Overhead view of injection well
Ted Auch, PhD

The Hidden Inefficiencies and Environmental Costs of Fracking in Ohio

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

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

Well Volumes

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

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

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

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

Oil and Gas Production in Ohio

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

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

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

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

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

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

 

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

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

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

Water demands for oil and gas production in Ohio

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

Waste Disposal

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

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

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

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

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

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

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

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

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

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

But wait, here is the real stunner:

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

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

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

Conclusion

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

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

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

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

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

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

Data Downloads

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

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

Ohio Hydraulic Fracturing Freshwater and Groundwater Withdrawals from 2010 to 2018

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

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

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

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

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

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

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

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Matt Kelso, BA

Fracking in Pennsylvania: Not Worth It

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

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

Production

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

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

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

Fracked Gas Production and Consumption in Pennsylvania from 2013 through 2018

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

 

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

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

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

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

 

Waste

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

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

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

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

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

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

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

 

Drilled Wells

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

 

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

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

 

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

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

Violations

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

Unconventional fracked wells drilled and violations issued from 2005 through 2019

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

 

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

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

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

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

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

Bloated With Gas, Fraught With Trouble

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

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

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

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

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

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

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

 

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Captina Creek Watershed FeaturePhoto by Ted Auch, FracTracker Alliance
Ted Auch, PhD

Fracking Threatens Ohio’s Captina Creek Watershed

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FracTracker’s Great Lakes Program Coordinator Ted Auch explores the risks and damages brought on by fracking in Ohio’s Captina Creek Watershed

 

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The Captina Creek Watershed straddles the counties of Belmont and Monroe in Southeastern Ohio and feeds into the Ohio River. It is the highest quality watershed in all of Ohio and a great examples of what the Ohio River Valley’s tributaries once looked, smelled, and sounded like. Sadly, today it is caught in the cross-hairs of the oil and gas industry by way of drilling, massive amounts of water demands, pipeline construction, and fracking waste production, transport, and disposal. The images and footage presented in the story map below are testament to the risks and damage inherent to fracking in the Captina Creek watershed and to this industry at large. Data included herein includes gas gathering and interstate transmission pipelines like the Rover, NEXUS, and Utopia (Figure 1), along with Class II wastewater injection wells, compressor stations, unconventional laterals, and freshwater withdrawal sites and volumes.

Ohio Rover NEXUS Pipelines map

The image at the top of the page captures my motivation for taking a deeper dive into this watershed. Having spent 13+ years living in Vermont and hiking throughout The Green and Adirondack Mountains, I fell in love with the two most prominent tree species in this photo: Yellow Birch (Betula alleghaniensis) and Northern Hemlock (Tsuga candadensis). This feeling of being at home was reason enough to be thankful for Captina Creek in my eyes. Seeing this region under pressure from the oil and gas industry really hit me in my botanical soul. We remain positive with regards to the area’s future, but protective action against fracking in the Captina Creek Watershed is needed immediately!

Fracking in the Captina Creek Watershed: A Story Map

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Kyle Ferrar, MPH

California is Frack Free, for the Moment

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Intern FracTracker

How State Regulations Hold Us back and What Other Countries are doing about Fracking

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By Isabelle Weber, FracTracker Alliance Spring 2019 Intern 

Feature photo of oil and gas drilling in North Dakota, and is by by Nick Lund, NPCA, 2014

 

Although there are some federal regulations in place to protect the environment indirectly from fracking in the United States, the regulations that try to keep fracking in check are largely implemented at the state governing level. This has led to a patchwork of regulations that differ in strictness from state to state. This leads to the concern that there will be a race to the bottom where states lower the strictness of their regulations in order to draw in more fracking. While it might be tempting to welcome an industry that often creates a temporary economic spike, the costs of mitigating the environmental damage from fracking far out-weighs the profit gained. Germany, Scotland, and France are examples of countries that have taken more appropriate regulatory measures to protect their populations from the risks involved in unconventional oil and gas development.

The Shortfalls of State by State Regulations

For a detailed overview of how fracking regulation differs between states, check out the Resources for the Future report, The State of State Shale Gas Regulation, which analyzes 25 regulatory elements and how they differ between states. Two of their maps that attest to this vast difference in regulation are the “Fracturing Fluid Disclosure Requirements” map as well as the “Venting Regulations” map.

The “Fracturing Fluid Disclosure Requirements” map shows regulatory differences between states regarding whether or not the chemical mixture used to break up rock formations must be made known to the public. “Disclosure” means that the chemical mixture is made known to the public and “No Regulation” means that there is nothing that obligates companies to share this information, which usually implies this information is not available.

Fig 1. Map of fracking fluid disclosure requirements by state, from Resources for the Future’s report, “The State of State Shale Gas Regulation.” Original data from US Energy Information Administration.

