By Ted Auch, PhD – Great Lakes Program Coordinator
Hydraulic Fracturing “Fracking” at a well-pad outside Barnesville, Ohio operated by Halliburton
The industrial practice of disposing of oil and gas drilling waste into Class II injection wells causes a lot of strife for people on both sides of the fracking debate. This process has exposed many “hidden [geologic] faults” across the US as a result of induced seismicity. It has been linked in recent months and years with increases in earthquake activity in states like Arkansas, Kansas, Texas, and Ohio.
Locally, there is growing evidence in counties – from Ashtabula to Washington – that Ohio Class II injection well volumes and quarterly rates of change are related to upticks in seismic activity (Figs. 1-3). But exactly how much waste are these sites receiving, and where is it coming from? Since it has been a little over a year since last we looked at the injection well landscape here in Ohio, we decided to revisit the issue here.
Figures 1-3. Ohio Class II Injection Well disposal during Q3-2010, Q2-2012, and Q2-2015
The Class II Landscape in Ohio
In Ohio 245+ Class II Salt Water Disposal (SWD) Disposal Wells are permitted to accept unconventional oil and gas waste. Their disposal capacity and number of wells served is by far the most of any state across the Marcellus and Utica Shale plays.
Ohio’s Class II Injection wells have accepted an average of 22,750 barrels per quarter per well (BPQPW) (662,632 gallons) of oil and gas wastewater over the last year. In comparison, our last analysis uncovered a higher quarterly average (29,571 BPQPW) between the initiation of frack waste injection in 2010 and Q2-2015 (Fig. 4). This shift is likely due to the significant decrease in overall drilling activity from 2012 to 2015. Between Q3-2010 and Q1-2016, however, OH’s Class II injection wells saw an exponential increase in injection activity. In total, 109.4 million barrels (3.8-4.6 billion gallons) of waste was disposed in Ohio. From a financial perspective this waste has generated $3.4 million in revenue for the state or 00.014% of the average state budget (Note: 2.5% of ODNR’s annual budget).
The more important point is that even in slow times (i.e., Q2-2015 to the present) the trend continues to migrate from the bottom-left to the top-right, with each of Ohio’s Class II injection wells seeing quarterly demand increases of 972 BPQPW (34,017-40,821 gallons). This means that the total volume coming into our Class II Wells is increasing at a rate of 8.2-9.8 MGs per year, or the equivalent to the water demand of several high volume hydraulically fractured wells.
With respect to the source of this waste, the story isn’t as clear as we had once thought. Slightly more than half the waste came from out-of-state during the first two years for which we have data, but this statistic plummeted to as low as 32% in the last year-to-date (Fig. 5). This change is likely do to the high levels of brine being produced in Ohio as the industry migrates towards the perimeter of the Utica Shale.
Figures 4 and 5
Freshwater Demand and Brine Production
Map of Ohio Utica Brine Production and Class II Injection Well Disposal
Figure 6. Ohio Class II Injection Well disposal as a function of freshwater demand by the shale industry in Ohio between Q3-2010 and Q1-2015
To gain a more comprehensive understanding of what’s going on with Class II wastewater disposal in Ohio, it’s important to look into the relationship between brine and freshwater demand by the hydraulic fracturing industry. The average freshwater demand during the fracking process, accounts for 87% of the trend in brine disposal in Ohio (Fig. 6).
As we mentioned, demand for freshwater is growing to the tune of 405-410,000 gallons PQPW in Ohio, which means brine production is growing by roughly 12,000 gallons PQPW. This says nothing for the 450,000 gallons of freshwater PQPW increase in West Virginia and their likely demand for injection sites that can accommodate their 13,500 gallons PQPW increase.
Conclusion
Essentially, the seismic center of Ohio has migrated eastward in recent years; originally it was focused on Western counties like Shelby, Logan, Auglaize, Darke, and Miami on the Indiana border, but it has recently moved to injection well hotbed counties like Ashtabula, Trumbull, and Washington along the Pennsylvania and West Virginia borders. This growth in “induced seismicity” resulting from the uptick in frack waste disposal puts Ohio in the company of Oklahoma, Arkansas, Colorado, Kansas, New Mexico, and Texas. Each of those states have reported ≥4.0 magnitude “man-made” quakes since 2008. Between 1973 and 2008 an average of 21 earthquakes of ≥M3 were reported in the Central/Eastern US. This number jumped to 99 between 2009 and 2013, with 659 of M3+ in 2014 alone according to the USGS and Virginia Tech Seismological Observatory (VTSO). This “hockey stick moment” is exemplified in the below figure from a recent USGS publication (Fig. 7). Figure 8 illustrates the spatial relationship between recent seismic activity and Class II Injection well volumes here in Ohio. The USGS even went so far as to declare the following:
An unprecedented increase in earthquakes in the U.S. mid-continent began in 2009. Many of these earthquakes have been documented as induced by wastewater injection…We find that the entire increase in earthquake rate is associated with fluid injection wells. High-rate injection wells (>300,000 barrels per month) are much more likely to be associated with earthquakes than lower-rate wells.
– From USGS Report High-rate injection is associated with the increase in U.S. mid-continent seismicity
Figures 7 and 8
The sentiment here in Ohio regarding Class II Injection wells is best summed up by Dr. Ray Beiersdorfer, Distinguished Professor of Geology, Youngstown State University and his wife geologist Susie Beiersdorfer who jointly submitted the following quote regarding the North Star (SWIW #10) Class II Injection Well in Mahoning County, which processed 555,030 barrels (21,368,655 gallons) of fracking waste between Q4-2010 and Q4-2011[1].
The operator, D&L, and the ODNR denied the correlation in space and time between the injection of toxic fracking fluids into the well and earthquakes for over eight months in 2011. The well was shut down on December 30 and the largest seismic event, a 4.0 happened at 3:04 p.m. on December 31, 2011. Though the rules say that a “shut-in” well must be plugged after 60 days, this well is still “open” after 1656 days (July 12, 2016). This well must be plugged [and abandoned] to prevent further risks to the health and safety of the Youngstown community… According to Rick Simmers, the only thing holding this up is bankruptcy procedures. It was drilled into a fault, triggered over five hundred earthquakes, including a Magnitude 4.0 that caused damage to homes. [It is likely] that any other use of this well would trigger additional hazardous earthquakes.
Images From Across Ohio
Click on the images below to explore visual documentation and volumes disposed (as of Q1-2016) into Class II Injection wells in Ohio.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/07/ClassIIOhio-Feature.jpg400900Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngTed Auch, PhD2016-07-15 14:03:162020-03-12 17:19:05OH Class II Injection Wells – Waste Disposal Trends and Images From Around Ohio
Sierra Shamer, Visiting Scholar, FracTracker Alliance
While neighboring states New York and Maryland work to regulate the natural gas industry, Pennsylvania makes way for a pipeline build-out and continued unconventional oil and gas drilling. The industry, legislature, and state agencies claim that continued natural gas development is necessary, can be carried out safely, and will provide money, jobs, and energy to Pennsylvania. However, the price is increasingly evident, and the realization of these claims is yet to come.
PA residents are quickly learning that pipelines come with a cost; their permitting, construction, and supporting facilities infringe on private property rights, cause water and air pollution, and threaten public safety. On Friday April 29th in Westmoreland County, for example, Spectra Energy’s Texas Eastern 30″ gas pipeline exploded, severely burning one man, destroying his home, and damaging homes nearby. The local fire chief recounted his awe at the explosion. For him, it was “… like you were looking down into hell.” These costs prompt communities to consider whether the advertised benefits of pipelines will actually outweigh the costs. Active grassroots resistance has emerged throughout the state, and as it grows, it is consistently met with industry aggression and state repression.
This article provides an overview of the pipeline build-out in Pennsylvania, the political and economic environment promoting it, growing community activism, and, how the industry and state respond. An interactive map of existing and proposed pipelines in PA is featured at the end of the article.
The Shale in Pennsylvania
Extent of the Utica (brown) and Marcellus (orange) shale formations. Click to expand.
The existing interstate pipeline network moves domestic and imported oil and gas to consumers and markets within North America. These pipelines extend from regions of conventional drilling to domestic and foreign energy markets. The recent development and expansion of unconventional drilling provides access to energy reservoirs that could not be extracted before. Within the past five years, the US overtook Russia to become the largest producer of natural gas in the world.
