed, Bella Romero would be far and above the most vulnerable school within 1,000ft of a well. It would also rank 3rd in the state for well heads located within 2,500ft of a school. The tables below summarize our findings of this proximity analysis.

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 1,000ft of a horizontal or directional well

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total.

Colorado public schools within 2,500ft of a horizontal or directional well with 5 or more well heads. There are 39 schools in total

Colorado private schools within 2,500ft of a horizontal or directional well

Colorado private schools within 2,500ft of a horizontal or directional well

The following interactive map shows which schools in Colorado are within a range of 2,500ft from a directional and horizontal well. Additional buffer rings show 1,000ft and 500ft buffers for comparison. 1,000ft was selected as this is the minimum distance required by Colorado regulations from densely populated areas and schools without requiring special variances. Environmental advocacy groups are presently working to change this number to 2,500ft. The map is zoomed in to show the area around Bella Romero. Zoom out see additional schools and click on features to see more details. [NOTE: The Colorado school dataset lists Bella Romero Academy as an elementary/middle school. Bella Romero was recently split, with the elementary school moving a few blocks west.]

Map of schools and setbacks in Colorado

View map full screen | How FracTracker maps work

Environmental Injustice

Drilling near Bella Romero is also arguably an environmental justice issue, as its student population has some of the highest minority rates in the county and are amongst the poorest. According to coloradoschoolgrades.com, Bella Romero is 89% Hispanic or Latino and 3% African American whereas, according to the U.S. Census Bureau, Greeley as a whole is 59% White and 36% Hispanic or Latino. 92% of Bella Romero’s students are also from low income families. Furthermore, according to the EPA’s Environmental Justice Screening Tool, which is used by the agency to assess high risk populations and environments, the community surrounding Bella Romero is within the 90-95% percentile range nationally for linguistically isolated communities.

Many of Bella Romero's students come from low-income communities surrounding Greeley.

Many of Bella Romero’s students come from low-income communities surrounding Greeley.

 

Implications

These statistics are significant for a number of reasons. Firstly, oil and gas permitting in Colorado only requires operators to notify residents immediately surrounding proposed well pads. This rule does not include residents who may live further from the site but send their students to schools like Bella Romero. Parents who might comment on the project would need to hear about it from local papers or neighbors, but language barriers can prevent this from occurring. Another factor we witnessed in our June visit to Latino communities in Weld County is that many students have undocumented family members who are hesitant to speak out in public, leaving them with no voice to question risks to their children.

Residents of Greeley speak out at the June 7th Planning Commission meeting.

Residents of Greeley speak out at the June 7th Planning Commission meeting

Nevertheless, at the June 7th Planning Commission hearing, Weld County administrators insisted that their decisions would not take race and poverty into consideration, which is a blatant disregard for EPA guidelines in siting industrial development in poor minority communities. Weld County’s Planning Commission claimed that their ruling on the site would be the same regardless of the school’s demographics. By comparison, another proposed Extraction Oil & Gas site that would have brought a 22-head well pad to within 1,000ft of homes in a more well off part of town was denied on a 0-6 vote by the City of Greeley’s Planning Commission earlier this year after nearby residents voiced concerns about the potential impacts. Extraction Oil & Gas appealed the ruling and Greeley City Council passed the proposal in a 5-2 vote pending additional urban mitigation area permit approval. While the Greeley Planning Commission and the Weld County Planning Commission are distinct entities, the contrast of these two decisions should emphasize concerns about fair treatment.

Conclusion

There are very real health concerns associated with siting oil and gas wells near schools.  When evaluating this project, county administrators should assess not only the immediate impacts of constructing the well pad but also the long-term effects of allowing an industrial facility to operate so close to a sensitive youth population. There are obvious environmental justice issues at stake, as well. Public institutions have a responsibility to protect marginalized communities such as those who send their children to Bella Romero. Finally, approving the Vetting 15H project would place Bella Romero far at the top of the list for schools in Colorado within 1,000ft of oil and gas wells. School board administrators should be concerned about this activity, as it will undoubtedly put their students’ health and academic performance at risk. We hope that, when the County Commissions review the proposal, these concerns will be taken into account.

June 29, 2016 Update

Weld County approves huge gas development; commissioners blister critics.