 

Note from the editor: There are several exemptions that allow states to limit the scope of reporting chemicals used in underground fluid injection for fracking. For example, all states that require chemical disclosure are entitled to exemptions for chemicals that are considered trade secrets.  

Concealing the identity of chemicals increases the risk of harm from chemical exposure for people and the environment. Emergency first responders are especially at risk, as they may have to act quickly to put out a fracking-induced fire without knowing the safety measures necessary to avoid exposure to dangerous chemicals. The population at large is at risk of exposure though several pathways such as leaks, spills, and air emissions. Partnership for Policy Integrity, along with data analysis by FracTracker, investigated the implications of keeping the identity of certain fracking chemicals secret in two states, Ohio and Pennsylvania. These reports point to evidence that exposure to concealed fracking chemicals could have serious health effects including blood toxicity, developmental toxicity, liver toxicity and neurotoxicity.

 

The second map, “Venting Regulations,” shows which states have regulations that limit or ban venting and which do not. Venting is the direct release of methane from the well site into the atmosphere. Methane has 30 times the green-house gas effect as carbon dioxide. Given methane’s severe impact on the environment, no venting whatsoever should be allowed at well sites.

Fig 2. Map of fracking venting regulations by state, from Resources for the Future’s report, “The State of State Shale Gas Regulation.” Original data from US Energy Information Administration.

Having overarching federal regulatory infrastructure to regulate fracking would help to avoid risks such as toxic chemical exposure and accelerated climate change. Although leaving regulation development to states allows for more specialized laws, there are certain aspects of environmental protection that apply to every area in the United States and are necessary as standard protection against the effects of fracking.

How do other countries regulate fracking?

Stronger federal regulation of fracking has worked well in the past and can be seen in several other countries.

Germany

In 2017, Germany passed new legislation that largely banned unconventional hydraulic fracking. The ban on unconventional fracking excludes four experimental wells per state that will be commissioned by the German government to an independent expert commission to identify knowledge gaps and risks with regards to fracking. Conventional fracking also received tighter regulations including a ban on fracking near drinking water sources. In 2021, the ban will be reevaluated, taking into account research results, public perception, long term damage to residents and the environment, and technological advances. This is a perfect example of how a country can use overarching federal regulation to make informed decisions about industry action.

Scotland

In 2015, Scotland placed a moratorium into effect that halted all fracking in the country. Since 2017, the government has held that the moratorium will stand indefinitely as an effective ban on fracking in the country, but the country is still working on the legislature that will officially ban fracking. Meanwhile, the Scottish government conducted one of the most far-reaching investigations into unconventional oil and gas development, which included a four-month public consultation period. This public consultation garnered 65,000 responses, 65% of which were from former coal mining communities targeted by the fracking industry. Of those responses, 99% of responses opposed fracking.

The Scottish people should be applauded for holding their federal government accountable in fulfilling its responsibility to protect its people and its environment against the effects of fracking.

France

In December 2017, France passed a law that bans exploration and production of all oil and natural gas by the year 2040. This applies to mainland France as well as all French territories. Although France has limited natural gas resources, it is hoped that the ban will be contagious and spread to other countries. This is a prime example of a country making a decision to protect their environment through regulation.

Although France’s banning of fracking was largely symbolic and may not result in a considerable reduction of greenhouse gases related to natural gas exploration, the country is sending a message to the world that we need to facilitate the end of the fossil fuel era and a move toward renewables.

Back to the US, the world’s leading producer of natural gas

Federal regulation on fracking should be holding the oil and gas industry in check by requiring states to meet basic measures to protect people and the environment. States could then develop more stringent regulations as they see fit. It is important that we come to a national consensus on the environmental and health hazards of fracking, and consequently, to adopt appropriate federal regulations.


By Isabelle Weber, FracTracker Alliance Spring 2019 Intern

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Guest Author

New Method for Locating Abandoned Oil and Gas Wells is Tested in New York State

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Guest blog by Natalia N. Romanzo, graduate student, Binghamton University, Binghamton, NY

 

Innovations in geospatial remote sensing technology developed by a research team at Binghamton University’s Geophysics and Remote Sensing Laboratory allow for improved detection of unplugged oil and gas wells. Implementing this technology would allow responsible agencies to more efficiently locate, and then plug, the 30,000+ undocumented oil and gas wells in New York State. Plugging these wells would help residents to assess risks of any wells on or near their property, improve air quality, and keep New York State on track to reaching its greenhouse gas emissions targets.