The Marcellus and Utica shale formations exist below the Appalachian Mountains in the northeast U.S. and into Canada. The Marcellus lies beneath Pennsylvania, Virginia, Maryland, West Virginia, Ohio, and New York. The Marcellus is now the largest region of natural gas production in the United States. Geologists estimate that 4-8,000 ft. underground, over 600 trillion cubic ft. of natural gas is accessible. The Utica formation lies underneath the Marcellus, extending north into Ontario and New York, and south into Virginia, Kentucky, and Tennessee. Geologists estimate over 38 trillion cubic ft. of natural gas is accessible – in some locations over 10,000 feet underground.
Extraction in Pennsylvania
Almost 10,000 unconventional wells in Pennsylvania produce millions of cubic feet of gas each day. This rapid extraction flooded the market, causing natural gas prices to drop dramatically. Marcellus production also outpaced the capacity of the current pipeline network. The location and flow direction of existing pipelines is not ideal for transporting Marcellus gas to markets with higher demand. Additionally, well productivity drops 70% within the first year, so new wells must be drilled to keep the gas flowing. However, the low price of gas reduced revenues, and the cost of drilling new wells remains high. Combined, these factors have paused drilling activity throughout the state. In order to overcome this, gas companies are proposing construction of new pipelines and expansions of existing ones, resulting in the current pipeline build-out.
The Economics of Pipelines
The dominant narrative, promoted by industry and state, weaves a story of economic prosperity gained by drilling the Marcellus, eclipsing concerns of pipeline necessity and safety. Each pipeline project claims an economic impact in dollar amounts and jobs. Williams claims that their proposed Atlantic Sunrise pipeline will “increase economic activity by $1.6 billion in project regions” and create job opportunities. Sunoco Logistics claims that the Mariner East pipeline will “add $4.2 billion to Pennsylvania’s economy, supporting more than 30,000 jobs during the construction period and … 300-400 permanent jobs.” Often, the specifics of money and jobs are not explained, and when construction begins, communities are invaded by out of state workers and left with little economic benefit.
Response to this buildout arises at all levels. Support pours down from federal and state government while resistance pushes up from the grassroots. The EPA and Obama administration work to shut down coal and promote natural gas, claiming it’s a “bridge fuel” to renewable energy. Pennsylvania’s legislature and Dept. of Environmental Protection (DEP) have battled over drilling regulations, and the push for pipelines presents a different set of challenges. While some consider the build-out necessary to maintain the natural gas industry in PA, others, such as Phil Rinaldi, envision ways in which pipelines can bring money to the state.
Philadelphia Energy Hub
Aware that interstate pipelines carry Pennsylvania shale to out-of-state markets, Phil Rinaldi, the CEO of Philadelphia Energy Solutions (PES) views the shale boom as an opportunity to maintain resource and revenue in state. In 2013 he established the Greater Philadelphia Energy Action Team (GPEAT), a group of over 80 industry, manufacturing, labor, and government stakeholders. Their objective is to capitalize on shale by promoting pipeline construction and bringing energy-intensive manufacturing to the Greater Philadelphia area. In March of this year, the GPEAT released a report titled, “A Pipeline for Growth: Fueling Economic Revitalization with Marcellus and Utica Shale Gas.” This reports details strategies to hasten the transformation of Philly into the “energy hub” of the East by inviting chemical manufacturing industries, and supporting pipeline projects to Philadelphia.
At Ground Level
2016: Columbia 26″ pipeline construction near a home in Northern Maryland (Photo: Sierra Shamer)
At a ground level, impacted communities, public health professionals, and environmental organizations face a ravenous industry. Unaccountable for property takings, fair compensation, and pollution, it as an industry that disregards public health and ecosystems within the shalefields. As a result, grassroots and advocacy groups organize and mobilize throughout Pennsylvania to amplify the voices of impacted residents and communities and to hold the industry and government accountable to the people.
Although pipelines bring large revenues for companies, industry, and the state, the story on the ground is different. New pipelines are either constructed on existing land easements, or new ones must be purchased from landowners along the proposed right-of-way. Pipeline operators have one goal: to find the most direct and least complicated route from supply to demand. While this lower their bottom line, new pipeline routes often disregard nearness to homes, schools, and other populated areas, and cause significant damage to farmland and ecosystems.
Frontline Communities
Pipeline companies often have the power of eminent domain, the ability to take possession of land in court if the property owner refuses a contract. Negotiating fair agreements requires landowners to hire their own appraiser and lawyer, which is not an option for everyone. Unlike drilling wells, landowners do not receive royalties for the pressurized gas flowing underneath their property, facing instead declines in property values and an inability to sell their home. As a result, landowners are left undercompensated, their land forcibly taken away in an unjust process.
Landowners along the right-of-way are the most immediately impacted, but neighbors and communities are affected as well. Each pipeline has a “potential impact radius” or “hazard zone,” the area within which an explosion causes immediate destruction. Residents within this distance experience a decrease in their property values, but currently have no legal recourse for compensation. Pipelines also require numerous compressor stations, facilities that operate 24-7 to maintain the pressure of the gas within the pipeline. Compressor stations are industrial, air polluting facilities that release greenhouse gases, neurotoxins, cancer causing agents, and other pollutants that negatively impact human health and the environment. Residents living near compressor stations experience various respiratory, sinus, and nervous system health issues. These are caused by both everyday operation and periodical gas blowdowns – facility operations when large amounts of methane and other chemicals are released directly into the air for station maintenance or emergencies.
Pipeline Regulation
FERC holds Public Meetings for the Atlantic Sunrise Pipeline (Photo: Justin Engle/The Daily Item)
In Pennsylvania, no single agency is responsible for permitting, monitoring, or regulating pipelines. The Federal Energy Regulatory Commission (FERC) permits interstate pipelines, those that cross state boundaries or carry product that does. Pipelines within the state are under the jurisdiction of the Public Utility Commission (PUC), the DEP, and/or the Dept. of Conservation and Natural Resources (DCNR).
Typically, the PUC is responsible for pipelines that provide directly to consumers. However, in 2011 Act 127 gave the PUC authority to permit and inspect gathering lines, those that move gas from well pads to larger transmission pipelines. All gathering lines have national safety standards except Class 1, those with no more than ten buildings within 220 yards. The PUC maintains a registry of the location, size, and length of gathering lines, but is only includes length for Class 1. Over 12,000 miles of Class 1 pipelines currently exist in PA, a number expected to quadruple by 2030.
Pipeline Infrastructure Task Force
The complex regulation and unprecedented increase in proposals prompted Governor Wolf to create the Pipeline Infrastructure Task Force (PITF) in 2015. Headed by former Secretary of the DEP, John Quigley, the Task Force included regulatory agencies, industry representatives, and government officials. Their mission: to “engage stakeholders in a collaborative process to achieve a world-class pipeline infrastructure system” and to develop “policies, guidelines, and tools to assist in pipeline development.” The DEP offered live stream of meetings, provided public information, and opportunity for public input in an attempt to be transparent.
Task Force meetings eventually resulted in a final report, outlining challenges and providing suggestions for pipeline construction. First, the Task Force recommended an increase meaningful public participation and the development of long term maintenance plans to ensure safety. Second, they suggested reducing environmental impact by improving pipeline siting and construction and maximizing efficient permitting. Finally, they recommended enhancing the workforce and economic development from pipeline projects.
The Task Force openly acknowledged problems of the pipeline build-out, stating that “permits are not reviewed for the cumulative and long term impacts at a landscape level…they do not necessarily avoid sensitive lands, habitats, and natural features, nor are the impacts to natural and cultural resources, landowners, and communities…always minimized or mitigated.” Despite this, the administration and the Task Force maintain that pipelines can be built responsibly.
Community Opposition and Criticism
2016: Landowners and supporters protest the Constitution Pipeline in Northeast PA. (Photo: DC Media Group)
Challenges to the pipeline build-out exist in many forms. Landowners challenge the bullying, harassment, and eminent domain condemnations of pipeline companies. Communities criticize the acceptance of industry funding and pipelines by local representatives. Additionally, grassroots groups and environmental non-profits challenge the minimal regulation, permitting process, and lack of public participation allowed by the DEP, and the FERC “rubber stamp” permitting process.
Awareness and opposition grow with each proposal, condemnation, rupture, and explosion. This rapid construction is compromising pipeline quality and public safety, according to a report conducted by the Pipeline Safety Trust. They found that pipelines built after 2010 had higher rates of failure than those in decades past. Whistleblowers who worked for Spectra Energy have attested to the neglect of proper inspection in the haste to construct pipelines. Spectra’s Texas Eastern pipeline, completed in 1981, was built in a decade when pipelines failed at one-sixth the rate they do today. However, their preliminary investigation indicates that the explosion in Salem Township was likely the result of corrosion due to a “possible flaw in the coating material applied to the weld joints.”
The FERC is a regular target of criticism. Funded through fees received by the companies and industries it oversees, FERC rarely denies permits for pipelines. The Delaware Riverkeeper Network has filed a lawsuit against the FERC challenging the constitutionality of its decision-making.
The DEP’s dedication to protecting Pennsylvania’s environment from the natural gas industry at large is continuously questioned due to its infrastructure permitting, negligent response to water contamination complaints, and unwillingness to hold companies accountable. The DEP’s poor record on drilling regulation continues with regard to the pipeline build-out.
Pipeline Infrastructure Task Force
The Task Force is criticized for its overwhelming industry influence and lack of public inclusion. Of the 48 Infrastructure Task Force members, 56% are tied to the oil and gas industry. Specifically, 92% of the non-governmental members have industry ties. In fact, potential opposition to the build-out was intentionally absent. PA resident and documentary filmmaker Scott Cannon of the Gas Drilling Awareness Coalition (GDAC) was invited to the PITF, only to receive a letter rescinding his invitation a few days later. Additionally, concerned residents were allowed 2 minutes to make a statement, a limit strictly enforced by Secretary Quigley. While affected landowners recounted their fight for their livelihoods, the roundtable of apathetic Task Force members stared blankly. These problems resulted in escalating activist presence increasing from comments and protests outside the DEP building, to meeting disruptions and arrests.
Residents and activists weren’t the only ones unhappy with the PIFT. Cindy Ivey, representative for Williams, and Sarah Battisti, with SouthWest Energy, spoke of their frustrations. The fact that interstate pipeline projects are regulated by federal agencies, and state level organizations have a minor role caused tension in the group. According to Ivey, these issues are “hard things to try to explain gracefully.” Additionally, Battisti added that the 184 recommendations in the report wouldn’t “impact any of us in the near future.”
Despite recommendations of the Task Force, the DEP continues to issue permits that neglect cumulative impacts and complete environmental review. Unlike New York, which denied the 401 Water Quality certificate and prevented the construction of Constitution pipeline, the PA DEP granted the 401 certificate to the Atlantic Sunrise pipeline. As a result, it is under appeal by environmental groups, who argue that it violates the Clean Water Act and the Pennsylvania Code.
PA’s Political Climate
Regulations
Unfortunately, meaningful updates to oil and gas regulations in Pennsylvania are consistently challenged. Although Act 13 passed in 2012, critical components were appealed repeatedly, specifically the issue of local zoning authority of oil and gas infrastructure. Lawmakers who oppose any restriction on the industry dominate the current legislature. Recently, the House panel voted a second time to block increased DEP oil and gas regulations, in the making since 2011.
Frustrations in the process peaked when John Quigley resigned as secretary of the DEP after sending a profane email chastising environmental groups for their lack of support. Weeks later, Governor Wolf signed a bill that eliminates current regulations, aiming to start new and in agreement with the legislature. As a result, many environmentalists feel that the Governor has consistently compromised on the environment, putting the lives of PA residents at risk.
Political Campaigns
The relationship between the state and the drilling industry is evident and problematic in Pennsylvania. The Marcellus Money project has tracked campaign contributions and lobbying expenses from the natural gas industry, revealing over $8 million in political contributions and $46 million for lobbying efforts. In 2013 the Public Accountability Initiative released a report revealing the “revolving door” between state government and the oil and gas industry. The report identifies individuals who have moved from the public sector to industry jobs or vice versa, and how often this occurs over the course of their careers.
NPR StateImpact Pennsylvania created an interactive webpage called, “Blurred Lines” that provides a visual exploration of the “revolving door.” As you scroll through the years, individuals slide back and forth between the private and public sector. Additionally, lawmakers have, for a third time, earmarked fiscal code legislation to fund an industry-supported non-profit Shale Alliance for Energy Research PA, (SAFER PA).
State Agencies
Financial gains from drilling support other aspect of the public sector as well. The DCNR’s annual budget became increasingly reliant upon revenues from gas leases within public lands. In 2013, oil and gas lease royalties and other payments provided one-third of the DCNR’s budget. Act 13 implemented a mandatory impact fee whereby the PUC collects money from companies based on the number of oil and gas wells in the state. This money is directed to local municipalities based on the number of wells within their boundaries. However, while 60% of the fee total goes directly to impacted counties, the remaining 40% can go anywhere in PA. While impact fees totaled over $233 billion dollars in 2014, 2016 is expected to be the lowest amount yet due to the decline in drilling activity. This statistic is one of many that highlights the risk of relying on a fluctuating resource.
Governmental and Industry Responses
2016: Armed U.S. Marshall escort the tree cutting crew for the Constitution pipeline on Megan Holleran’s property (Photo: Alex Lotorto)
Response to community opposition of pipeline projects is often militaristic in nature and exaggerated by the industry and the state. The oil and gas industry views community opposition to infrastructure as an “insurgency.” In 2011, it was revealed that the Army/Marine Corps Counterinsurgency manual is used as a tactical reference. The Gas Drilling Awareness Coalition was classified as a terrorist threat by the PA Office of Homeland security, who hired the Institute of Terrorism Research and Response to track activists provide weekly information on a bulletin sent to law enforcement and gas companies. In 2012, state law enforcement, the FBI, the PA Office of Homeland Security, and the oil and gas industry established the Marcellus Shale Operators’ Crime Committee (MSOCC). This committee actively targeted activists and environmentalists in their homes.
Landowners who refuse to sign easements face an uphill battle against companies, law enforcement, and the state as they advocate for their rights. Megan Holleran of Susquehanna County lost her family’s maple syrup trees to Williams’ proposed Constitution pipeline. After protesting and challenging in court, the judge upheld eminent domain and prohibited the family from being within 150 feet from the right-of-way. Further, armed U.S. Marshalls escorted and guarded the tree cutting crew against peaceful protest. Additionally, in Huntingdon County, Elise and Ellen Gerhart faced tree clearing of their woods for Sunoco’s Mariner East pipeline. Once again, armed police escorted tree cutting crews and made several arrests of protesters, who faced bails of up to $200,000.
Pipeline Build-Out Map
The map below shows the existing major pipeline infrastructure in Pennsylvania and proposed pipelines, with the option of also viewing the unconventional wells in the Marcellus and Utica shale. For more information on pipeline regulation and public information, please view our Intro to Pipelines resource page. It includes details about current and proposed pipeline projects in Pennsylvania and throughout the country. Additionally, the intro links to a map of all proposed pipeline projects in North America.
While it is clear that companies go to every length to construct pipelines, it is equally clear that state agencies, courts, and law enforcement support pipeline development. The direction of drilling, pipelines, and politics in the state of Pennsylvania serves the bottom line of the natural gas industry. This is evidenced by the proposed pipeline built-out, state support, and state suppression of public backlash. However, continued challenges to public health and environment will only serve to increase the resilience and strength of community opposition.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/06/Pipeline-Build-Out-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2016-06-28 09:29:382020-03-12 17:19:41Infrastructural Challenges: The Direction of Drilling, Pipelines, and Politics in Pennsylvania
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.
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.
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.
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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/06/PAUpdate-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2016-06-22 10:05:472020-03-12 17:20:08Approaching 10K Unconventional Wells in PA
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’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.
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 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 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
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.]
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.