 

Dangers of Unplugged Orphan Oil and Gas Wells

In 2018, the United States Environmental Protection Agency (EPA) estimated that nationwide, there were 3.11 million abandoned oil and gas wells. Sixty-nine percent — or 2.15 million — of these wells are not even plugged. Many were drilled prior to the existence of state regulatory programs, subsequently abandoned by their original owners or operators over a century ago, and then left unplugged or poorly plugged. State and federal regulators are in the process of plugging these wells, but the process is slow; many are still unplugged today.

Unplugged or incorrectly plugged wells can leak methane into drinking water and the atmosphere. As a greenhouse gas, methane in the atmosphere is more than 80 times more effective at trapping heat than carbon dioxide, and, as such, becomes a driving mechanism of global warming. Methane has come under scrutiny by climate scientists and other concerned with the relationship between unconventional gas drilling (“fracking”) and the climate crisis.

Anthropogenic methane is the cause of a quarter of today’s global warming, and the oil and gas industry is a leading source of these emissions. Every year, oil and gas companies release an estimated 75 million metric tons of methane globally, an amount of gas sufficient to provide electricity for all of Africa twice over. Unplugged wells are often high emitters contributing to this energy waste. A study of almost 140 wells in Wyoming, Colorado, Utah, and Ohio found that more than 40% of unplugged wells leak methane, compared to less than 1% of plugged wells.

Unplugged, incorrectly plugged, as well as active wells can all leak methane. Methane-leaking wells are especially problematic when their locations are undocumented or unknown. Until they are located, undocumented wells that remain unplugged can continue to emit methane into the atmosphere and into drinking water. For example, in Pennsylvania, methane was detected in water samples at average concentrations six times higher in homes less than one kilometer from oil and gas wells. The potential negative impact of unplugged orphan oil and gas wells makes this a pressing environmental concern.

Of the more than 3 million problematic oil and gas wells nationwide, over 35,000 unplugged oil and gas wells may exist in New York State alone. Unplugged or improperly plugged wells that leak methane can pose direct threats to New York State residents, especially for people living nearby to these wells. Many New York State residents are unaware that they have an unplugged well on their property, and could be at risk of potential exposure to uncontrolled releases of gas or fluids from unplugged orphan wells. In one case in Rushville, New York, two dozen unplugged wells emitted methane at explosive levels. An unplugged well in Rome, New York discharged brine to the land surface for decade at a rate of 5 gallons per minute, killing an acre of wetland vegetation. If these wells had been located and assessed, property owners would be better informed and safer.

In addition to directly harming New York State residents and contributing to climate change, unplugged orphan wells also impact New York State’s ability to reach its 2030 emissions targets. New York State recently set ambitious statewide greenhouse gas emissions targets through the Climate Leadership and Community Protection Act to lower emissions by 85% by 2050. However, New York State has only reduced emissions 8% from 1990-2015 levels. If New York State is to reach its emissions targets, it must continue and improve its efforts to locate, assess, and ultimately plug all its orphan oil and gas wells.

Inaccurate Records and Inefficient Detection Methods

The New York State Department of Environmental Conservation (DEC) is responsible for task of mitigating and preventing damage caused by oil and gas wells. Unfortunately, flaws in record keeping have made it difficult to locate undocumented wells. The DEC began record keeping of oil and gas wells in 1983 and took on regulatory authority over wells drilled in the state after 1983. There are strict rules and regulations for plugging wells drilled after 1983, and wells drilled prior to 1983 must comply with applicable regulations. Nevertheless, many older wells are still unaccounted for. In their external review in 1994, staff estimated that 61,000 wells had been developed prior to 1983. However, the agency only has records on about 30,000 of them. Because accurate records do not exist for old wells, it is difficult to monitor, and even locate, them.

Click here for a full-screen view of FracTracker Alliance’s map of all known wells in New York State (data current as of October 2018, to be updated soon).

 

View map fullscreen | How FracTracker maps work

Despite inaccurate records, the DEC does try to locate, assess, and plug old wells using maps created by drilling companies in the late 1800s. A section of one such map can be seen in Figure 1. This map shows proposed oil and gas drilling sites in Cattaraugus County, New York in the late 1800s. It has been georeferenced using ArcGIS  mapping software to assign present day coordinates to hand drawn features.

Figure 1. Georeferenced Lease Map, Cattaraugus County, New York

Unfortunately, these maps are not entirely reliable. Some wells may be incorrectly documented on a map as drilled when, in fact, they were merely proposed but never drilled; some wells may have been drilled but never marked on a map. Other wells may have been both marked on a map and drilled, but due to inaccurate survey technologies of the past, the location on the ground is incorrect. As a result, DEC staff are left searching on foot for wells that may or may not be there. Working with limited equipment, in dense brush, and over uneven terrain make the task of finding the abandoned wells even more problematic.