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
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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/06/BellaRomeroSchool-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2016-06-21 13:09:522020-03-11 17:05:19Drilling Bella Romero: Children at Risk in Greeley, Colorado
North America consists of a vast network of inter- and intrastate pipelines that serve a vital role in transporting water, hazardous liquids, and raw materials. There is an estimated 2.6 million miles of pipelines in the nation, and it delivers trillions of cubic feet of natural gas and hundreds of billions of tons of liquid petroleum products each year. Because the pipeline network fuels the nation’s daily functions and livelihoods by delivering resources used for energy purposes, it is crucial to shed light on this transportation system. This article briefly discusses oil and gas pipelines, what they are, why they exist, their potential health and environmental impacts, proposed projects, and who oversees them.
What are pipelines, and what are they used for?
Pipelines in North Dakota. Photo credit: Kathryn Hilton
The pipeline network in the U.S. is a transportation system used to move goods and materials. Pipelines transport a variety of products such as sewage and water. However, the most common products transported are for energy purposes, which include natural gas, biofuels, and liquid petroleum. Pipelines exist throughout the country, and they vary by the goods transported, the size of the pipes, and the material used to make pipes.
While some pipelines are built above ground, the majority of pipelines in the U.S. are buried underground. Because oil and gas pipelines are well concealed from the public, most individuals are unaware of the existence of the vast network of pipelines.
Extent of U.S. Pipeline System
The United States has the most miles of pipelines than any other country, with 1,984,321 km (1,232,999 miles) in natural gas transport and 240,711 km (149,570 miles) in petroleum products. The country with the second most miles of pipelines is Russia with 163,872 km (101,825 miles), and then Canada with 100,000 km (62,137 miles).
Types of Oil and Gas Pipelines
There are two main categories of pipelines used to transport energy products: petroleum pipelines and natural gas pipelines.
Petroleum pipelines transport crude oil or natural gas liquids, and there are three main types of petroleum pipelines involved in this process: gathering systems, crude oil pipeline systems, and refined products pipelines systems. The gathering pipeline systems gather the crude oil or natural gas liquid from the production wells. It is then transported with the crude oil pipeline system to a refinery. Once the petroleum is refined into products such as gasoline or kerosene, it is transported via the refined products pipeline systems to storage or distribution stations.
Natural gas pipelines transport natural gas from stationary facilities such as gas wells or import/export facilities, and deliver to a variety of locations, such as homes or directly to other export facilities. This process also involves three different types of pipelines: gathering systems, transmission systems, and distribution systems. Similar to the petroleum gathering systems, the natural gas gathering pipeline system gathers the raw material from production wells. It is then transported with large lines of transmission pipelines that move natural gas from facilities to ports, refiners, and cities across the country. Lastly, the distribution systems consist of a network that distributes the product to homes and businesses. The two types of distribution systems are the main distribution line, which are larger lines that move products close to cities, and the service distribution lines, which are smaller lines that connect main lines into homes and businesses.
Right-of-Way (ROW)
Before pursuing plans to build new pipelines, a ROW needs to be secured from private and public landowners, which pipeline companies usually will pay for. ROW are easements that must be agreed and signed upon by both the landowner and pipeline company, and permits pipeline operators to go forth with installing and maintaining pipelines on that land. Pipeline operators can obtain ROW by purchasing the property or through a court-ordered procedure. ROW can be permanent or temporary acquisitions, and needs approval from FERC.
Regulatory Oversight
Depending on the type of pipeline, what it is transferring, what it is made of, and where it runs, there are various federal or state agencies that have jurisdiction over its regulatory affairs.
A. Federal Energy Regulatory Commission (FERC)
Interstate pipelines, those that either physically cross state boundaries or carry product that will cross state boundaries, are all permitted by the Federal Energy Regulatory Commission (FERC). The FERC is an independent organization within the U.S. Department of Energy that permits interstate electricity and natural gas infrastructure. The FERC’s authority lies within various acts of energy legislation, beginning with the Natural Gas Act of 1938 to the more recent Energy Policy Act of 2005. The U.S. President appoints its four commissioners. Other agencies such as the Dept. of Transportation, regional authorities such as the River Basin Commissions, and the Army Corps of Engineers may also be involved. FERC approves the location, construction, operation, and abandonment of interstate pipelines. They do not have jurisdiction over the siting of intrastate natural gas pipelines nor hazardous liquids.
B. Pipeline and Hazardous Materials Administration (PHMSA)
Under the U.S. Department of Transportation, the PHMSA oversees, develops, and enforces regulations to ensure the safe and environmentally sound pipeline transportation system. There are two offices within the PHMSA that fulfill these goals. The Office of Hazardous Materials Safety develops regulations and standards for classifying, handling, and packaging hazardous materials. The Office of Pipeline Safety develops regulations and risk management approaches to assure safe pipeline transportation, and ensures safety in the design, construction, operation and maintenance, and spill response of hazardous liquid and natural gas pipeline transportation. Below are some regulations enforced by PHMSA:
1. Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 or Pipeline Safety Act 2011
This act reauthorizes PHMSA to continue with the examination and improvement of the pipeline safety regulations. It allows PHMSA to:
Provide the regulatory certainty necessary for pipeline owners and operators to plan infrastructure investments and create jobs
Improve pipeline transportation by strengthening enforcement of current laws and improving existing laws where necessary
Ensure a balanced regulatory approach to improving safety that applies cost-benefit principles
Protect and preserve Congressional authority by ensuring certain key rule-makings are not finalized until Congress has an opportunity to act
2. Federal Pipeline Safety Regulations: Public Awareness Programs
Enforced by PHMSA, the Public Awareness Program mandates that pipeline companies and operators to develop and implement public awareness programs that follow guidance provided by the American Petroleum Institute.
Under this regulation, pipeline operators must provide the public with information on how to recognize, respond, and report to pipeline emergencies.
3. Natural Gas Pipeline Safety Act of 1968
This act authorizes the Department of Transportation to regulate pipeline transportation of flammable, toxic, or corrosive natural gas, or other gases, as well as transportation and storage of liquefied natural gas.
The PHMSA also designed an interactive national pipeline mapping system for the public to access and utilize. However, the map can only be viewed one county at a time, it does not include distribution or gathering lines, and when you zoom in too far, the pipelines disappear. In fact, the site warns that the map should not be used to determine accurate locations of pipelines, stating that the locations can be incorrect by up to 500 ft. PHMSA argues that these restrictions exist in the interest of national security.
C. United States Army Corps of Engineers
Permits must be obtained from the U.S. Army Corps of Engineers if a pipeline is to be constructed through navigable bodies of water, including wetlands. State environmental regulatory agencies, such as PA’s Department of Environmental Protection, are also involved in the approval process of pipeline construction through waterways and wetlands.
Environmental Health and Safety Risks
Although pipeline transportation of natural gas and petroleum is considered safer and cheaper than ground transportation, pipeline failures, failing infrastructure, human error, and natural disasters can result in major pipeline disasters. As such, previous incidents have been shown to cause detrimental effects to the environment and the public’s safety.
A. Land Use and Forest Fragmentation
Construction staging area and the right-of-way of Columbia’s 26″ Pipeline. Photo credit: Sierra Shamer
In order to bury pipelines underground, an extensive amount of forest and land is cleared out to meet the pipe’s size capacity. States, such as Pennsylvania, that consist of rich ecosystem due to their abundance of forests, are at critical risk of diminishing habitats for plant species, and are at risk of the eradication of certain animal species. The U.S. Geological Survey (USGS) aimed to quantify the amount of land disturbance in Bradford and Washington counties in PA as a result of oil and gas activity including pipeline implementation. The USGS report concluded that pipeline construction was one of the highest sources of increasing forest patch numbers. Bradford County, PA had an increase of 306 patches, in which 235 were attributable to pipeline construction. Washington County increased by 1,000 patches, in which half was attributable to pipeline construction.
B. Compressor Stations
Compressor stations play an important role in processing and transporting the materials that pass through the pipeline. However, compressor stations present significant environmental health hazards. Even when the process of drilling and fracking is completed, compressor stations remain in the area to keep the gas in pipelines continually flowing. The stationary nature of this air pollution source means that a combination of pollutants such as volatile organic compounds (VOCs), nitrogen oxides (NOx), formaldehyde, and greenhouse gases are continually being released into the atmosphere. These pollutants are known to produce deleterious health impacts to the respiratory system, nervous system, or lung damage. In addition to pollutants emitted, the noise level generated by compressor stations can reach up to 100 decibels. The Center of Disease Control and Prevention (CDC) reports hearing loss can occur by listening to sounds at or above 85 decibels over an extended period of time.