These traditional methods of detection, which include referencing lease maps and searching for wells in the field, are not only time consuming, but are also costly. Using traditional methods of well detection, between 1988 and 2009, the United States Bureau of Land Management spent $3.8 million and only successfully reclaimed 295 well sites. It is clear that on both the federal and state levels, traditional well detecting methods are expensive, cumbersome, and inefficient.

Drones Pave the Way for Oil and Gas Well Detection

Recent improvements in geospatial remote sensing technology have opened opportunities for more efficient well detection. Previously, the battery life of drones and the weight of magnetometers prevented the two technologies from being used together to locate oil and gas wells. Furthermore, because drones must be flown high enough to clear vegetative canopies, methane sensors attached to drones are too far away from the source to accurately detect the location of the well. Due to these technological barriers, the DEC and other environmental departments and agencies have had to rely on inefficient, traditional methods of well detection described above.

At Binghamton University’s Geophysics and Remote Sensing Laboratory, a research team headed by Professors Timothy de Smet and Alex Nikulin, along with graduate student Natalia Romanzo, and undergraduate students Samantha Wong, Judy Li, and Ethan Penner, is taking on the task of developing a more efficient method to locate oil and gas wells. The Binghamton University research team deployed drones equipped with magnetometers to demonstrate that a high-resolution, low-altitude magnetic survey can successfully locate unmarked well sites.

Oil and gas wells have a characteristic magnetic signal that is generated by vertical metal piping fixed in the ground, making them identifiable in a magnetic survey.

Figure 2a. Oil and Gas Well Detected at 40m AGL showing LiDAR Total Horizontal Derivative of the site.

The magnetic signal generated by a well is shown in red in Figure 2b. At 40 meters above ground level (AGL), tree canopies are cleared, while the magnetic anomaly of the well is distinguishable. This drone-based magnetometer method has shown promising results.

Figure 2b. Magnetic Anomaly of an Oil and Gas Well Detected at 40m AGL, showing total magnetic intensity of the site.

To further test remote sensing techniques, the Binghamton University research team worked with Charles Dietrich and Nathan Graber from the NYS DEC to compare the efficiency of different survey methods. Currently, researchers are conducting fieldwork to compare the efficiency of traditional methods of well detection, well detection via a magnetic ground survey, and well detection via a drone-based magnetic survey. This research is showing that using drones equipped with magnetometers is a more efficient way to survey a wide area where wells may be present.

Remote sensing techniques can allow the DEC to more efficiently locate, and then plug, the 30,000+ undocumented oil and gas wells in New York State. Using this new method of well detection, the DEC will be able to inform residents who have unplugged wells on their property, assess the risks of the wells, and plug harmful wells. Residents with wells on or near their property will benefit directly. In addition, and more broadly, New Yorkers will enjoy improved air quality while New York State will be more on track to reaching its emissions targets.

FracTracker thanks Natalia Romanzo for her guest blog contribution. We feel that this technology holds promise for communities impacted by drilling across the nation.

For answers to specific questions about the project, you can email Natalia directly at nromanz1@binghamton.edu.

 

Ohio Secret Fracking Chemicals Report
Shannon Smith

Ohio’s Secret Fracking Chemicals

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Intern FracTracker

Abandoned Wells in Pennsylvania: We’re Not Doing Enough

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By Isabelle Weber, FracTracker Alliance Spring 2019 Intern 

Fracking in Pennsylvania: The History

When driving through Pennsylvania, you can see what an impact oil and gas has had on the state. Towns like Oil City and Petrolia speak to the oil and gas industry’s long standing history here. In more recent history, Pennsylvania has been a prime fracking location because of the presence of the Marcellus shale formation that covers over half of the state. With more unconventional oil and gas exploration came impacts to communities, who were denied their right to “clean air, pure water, and the preservation of the natural, scenic, historic, and esthetic values of the environment” as defined by the Pennsylvania Constitution.

Hydraulically fractured wells are often no longer profitable after just one stimulation, after which they are abandoned. Improperly abandoned wells wreak havoc on our communities and our environment. The number of improperly abandoned wells has been increasing over time as companies go bankrupt transfer wells to other companies. These wells can easily go undetected because they are often buried underground, leaving no traces at the surface level.

These unplugged abandoned wells are underneath our homes, our schools, and in our own backyards, negatively impacting our health and the environment.

FracTracker’s West Coast Coordinator Kyle Ferrar shows how abandoned wells are hiding all around us in his investigation of downtown Los Angeles. He used an infrared camera to visualize the plumes of methane and other volatile organic compounds spewing out of abandoned wells in the middle of streets.

 

Dangers of unplugged abandoned wells

The plugging process consists of filling the well with cement, ensuring that nothing leaks from the well into the surrounding ecosystem. Without that measure in place, the chemical-water solution used to frack the underlying shale, as well as any oil or natural gas still left in the well, can very easily seep into nearby aquifers or into close by waterways. Wells that are not plugged or are not plugged properly leak into nearby aquifers, releasing methane and other volatile organic compounds are continually released from the well into the atmosphere as well. This leakage into the atmosphere and ground water can have disastrous effects on our ecosystem and health.

Abandoned wells are also a dangerous threat because many of their locations are unknown. These wells can ruin the structural integrity of buildings and homes that are unknowingly built on top of them. The methane leaking out of the well is colorless and odorless, meaning that it can easily build-up in homes or elsewhere and cause explosions.

 Bankruptcy and Bonds

When an oil and gas company drills a well, they are responsible for making sure that it is plugged properly at the end of the well’s life. This is the case even if the company goes bankrupt. To do this, Pennsylvania government requires that the company put up a bond that is set aside to plug the well properly. This ensures that if the company does go bankrupt, the necessary funds are already set aside to plug the well. Normally, this bond takes the shape of a blanket bond amount of $25,000 which is intended to cover the total expenses that would be incurred in plugging all of the wells a company has in the state. Depending on the number of wells a company possesses, this could mean very little actually being set aside for each individual well.

A shallow well can cost between $8,000 to $10,000 plus, and up to $50,000 or more depending on how difficult it is to plug. In the case of Pennsylvania’s top oil and gas holder Diversified Gas & Oil PLC and its recently acquired. Company Alliance Petroleum Corp, this bond sets aside just $2 per well. With most other companies holding no more than 5,700 wells, this sets aside $4.40 per well. Where the bond amounts fall short in accounting for the cost to plug the hundreds of thousands of abandoned wells across the state, the rest of the cost falls at the feet of taxpayers.

The New Contract

The state government has started to recognize the severity of the situation as they are confronted with a mountain of costs in plugging these wells. To start to mitigate this, the government has recently settled with Diversified Gas & Oil. The company has been ordered to properly plug 1,058 abandoned wells. To do this they have signed on to a $7 million bond with $20,000 to $30,000 bonds for each additional abandoned or non-producing well that is acquired.

Although it is a great start to ensure that these two major companies have the proper bonding amount moving forward, this does not apply to all companies, whose likelihood of going bankrupt puts a lot of financial pressure on Pennsylvanian citizens. Also, these 1,058 wells are only the tip of the iceberg, with the DEP estimating that there are between 100,000 and 560,000 total abandoned wells in Pennsylvania, many of which still have unknown locations.

In the 2017 Pennsylvania Oil and Gas Report, it is stated that: “Currently, more abandoned wells are being added to the state’s inventory than are being addressed through permanent plugging through state-issued contracts. Since 2015, DEP has been able to fund the plugging of oil and gas wells only in emergency situations and/or when residents must be temporarily evacuated from their homes due to imminent threats that legacy wells pose when well integrity is compromised.” They continue on by stating that, considering the historic operating costs and acknowledging the sheer number of wells, properly addressing es the abandoned wells will cost between $150 million and $3.7 billion. The $150 million is an estimation based on the scenario that no more historic legacy wells are discovered, and the $3.7 billion is based on if 200,000 more are found, a more likely scenario.

The funding to cover the costs of plugging these abandoned wells comes from surcharges of $150 and $200 established by the 1984 Oil and Gas Act for each oil well permit and gas well permit. The DEP has received fewer permits in recent years meaning that there are very little funds to resolve this issue. This means that eventually this public health and environmental burden will have to fall at the feet of the taxpayers.

This makes the state’s step in the right direction look more like a tip toe. With no real, substantial plans to locate and address the large amount of wells across the state, the government is putting their people at risk because these abandoned wells are not harmless.

Washington County Case study

 Washington County can be used as a window into the abandoned well crisis in Pennsylvania. This county sits in the middle of the Marcellus Shale formation, making it a key site for unconventional oil and gas development. According to the DEP, there are 215 abandoned, orphaned wells in Washington county, but realistically we know that there are likely many  more than that.

The Pennsylvania Spatial Data Access (PASDA) has derived a dataset from historical sources to determine the possible locations of other abandoned wells. These historical documents include the WPA, Ksheet, and Hsheet collections. This data set highlights over 6,000 locations where an abandoned oil and gas well could be located.

 

View map fullscreen | How FracTracker maps work

This is a testament to how many of these wells exist without our knowledge. If this difference in DEP records and possible wells is this great in Washington County, then we face the enormous potential problem of tens of thousands of additional abandoned wells that need to be resolved. The effects of these wells are real and they must be identified quickly.