C. Erosion and Sedimentation
Heavy rainfall or storms can lead to excessive soil disruption, in turn increasing opportunities for erosion and sedimentation to occur. Erosion can uncover pipelines buried underground, and rainfall of more than 5 inches (13 cm) can move or erode berms, and also disrupt mounds of soil used to protect against flooding. Soil erosion increases underground pipelines’ vulnerability to damage from scouring or washouts, and damage from debris, vehicles, or boats.
D. Eminent Domain
Eminent domain allows state or federal government bodies to exercise their power to take private property from residents or citizens for public use and development. In some cases, private companies have exercised power to seize land for their own profit. Owners of the property are then given a compensation in exchange for their land. However, landowners may end up spending more than they receive. In order to receive compensation, owners must hire their own appraiser and lawyer, and they are also not usually compensated for the full value of the land. Furthermore, property values decrease once pipelines are established on their land, making it more difficult to sell their home in the future.
E. Spills and Leaks
Poorly maintained and faulty pipelines that transport liquefied natural gas or crude oil may pose high health and environmental risks should the fluids spill or leak into the soil. Crude oil can contain more than 1,000 chemicals that are known carcinogen to humans, such as benzene. The release of the potentially toxic chemical or oil can infiltrate into the soil, exposing communities to fumes in the atmosphere as well as contaminating groundwater and surface water. Not only are the incidents costly to control and clean up, the chemical or oil spills can also have long lasting impacts to the environment and the public. A ruptured pipeline that leaked 33,000 gallons of crude oil in Salt Lake City, Utah in 2010 exposed residents in a nearby community to chemical fumes, causing them to experience drowsiness and lethargy. After being commissioned in 2010, the TransCanada Keystone Pipeline had reported 35 leaks and spills in its first year alone. In April 2016, the Keystone pipeline leaked 17,000 gallons of oil in South Dakota. Older pipelines are more likely to leak than newer ones, so this issue will only increase as pipeline infrastructure ages.
Natural gas pipelines have also been shown to leak methane, a major component in natural gas, at levels that far exceed what is estimated. Not only does methane contribute to climate change, it puts surrounding communities at risk of gas explosions, and exposes them to dangerously high levels of methane in the air they breathe.
F. Explosions
Pipeline warning sign in Texas. Photo credit: Ecologic Institute US
Explosions are also common with faulty pipelines that leak natural gas. Unlike oil or liquid spills, which generally spread and infiltrate into the soil, gas leaks can explode due to the hydrocarbon’s volatility. A recent pipeline explosion in Westmoreland County, PA, for example, caused a man to incur severe burns, as well as caused dozens of homes to be evacuated. Another pipeline explosion in San Bruno, California resulted in 8 people dead, 6 missing, and 58 injured. Thirty-eight homes were also destroyed and 70 others were damaged. This explosion exposed the haphazard system of record keeping for the tens of thousands of miles of gas pipelines, shoddy construction, and inspection practices.
Upcoming Proposed Projects
An estimated 4,600 miles of new interstate pipelines will be completed by 2018. Below are just a few major projects that are currently being proposed or are in the process of obtaining a permit.
This pipeline will include 194 miles throughout the state of Pennsylvania. It will be constructed to cut through portions of 10 different PA counties, including Columbia, Lancaster, Lebanon, Luzerne, Northumberland, Schuylkill, Susquehanna, Wyoming, Clinton, and Lycoming. This project will require a 125-foot ROW, and will traverse through 52 areas designed as “protected land” in Pennsylvania. This proposed project is still in review by FERC – a decision is expected late 2016 or early 2017.
Spectra Energy (Houston), DTE Energy (Detroit), and Enbridge Inc. (Canada) are partnering to build a $2 billion gas line that would travel from eastern Ohio to Michigan to Ontario. Already applied with FERC and will start construction early 2017. It proposed a 255-mile pipeline and will be 36-inch wide line.
This pipeline will expand the existing pipeline’s capacity from 70,000 barrels a day to 345,000. It has plans to deliver propane, butane, ethane, and other natural gas liquids across state to Delaware, Berks, and Lebanon counties in PA. Currently, the construction is delayed due to push back and permits acquisition.
This project was intended to expand an existing pipeline by 420 miles from Susquehanna County, Pennsylvania and passing through New York, Massachusetts, New Hampshire, and Connecticut. Recently in April 2016, Kinder Morgan decided to suspend further development of this proposed pipeline.
The Atlantic Coast Pipeline had initial plans to establish 550 miles of pipeline from West Virginia to North Carolina, and to cut through dozens of Chesapeake headwater streams, two national forests, and across Appalachian Trail. Their permit to construct this pipeline was denied by the US Forest Service on January 2016; thus, delaying the project at the moment.
With approval by FERC, Spectra Energy has begun 37 miles of pipeline construction through New York, Connecticut, and Massachusetts. The pipeline location is particularly worrisome because it is critically close to the Indian Point nuclear power plant. Ruptures or leaks from the pipeline can threaten the public’s safety, and even result in a power plant meltdown. Spectra Energy has also submitted two additional proposals: the Atlantic Bridge and Access Northeast. Both projects will expand the Algonquin pipeline to reach New England, and both are still in the approval process with FERC.
The Constitution pipeline had initially planned to include 124 miles from Susquehanna County, Pennsylvania to Schoharie County, New York, and was denied by NY State in April 2016.
Preview of North America proposed pipelines map. Click to view fullscreen.
Further Questions
Please email us at info@fractracker.org if there are any unanswered questions you would like us to answer or include.
Update: this article was edited on June 21, 2016 due to reader feedback and suggestions.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/06/Pipeline-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2016-06-14 16:01:022020-03-12 13:32:32An Introduction to Oil and Gas Pipelines
CA Crude by Rail, from the Bakken Shale and Canada’s Tar Sands to California Refineries By Kyle Ferrar, Western Program Coordinator & Kirk Jalbert, Manager of Community Based Research & Engagement
Refineries in California plan to increase capacity and refine more Bakken Shale crude oil and Canadian tar sands bitumen. However, CA’s refinery communities that already bear a disparate amount of the burden (the refinery corridor along the north shore of the East Bay) will be more impacted than they were previously. New crude-by-rail terminals will put additional Californians at risk of accidents such as spills, derailments, and explosions. Additionally, air quality in refinery communities will be further degraded as refineries change to lower quality sources of crude oil. Below we discuss where the raw crude oil originates, why people are concerned about crude-by-rail projects, and what CA communities are doing to protect themselves. We also discuss our GIS analysis, showing the number of Californians living within the half-mile blast zones of the rail lines that currently are or will be supported by the new and existing crude by rail terminal projects.
Sources of Raw Crude Oil
Figure 1. Sources of crude oil feedstock refined in California over time (CA Energy Commission, 2015)
California’s once plentiful oil reserves of locally extracted crude are dwindling and nearing depletion. Since 1985, crude extraction in CA has dropped by half. Production from Alaska has dropped even more, from 2 million B/D (barrels per day) to around 500,000 B/D. The 1.9 million B/D refining capacity in CA is looking for new sources of fuels. Refineries continue to supplement crude feedstock with oil from other sources, and the majority has been coming from overseas, specifically Iraq and Saudi Arabia. This trend is shown in figure 1.
Predictions project that sources of raw crude oil are shifting to the energy intensive Bakken formation and Canadian Tar Sands. The Borealis Centre estimates an 800% increase of tar sands oil in CA refineries over the next 25 years (NRDC, 2015). The increase in raw material from these isolated locations means new routes are necessary to transport the crude to refineries. New pipelines and crude-by-rail facilities would be necessary, specifically in locations where there are not marine terminals such as the Central Valley and Central Coast of CA. The cheapest way for operators in the Canadian Tar Sands and North Dakota’s Bakken Shale to get their raw crude to CA’s refinery markets is by railroad (30% less than shipping by marine routes from ports in Oregon and Washington), but this process also presents several issues.
CA Crude by Rail
More than 1 million children — 250,000 in the East Bay — attend school within one mile of a current or proposed oil train line (CBD, 2015). Using this “oil train blast zone” map developed by ForestEthics (now called Stand) you can explore the various areas at risk in the US if there was an oil train explosion along a rail line. Unfortunately, there are environmental injustices that exist for communities living along the rail lines that would be transporting the crude according to another ForestEthics report.