These are some of the physical effects of abandoned wells:

 

Fig 1. A Collapsed Well Opening – A Physical Hazard (photo credit: Friends of Oil Creek State Park)

Fig. 2. Well Spouting Acid Water. Well later plugged by DEP (photo credit: Friends of Oil Creek State Park)

Fig. 3. Oil Seepage (photo credit:(photo credit: Friends of Oil Creek State Park)

 

Fig. 4. Abandoned Well and Storage Tank (photo credit: Friends of Oil Creek State Park)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Conclusion

Pennsylvania is facing a mountain of an issue with decades of work ahead. The state must act quickly to ensure the health and protection of our people and our environment, which entails taking active steps to secure an adequate budget to resolve this issue. To start, the state should identify where all of the wells are, set up a financial plan that puts the cost of the plugging process for these wells back onto the oil and gas companies, and begin to take active measures to plug the wells quickly and efficiently.

Shannon Smith

Wildness Lost – Pine Creek

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Ted Auch, PhD

The Underlying Politics and Unconventional Well Fundamentals of an Appalachian Storage Hub

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FracTracker is closely mapping and following the petrochemical build-out in Appalachia, as the oil and gas industry invests in petrochemical manufacturing. Much of the national attention on the build-out revolves around the Appalachian Storage Hub (ASH), a venture spearheaded by Appalachian Development Group.

The ASH involves a network of infrastructure to store and transport natural gas liquids and finds support across the political spectrum. Elected officials are collaborating with the private sector and foreign investors to further development of the ASH, citing benefits such as national security, increased revenue, job creation, and energy independence.

Left out of the discussion are the increased environmental and public health burdens the ASH would place on the region, and the fact that natural gas liquids are the feedstock of products such as plastic and resins, not energy.

The “Shale Revolution”

the allegheny plateau

The Allegheny Plateau. Wikipedia

The “Shale Revolution” brought on by high-volume hydraulic fracturing (fracking) in this region encompasses thousands of wells drilled into the Marcellus and Utica-Point Pleasant shale plays across much of the Allegheny Plateau. This area spans from north of Scranton-Wilkes Barre, Pennsylvania, just outside the Catskills Mountains to the East in Susquehanna County, Pennsylvania, and down to the West Virginia counties of Logan, Boone, and Lincoln.  The westernmost extent of the fracking experiment in the Marcellus and Utica shale plays is in Noble and Guernsey Counties in Ohio.

Along the way, producing wells have exhibited steeper and steeper declines during the first five years of production, leading the industry to develop what they refer to as “super laterals.” These laterals (the horizontal portion of a well) exceed 3 miles in length and require in excess of 15 million gallons of freshwater and 15,000 tons of silica sand (aka, “proppant”)[1].

The resource-intense super laterals are one way the industry is dealing with growing pressure from investors, lenders, the media, state governments, and the public to reduce supply costs and turn a profit, while also maintaining production. (Note: unfortunately these sources of pressures are listed from most to least concerning to industry itself!)

Another way the fracking industry is hoping to make a profit is by investing in the region’s natural gas liquids (NGLs), such as ethane, propane, and butane, to support the petrochemical industry.

The Appalachian Storage Hub

Continued oil and gas development are part of a nascent effort to establish a mega-infrastructure petrochemical complex,  the Appalachian Storage Hub (ASH). For those that aren’t familiar with the ASH it could be framed as the fracking industry’s last best attempt to lock in their necessity across Appalachia and nationwide. The ASH was defined in the West Virginia Executive as a way to revitalize the Mountain State and would consist of the following:

“a proposed underground storage facility that would be used to store and transport natural gas liquids (NGLs) extracted from the Marcellus, Utica and Rogersville shales across Kentucky, Ohio, Pennsylvania and West Virginia. Construction of this hub would not only lead to revenue and job creation in the natural gas industry but would also further enable manufacturing companies to come to the Mountain State, as the petrochemicals produced by shale are necessary materials in most manufacturing supply chains…[with] the raw materials available in the region’s Marcellus Shale alone…estimated to be worth more than $2 trillion, and an estimated 20 percent of this shale is composed largely of ethane, propane and butane NGLs that can be utilized by the petrochemical industry in the manufacturing of consumer goods.”

This is yet another example of fracking rhetoric that appeals to American’s sense of patriotism and need for cheaper consumer goods (in this case, plastics), given that they are seeing little to no growth in wages.

While a specific location for underground storage has not been announced, the infrastructure associated with the ASH (such as pipelines, compressor stations, and processing stations) would stretch from outside Pittsburgh down to Catlettsburg, Kentucky, with the latter currently the home of a sizeable Marathon Oil refinery. The ASH “would act like an interstate highway, with on-ramps and off-ramps feeding manufacturing hubs along its length and drawing from the available ethane storage fields. The piping would sit above-ground and follow the Ohio and Kanawha river valley.”

The politics of the ASH – from Columbus and Charleston to Washington DC

Elected officials across the quad-state region are supporting this effort invoking, not surprisingly, its importance for national security and energy independence.

State-level support

West Virginia Senator Joe Manchin (D) went so far as to introduce “Senate Bill 1064 – Appalachian Energy for National Security Act.”  This bill would require Secretary of Energy Rick Perry and his staff to “to conduct a study on the national security implications of building ethane and other natural-gas-liquids-related petrochemical infrastructure in the United States, and for other purposes.”

Interestingly, the West Virginia Senator told the West Virginia Roundtable Inc’s membership meeting that the study would not examine the “national security implications” but rather the “additional security benefits” of an Appalachian Storage Hub and cited the following to pave the way for the national security study he is proposing: “the shale resource endowment of the Appalachian Basin is so bountiful that, if the Appalachian Basin were an independent country, the Appalachian Basin would be the third largest producer of natural gas in the world.”

Senator Manchin is not the only politician of either party to unabashedly holler from the Appalachian Mountaintops the benefits of the ASH. Former Ohio Governor, and 2016 POTUS primary participant, John Kasich (R) has been a fervent supporter of such a regional planning scheme. He is particularly outspoken in favor of the joint proposal by Thailand-based PTT Global Chemical and Daelim to build an ethane cracker in Dilles Bottom, Ohio, across the Ohio River from Moundsville, West Virginia. The ethane cracker would convert the region’s fracked ethane into ethylene to make polyethylene plastic. This proposed project could be connected to the underground storage component of the ASH.

The Democratic Pennsylvania Governor Tom Wolf has consistently advocated for the project, going so far as to sign “an unprecedented agreement at the Tri-State Shale Summit, promising collaboration between the states in securing crackers for the region and, by extension, support of the storage hub.”

Dilles Bottom, OH ethane cracker site. Photo by Ted Auch, aerial assistance provided by LightHawk.

Not to be outdone in the ASH cheerleading department, West Virginia Governor Jim Justice (R), who can’t seem to find any common ground with Democrats in general nor Senator Manchin specifically, is collaborating with quad-state governors on the benefits of the ASH. All the while, these players ignore or dismiss the environmental, social, and economic costs of such an “all in” bet on petrochemicals and plastics.

Even the region’s land-grant universities have gotten in on the act, with West Virginia University’s Appalachian Oil and Natural Gas Research Consortium and Energy Institute leading the way. WVU’s Energy Institute Director Brian Anderson pointed out that, “Appalachia is poised for a renaissance of the petrochemical industry due to the availability of natural gas liquids. A critical path for this rebirth is through the development of infrastructure to support the industry. The Appalachian Storage Hub study is a first step for realizing that necessary infrastructure.”

National-level support

The Trump administration, with the assistance of Senator Manchin’s “Senate Bill 1337 – Capitalizing on American Storage Potential Act”, has managed to stretch the definition of the Department of Energy’s Title XVII loan guarantee to earmark $1.9 billion for the Appalachian Development Group, LLC (ADG) to develop the ASH, even though any project that receives such a loan must:

  1. utilize a new or significantly improved technology;
  2. avoid, reduce or sequester greenhouse gases;
  3. be located in the United States; and,
  4. have a reasonable prospect of repayment.

This type of Public-Private Investment Program  is central planning at its finest, in spite of the likelihood that the prospects of the ASH meeting the second and fourth conditions above are dubious at best (even if the project utilizes carbon capture and storage technologies).

Public-Private Investment Programs have a dubious past. In her book “Water Wars,” Vandana Shiva discusses the role of these programs globally and the involvement of institutions like the World Bank and International Monetary Fund:

“public-private partnerships”…implies public participation, democracy, and accountability.  But it disguises the fact that the public-private partnership arrangements usually entail public funds being available for the privatization of public goods…[and] have mushroomed under the guise of attracting private capital and curbing public-sector employment.”

In response to the Department of Energy’s Title XVII largesse, Congresswoman Pramila Jayapal and Ilhan Omar introduced Amendment 105 in Rule II on HR 2740. According to Food and Water Watch, this amendment would restrict “the types of projects the Department of Energy could financially back. It would block the funding for ALL projects that wouldn’t mitigate climate change.”

On Wednesday, June 19th Congress voted 233-200 along party lines to pass the amendment, preventing funds from the Energy Policy Act of 2005  to be provided to any “project that does not avoid, reduce, or sequester air pollutants or anthropogenic emissions of greenhouse gases”.

International interest

The only condition of Department of Energy’s Title XVII loan program ASH is guaranteed to meet is the third (be located in the United States), but as we’ve already mentioned, the level of foreign money involved complicates the domestic facade.