The specific focus of the map in Figure 2 is the five proposed and eight existing crude-by-rail terminals that allow oil rail cars to unload at the refineries. The eight existing rail terminals have a combined capacity of 496,000 barrels. Combined, the 15 terminals would increase CA’s crude imports to over 1 million B/D by rail. The currently active terminals are shown with red markers. Proposed terminals are shown with orange markers, and inactive terminals with yellow markers. Much of the data on terminals was taken from the Oil Change International Crude by Rail Map, which covers the entire U.S.
The same type of facility is currently operating in the East Bay’s refinery corridor in Richmond, CA. The Kinder Morgan Richmond terminal was repurposed from handling ethanol to crude oil, but with no public notice. The terminal began operating without conducting an Environmental Impact Report (EIR) or public review of the permit. Unfortunately, this anti-transparent process was similar to a tactic used by another facility in Kern County. The relatively new (November 2014) terminal in Taft, CA operated by Plains All American Pipeline LLC also did not conduct an EIR, and the permit is being challenged on the grounds of not following the CA Environmental Quality Act (CEQA).
EIRs are an important component of the permitting process for any hydrocarbon-related facility. In April 2015 in Pittsburg, for example, a proposed 50,000 B/D terminal at the WesPac Midstream LLC’s railyard was abandoned due to community resistance and criticism over the EIR from the State Attorney General, along with the larger proposal of a 192,000 B/D marine terminal.
Crude-by-rail terminals bring with them not only the threat of derailments and the risk of other such accidents, but the terminals are also a source of air emissions. Terminals – both rail and marine – are major sources of PAH’s (polycyclic aromatic hydrocarbons). The Sacramento Valley Railroad (SAV) Patriot rail oil terminal at a business park on the former McClellan Air Force Base property actually had its operating permit withdrawn by Sacramento air quality regulators due to this issue (read more). The terminal was unloading and reloading oil tanker cars.
FracTracker’s recent report, Emissions in the Refinery Corridor, shows that the refineries in this region are the major point source for emissions of both cancer and non-cancer risk drivers in the region. These air pollution sources get worse, however. According to the report by NRDC, changing the source of crude feedstock to increased amounts of Canadian Tar Sands oil and Bakken Shale oil would:
… increase the levels of highly toxic fugitive emissions; heavy emissions of particulate, metals, and benzene; result in a higher risk of refinery accidents; and the accumulation of petroleum coke* (a coal-like, dusty byproduct of heavy oil refining linked to severe respiratory impacts). This possibility would exacerbate the harmful health effects faced by the thousands of low-income families that currently live around the edges of California’s refineries. These effects are likely to include harmful impacts to eyes, skin, and the nervous and respiratory systems. Read NRDC Report
The contribution to climate change from accessing the tar sands also needs to be considered. Extracting tar sands is estimated to release on average 17% average more green-house gas (GHG) emissions than conventional oil extraction operations in the U.S., according to the U.S. Department of State. (Greenhouse gases are gases that trap heat in the atmosphere, contributing to climate change on a global scale.) The refining process, too, has a larger environmental / public health footprint; refining the tar sands to produce gasoline or diesel generates an average of 81% more GHGs (U.S. Dept of State. Appendix W. 2015). In total this results in a much larger climate impact (NRDC, NextGen Climate, Forest Ethics. 2015).
Local Fights
People opposed to CA crude by rail have been fighting the railway terminal proposals on several fronts. In Benicia, Valero’s proposal for a rail terminal was denied by the city’s Planning Commission, and the project’s environmental impact report was denied, as well. The city of Benicia, however, hired lawyers to ensure that the railway projects are built. The legality of railway development is protected regardless of the impacts of what the rails may be used to ship. This legal principle is referred to as “preemption,” which means the federal permitting prevents state or local actions from trying to limit or block development. In this case, community and environmental advocacy groups such as Communities for a Better Environment, the Natural Resources Defense Council, and the Stanford-Mills Law Project all agree the “preemption” doctrine doesn’t apply here. They believe preemption does not disallow the city or other local governments from blocking land use permits for the refinery expansion and crude terminals that unload the train cars at the refinery. The Planning Commission’s decision is being appealed by Valero, and another meeting is scheduled for September, 2016.
The fight for local communities along the rail-lines is more complicated when the refinery is far way, under the jurisdiction of other municipalities. Such is the case for the Phillips 66 Santa Maria Refinery, located on California State Highway 1 on the Nipomo Mesa. The Santa Maria refinery is requesting land use permits to extend track to the Union Pacific Railway that transits CA’s central coast. The extension is necessary to bring the rail cars to the proposed rail terminal. This project would not just increase traffic within San Luis Obispo, but for the entirety of the rail line, which passes directly through the East Bay. The project would mean an 80-car train carrying 2 million gallons of Bakken Crude would travel through the East Bay from Richmond through Berekely and Emeryville to Jack London Square and then south through Oakland and the South Bay. This would occur 3 to 5 times per week. In San Luis Obispo county 88,377 people live within the half-mile blast zone of the railroad tracks.
In January, the San Luis Obispo County Planning Department proposed to deny Phillips 66 the permits necessary for the rail spur and terminals. This decision was not easy, as Phillips 66, a corporation ranked Number 7 on the Fortune 500 list, has fought the decision. The discussion remained open with many days of meetings, but the majority of the San Luis Obispo Planning Commission spoke in favor of the proposal at a meeting Monday, May 16. There is overwhelming opposition to the rail spur project coming from 250 miles away in Berkeley, CA. In 2014, the Berkeley and Richmond city councils voted to oppose all transport of crude oil through the East Bay. Without the rail spur approval, Phillips 66 declared the Santa Maria refinery would otherwise transport oil from Kern County via 100 trucks per day. Learn more about this project.
GIS Analysis
GIS techniques were used to estimate the number of Californians living in the half mile “at risk” blast zone in the communities hosting the crude-by-rail lines. First, we estimated the total population of Californians living a half mile from the BNSF and UP rail lines that could potentially transport crude trains. Next, we limited our study area to just the East Bay refinery corridor, which included Contra Costa and the city of Benicia in Solano County. Then, we estimated the number of Californians that would be living near rail lines if the Phillips 66 Santa Maria refinery crude by rail project is approved and becomes operational. The results are shown below:
Population living within a half mile of rail lines throughout all of California: 6,900,000
Population living within a half mile of rail lines in CA’s East Bay refinery communities: 198,000
Population living within a half mile of rail lines along the UP lines connecting Richmond, CA to the Phillips 66 Santa Maria refinery: 930,000
Asserting that the proposed Palmetto Pipeline is essential to supply gas and diesel to the residents of south Georgia and northern Florida, Houston-based energy giant Kinder Morgan has found themselves in the crosshairs of yet another battle. Connecting to the existing Plantation Pipeline, the proposed $1 billion Palmetto Pipeline would run from Belton, SC to terminals in Augusta, SC; Richmond Hill, GA; and Jacksonville, FL, a distance of 360+ miles. Along that corridor currently, gasoline is delivered from inland terminals to ports via trucking companies rather than by pipeline.
In order for the pipeline to be built through Georgia, agreements for a pipeline right-of-way would need to be sealed with 396 private landowners, and the land owned by these private citizens constitutes 92% of the route of the pipeline through the state. According to Kinder Morgan, however, 80% of the pipeline would be build next to (although not within) existing rights-of way for powerlines, pipelines, railroads, and roadways.
Kinder Morgan asserts that the Palmetto Pipeline would create 28 permanent jobs in Georgia. However, opponents of the pipeline measure the flip-side of economic impacts, with more than 250 jobs lost for coastal Georgia truckers, port workers, and Merchant Marines, as a result of changing the transportation medium for the petroleum to pipeline from truck.
The proposed pipeline would carry 167,000 barrels a day of refined petroleum – crossing the Savannah River, four other major watersheds in Georgia (Ogeechee, Altamaha, Satilla, and St. Mary’s), the upper reaches of the Okefenokee watershed, and countless freshwater, tidal, and brackish wetlands. These aquatic and terrestrial ecosystems through which the pipeline would pass are home to diverse numbers of rare and endangered species, as well as sportfish and notable forest habitats. Much of the area is underlain by extensive karst rock deposits, and as such, is especially at risk for groundwater contamination.