Foreign involvement in the ASH lends credence to Senator Manchin’s and others’ concerns about where profits from the ASH will go, and who will be reaping the benefits of cheap natural gas. The fact that the ASH is being heavily backed by foreign money is the reason Senator Manchin raised an issue with the outsized role of state actors like Saudi Arabia and China as well as likely state-backed private investments like PTT Global Chemical’s. The Senator even cited how a potential $83.7 billion investment in West Virginia from China’s state-owned energy company, China Energy, would compromise “domestic manufacturing and national security opportunities.”

“Critical” infrastructure

With all of the discussion and legislation focused on energy and national security, many don’t realize the output of the ASH would be the production of petroleum-based products: mainly plastic, but also fertilizers, paints, resins, and other chemical products.

Not coincidentally, Republican Ohio State Representatives George Lang and Don Jones just introduced House Bill 242, and attempt to support the plastic industry by “prohibit[ing] the imposition of a tax or fee on [auxiliary or plastic] containers, and to apply existing anti-littering law to those containers.”

There will most certainly be a battle in the courts between the state and urban counties like Cuyahoga County, Ohio, who’s council just voted to ban plastic bags countywide on May 28.

Bills like this and the not unrelated “critical infrastructure” bills being shopped around by the American Legislative Exchange Council will amplify the rural vs urban and local vs state oversight divisions running rampant throughout the United States.  The reason for this is that yet another natural resource boom/bust will be foisted on Central Appalachia to fuel urban growth and, in this instance, the growth and prosperity of foreign states like China.

Instead of working night and day to advocate for Appalachia and Americans more broadly, we have legislation in statehouses around the country that would make it harder to demonstrate or voice concerns about proposals associated with the ASH and similar regional planning projects stretching down into the Gulf of Mexico.

Producing wells mapped

Impacts from the ASH and associated ethane cracker proposals will include but are not limited to: an increase in the permitting of natural gas wells, an increase in associated gas gathering pipelines across the Allegheny Plateau, and an exponential increase in the production of plastics, all of which are harmful to the region’s environment and the planet.

The production of the region’s fracked wells will determine the long-term viability of the ASH. From our reading of things, the permitting trend we see in Ohio will have to hit another exponential inflection point to “feed the beast” as it were. Figure 1 shows an overall decline in the number of wells drilled monthly in Ohio.

Figure 2, below it, shows the relationship between the number of wells that are permitted verse those that are actually drilled.

Figures 1. Monthly (in blue) and cumulative (in orange) unconventional oil and gas wells drilled in Ohio, January, 2013 to November, 2018

 

 Figure 2. Permitted Vs Drilled Wells in Ohio, January, 2013 to November, 2018

That supply-demand on steroids interaction will likely result in an increased reliance on “super laterals” by the high-volume hydraulic fracturing industry. These laterals require 5-8 times more water, chemicals, and proppant than unconventional laterals did between 2010 and 2012.

Given this, we felt it critical to map not just the environmental impacts of this model of fracking but also the nuts and bolts of production over time. The map below shows the supply-demand links between the fracking industry and the ASH, not as discrete pieces or groupings of infrastructure, but rather a continuum of up and downstream patterns.

The current iteration of the map shows production values for oil, natural gas, and natural gas liquids, how production for any given well changes over time, and production declines in newer wells relative to those that were fracked at the outset of the region’s “Shale Revolution.” Working with volunteer Gary Allison, we have compiled and mapped monthly (Pennsylvania and West Virginia) and quarterly (Ohio)[2] natural gas, condensate, and natural gas liquids from 2002 to 2018.

This map includes 15,682 producing wells in Pennsylvania, 3,689 in West Virginia, and 2,064 in Ohio. We’ve also included and will be updating petrochemical projects associated with the ASH, either existing or proposed, across the quad-states including the proposed ethane cracker in Dilles Bottom, Ohio and the ethane cracker under construction in Beaver County, Pennsylvania, along with two rumored projects in West Virginia.


View Map Full Screen

Conclusion

We will continue to update this map on a quarterly basis, will be adding Kentucky data in the coming months, and will be sure to update rumored/proposed petrochemical infrastructure as they cross our radar. However, we can’t be everywhere at once so if anyone reading this hears of legitimate rumors or conversations taking place at the county or township level that cite tapping into the ASH’s infrastructural network, please be sure to contact us directly at info@fractracker.org.

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

Feature Photo: Ethane cracker plant under construction in Beaver County, PA. Photo by Ted Auch, aerial assistance provided by LightHawk.

[1] For a detailed analysis of the HVHF’s increasing resource demand and how lateral length has increased in the last decade the reader is referred to our analysis titled “A Disturbing Tale of Diminishing Returns in Ohio” Figures 12 and 13.

[2] Note: For those Bluegrass State residents or interested parties, Kentucky data is on its way!