Pipeline Push Back
Example of a 42-inch Pipeline Installation in WV
A fight against the pipeline is being waged between the public and Kinder Morgan. Opponents of the pipeline, such as the group “Push Back The Pipeline,” point out contradictions between Kinder Morgan’s rhetoric and the actual situation. For example, although the pipeline will run underground, protected from surface disturbance, should it rupture, the spilled petroleum could still have major impacts on coastal rivers that drain through wetlands, marshes, and into the Atlantic Ocean. Although 80% of landowners approached by Kinder Morgan for rights-of-way agreed to sign leases, it turns out that none of them were given the option not to sign. Kinder Morgan surveyors also trespassed on landowner property in the proposed right-of-way without any permission to be there. Kinder Morgan asserts that the pipeline will reduce reliance on foreign oil, when, in fact, the US is already a net exporter of petroleum products. Kinder Morgan also claims that the need for this oil will only increase, when statistics show that Georgia’s energy demands peaked in 2002, and have fallen 18% between 2005 and 2012 (data from eia.gov). Property owners along the proposed pipeline route are no strangers to spills, either. Kinder Morgan claims that pipelines are the safest method for transporting fuel. As recently as December 2014, however, Kinder Morgan’s Plantation Pipeline in Belton, SC – the location where Palmetto is proposed to start – spilled at least 360,000 gallons of fuel into the ground. Only half of the spilled fuel was recovered.
Opposition to the project is not following party lines. In May of 2015, Georgia’s Republican governor, Nathan Deal, vowed to fight the project in court. Similarly, the Georgia Department of Transportation rejected the proposal, stating that it was not in the public interest, and therefore, seizing the right-of-way by eminent domain was not an acceptable strategy for Kinder Morgan to pursue.
Another formidable opponent of the project is William S. Morris III, a powerful media magnate who owns newspapers in Jacksonville, Savannah, and Augusta and has been providing continual coverage of the controversy. Morris also owns more than 20,000 acres directly along the pipeline route, and could potentially lose an 11- mile corridor of land to eminent domain if the pipeline project is approved.
In late February 2016, a Georgia House subcommittee approved a moratorium on use of eminent domain on petroleum pipelines. Eminent domain would allow Kinder Morgan to take a 50-foot-wide strip of land for the pipeline right-of-way, whether or not the private citizens owning that land were in favor. The bill now moves on to a full committee. Georgia state law also requires that petroleum companies must prove a project meets guidelines of “public necessity” before eminent domain could ever move ahead.
Although Kinder Morgan hopes to see the pipeline built and in service by December 2017, critical components, such as a complete right-of-way, are far from finalized.
See the recent documentary created about the Palmetto Pipeline here:
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2016/03/Palmetto-Pipeline-Feature.jpg400900Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2016-03-04 15:47:472020-03-12 17:32:43Proposed Palmetto Pipeline: At what cost?
For anyone who even casually follows Marcellus and Utica shale gas exploration and production, such as in the active gas fields of West Virginia or Southwestern PA or Ohio, we know there are many concerns surrounding the natural gas production process. These issues range from air pollution, water consumption and contamination, to waste disposal. We know that, after all well the pad drilling and construction traffic are done, we must also have pipelines to get the gas to compressor stations, processing plants, and to markets in the Eastern United States (and likely Europe and Asia in the near future). Gas companies in Wetzel County, WV, and in neighboring tri-state counties, are convinced that building pipelines – really big pipelines – will be the silver bullet to achieving some semblance of stability and profitability.
Problems With Proposed Pipelines
One of the new, very large diameter (42”) proposed gas pipelines getting attention in the press is the Mountain Valley Pipeline, which will originate in the village of Mobley in eastern Wetzel County, WV and extend Southeast, through national forests and over the Appalachian Mountains into the state of Virginia. Even if the residents of Wetzel County and other natural gas fields are guinea pigs for experiments with hydraulic fracturing, we know how to build pipelines, don’t we? The equipment, knowledge, and skill sets needed for pipeline construction is readily available and commonly understood compared to high pressure horizontal drilling with large volumes of slick water. So, what could go wrong?
I can answer that question first hand from my hayfield in Wetzel County. Almost two years ago, EQT wanted to survey my property for a similar proposed pipeline – this one 30” in diameter, called the Ohio Valley Connector (OVC). The application for this project has now been filed with the Federal Energy Regulatory Commission (FERC). The below map shows a section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land. Multiple routes were being explored at first. Were this version approved, it would have gone right through my hayfield and under our stream.
A section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land.
Pipeline opponents express concern about habitat fragmentation, the crossing of pristine streams and rivers, erosion and sedimentation issues, spills, gas leaks, and possible explosions. These are all very valid concerns. But the potential for other logistical errors in the building process – from very simple to potentially serious ones – are also worth consideration. In this article I will use my recent personal experience as a detailed and documented example of how a professionally surveyed location on my property contained an error of almost one mile – over 4,000 feet – as part of a pipeline construction planning project. Yes, you read that right.
Part I: How Did We Get To This Point
Before we get to my story, I should review my first contact with EQT on this issue. In February of 2014, an EQT land agent asked me for permission to walk my property for preliminary evaluation of a route that would send their 30” high-pressure pipe through our land, from south to north.
It is important to keep in mind that almost every landowner in Wetzel County has been contacted by mail, phone or in person, by land agents promising cash with a verbal assurance that all will be well. The goal is to get a landowner’s signature on a loosely worded “right of way” (RoW) lease contract, with terms favorable to the gas company, and move on. Unfortunately, pipeline lease offers cannot be ignored. Not objecting or not questioning can sometime leave the landowner with fewer choices later. This is because many of the bigger interstate transmission lines are being proposed as FERC lines. When final approval is granted by FERC, these pipelines will have the legal power of eminent domain, where the property owner is forced to comply. Just filing a FERC application does not grant eminent domain in West Virginia, as it seems to in Virginia, but the potential for eminent domain gives land agents power over landowners.
I was not ready to give them surveying permission (to drive stakes or other permanent markers). Since a natural gas pipeline would affect all my neighbors, however, I agreed to allow a preliminary walk through my property and to hang surveyor ribbons in exchange for answering my questions about the project. For instance, one of my biggest concerns was the potential for significant habitat fragmentation, splitting up the forest and endangering wildlife habitat.
There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.
I never did get answers to most of my questions in the few e-mail exchanges and phone conversations with EQT. I never saw the surveyors either. They simply came and left their telltale colored ribbons. Later, at a public meeting an EQT representative said the closest they would run the pipe to any residence would be 37.5 feet. That number is correct. I asked twice. They said they had the right to run a pipeline that close to a residence but would do their best not to. The 37.5 feet is just one half of the permanent RoW of 75 feet, which was also only part of a 125 foot RoW requested for construction. A few months later, a very short e-mail said that the final pipeline route had changed and they would not be on my property. For a time we would enjoy some peace and quiet.
A Word On Surveyors
Most folks can relate to the work and responsibility of bookkeepers or Certified Public Accountants (CPAs). They measure and keep track of money. And their balance sheets and ledgers actually have to, well, BALANCE. Think of Surveyors as the CPAs of the land world. When they go up a big hill and down the other side, the keep track of every inch — they will not tolerate losing a few inches here and there. They truly are professionals, measuring and documenting everything with precision. Most of the surveyors I have spoken with are courteous and respectful. They are a credit to their profession. They are aware of the eminent domain threat and their surveying success depends on treating landowners with respect. They are good at what they do. However, as this article will show, their professional success and precision depends on whether or not they are given the correct route to survey.
Part II: Surveyor Stakes and Flags
Over the next year we enjoyed peace and quiet with no more surveyors’ intrusions. However, in my regular travels throughout the natural gas fields here, countless signs of surveyor activity were visible. Even with the temporary slowdown in drilling, the proposed pipeline installations kept these surveyors busy. Assorted types of stakes and ribbons and markings are impossible to miss along our roads. I usually notice many of the newer surveyor’s flags and the normal wooden stakes used to mark out future well pads, access roads, compressor stations, and more recently pipelines. Given that survey markings are never taken down when no longer needed, the old ones sometimes hide the new ones.
It can be difficult keeping track of all of them and hard at first to identify why they are there. Even if sometimes I am not sure what a stake and flag might indicate, when one shows up very unexpectedly in what is essentially my front yard, it is impossible to not see it. That is what happened in August of 2015. Despite being unable to get our hay cut due to excessive rain the previous month, the colored flags were highly visible. Below shows one of the stakes with surveyor’s tape, and the hay driven down where the surveyors had parked their trucks in my field alongside my access road.
A surveyor stake alongside my access road.
To call it trespassing might not be legally defensible yet. The stakes were, after all, near a public roadway – but the pins and stakes and flags were on my property. Incidents like this, whether intentional or accidental, are what have given the natural gas companies a reputation as bad neighbors. There were surveyors’ stakes and flags at two different locations, my hay was driven down, and I had no idea what all this meant given that I had no communication from anyone at EQT in over 18 months. I consider myself fortunate that the surveyors did not stray into wooded areas where trees might have been cut. It’s been known to happen.
Below shows the two sets of wooden stakes, roughly 70-80 feet apart, with flags and capped steel rebar pins. Both stakes were near the road’s gravel lane, which is a public right of way. Nevertheless, the stakes were clearly on my property. The markings on one side of the stake identify the latitude, longitude, and the elevation above sea level of the point. The other side of the stake identified it as locating the OVC pipeline (seen here as “OVC 6C):
These identifying numbers are unique to this pin which is used to denote a specific type of location called a “control point.” Control points are usually located off to the side of the center-line of the pipeline:
A control point, located off to the side of the center-line of the pipeline.
It seemed that somehow, without informing me or asking permission to be on my land, EQT had changed their mind on the OVC route and were again planning to run a pipeline through my property. If this was intentional, both EQT and I had a problem. If this was some kind of mistake, then only EQT would have a problem. Either way I could not fathom how this happened. Trespassing, real or perceived, is always a sensitive topic. This is especially true since, when I had initially allowed the surveyor to be on my property, I had not given permission for surveying. Given concerns about eminent domain, I wanted answers quickly. I documented all this with detailed pictures in preparation for contacting EQT representatives in Pittsburgh, PA, with my complaints.
Part III: What Happened & How?
I think it is safe to say that, in light of my well-known activism in documenting all things Marcellus, I am not your average surface owner. I have over 10,000 photographs of Marcellus operations in Wetzel County and I document every aspect of it. Frequently this leads to contacting many state agencies and gas operators directly about problems. I knew which gas company was responsible and I also knew exactly who in Pittsburgh to contact. To their credit, the person I contacted at EQT, immediately responded and it took most of the day to track down what had happen. The short story was that it was all a simple mistake—a 4,300 foot long mistake—but still just a mistake. The long story follows.
The EQT representative assured me that someone would be out to remove their stakes, flags and the steel pins. I told them that they needed to be prompt and that I would not alter or move their property and locating points. The next day, when I got home, the stakes with flags were gone. Just a small bare patch of dirt remained near the white plastic fencepost I had placed to mark the location. However, since I am a cultivated skeptic—adhering to the old Russian proverb made famous by President Reagan, “Trust but Verify”—I grabbed a garden trowel, dug around a bit, and clink, clink. The steel pin had just been driven deeper to look good, just waiting for my tiller to locate someday. I profusely re-painted the pin, photographed it, and proceeded to send another somewhat harsh e-mail to EQT. The pin was removed the next day.
After all the stakes, ribbons, and steel pins were removed, EQT provided further insights into what had transpired. Multiple pipeline routes were being evaluated by EQT in the area. Gas companies always consider a wide range of constraints to pipeline construction such as road and stream crossings, available access roads, permission and cooperation of the many landowners, steepness of terrain, etc. At a certain point in their evaluation, a final route was chosen. But for unknown reasons the surveyor crew was given the old, now abanoned, route on which to establish their control points. The magnitiude of the error can be seen on the map below. The bright blue line is the original path of the OVC pipeline through my property and the red line shows where the FERC filed pipeline route will go. A new control point has now been established near the highway where the pipeline was meant to cross.
The FERC filed OVC pipeline route vs. the accidentally surveyed route.
Part IV: Lessons To Be Learned
Given the likely impact of many proposed large-diameter, very long, pipelines being planned, it seems useful to examine how these errors can happen. What can we learn from my personal experience with the hundreds of miles of new pipelines constructed in Wetzel County over the past eight years? First, it is important to ask whether or not similar problems are likely to happen elsewhere, or if this was this just an isolated incident. Can we realistically expect better planning on the proposed Mountain Valley Pipeline, which will run for over 300 miles? Can the residents and landowners living along these pipeline RoWs expect more responsible construction and management practices?
In general, many of the pipeline projects with which landowners, such as those in Wetzel County, are familiar with fall into the unregulated, gathering line category. They might be anywhere from six inches in diameter up to sixteen inches. As we review their track record, we have seen every imaginable problem, both during construction and after they were put into operation. We have had gas leaks and condensate spills, hillside mud slips, broken pipes, erosion and sedimentation both during construction and afterwards.
Now for some apparently contradictory assumptions—I am convinced that, for the most part, truck drivers, pipeliners, equipment operators, drilling and fracturing crews, well tenders and service personnel at well sites, all do the best job they can. If they are given the proper tools and materials, accurate directions with trained and experienced supervision, the support resources and the time to do a good job, then they will complete their tasks consistently and proudly. A majority of employees in these positions are dedicated, trained, competent, and hard working. Of course, there are no perfect contractors out there. These guys are human too. And on the midnight shift, we all get tired. In the context of this story, some pipeline contractors are better and more professional than others, some are more experienced, and some have done the larger pipelines. Therefore, despite best intentions, significant errors and accidents will still occur.
The Inherent Contradictions
It seems to me that the fragile link in natural gas production and pipeline projects is simply the weakness of any large organization’s inherent business model. Every organization needs to constantly focus on what I refer to as the “four C’s—Command and Control, then Coordination and Communication—if they are to be at all successful. It is a challenge to manage these on a daily basis even when everyone is in the same big building, working for the same company, speaking the same language. This might be in a university, or a large medical complex, or an industrial manufacturing plant.
But the four C’s are nearly impossible to manage due to the simple fact that the organizational structure of the natural gas industry depends completely on hundreds of sub-contractors. And those companies, in turn, depend on a sprawling and transient, expanding and collapsing, network of hundreds of other diverse and divergent independent contractors. For example, on any given well pad, during the drilling or fracturing process, there might be a few “company” men on site. Those few guys actually work for the gas company in whose name the operating permit is drawn. Everyone else is working for another company, on site temporarily until they are ready to move on, and their loyalty is elsewhere.
In the best of situations, it is next to impossible to get the right piece of information to the right person at just the right time. Effective coordination among company men and contractors is also next to impossible. I have seen this, and listened in, when the drilling company is using one CB radio channel and the nearby pipeline company is using some private business band radio to talk to “their people.” In that case, the pipeline contractors could not talk to the well pad—and it did not matter to them. In other cases, the pilot vehicle drivers will unilaterally decide to use another CB radio channel and not tell everyone. I have also watched while a massive drill rig relocation was significantly delayed simply because a nearby new gas processing plant was simultaneously running at least a hundred dump trucks with gravel on the same narrow roadway. Constant communication is a basic requirement for traffic coordination, but next to impossible to do properly and consistently when these practices are so prevalent.
These examples illustrate how companies are often unable to coordinate their operations. Now, if you can, just try to picture this abysmal lack of command and control, and minimal communication and coordination, in the context of building a 300-mile length of pipeline. The larger the pipeline diameter, and the greater the overall length of the pipeline, the more contractors will be needed. With more contractors and sub-contractors, the more coordination and communication are essential. A FERC permit cannot fix this, nor would having a dozen FERC permits. Unfortunately, I do not envision the four Cs improving anytime soon in the natural gas industry. It seems to be the nature of the beast. If, as I know from personal experience, a major gas company can arrange to locate a surveyed control point 4,300 feet from where it should have been, then good luck with a 300 mile pipeline. Even with well-intentioned, trained employees, massive problems are still sure to come.
The FERC approvals for these pipelines might not be a done deal, but I would not bet against them. So vigilance and preparation will still be of the essence. Citizen groups must be prepared to observe, monitor, and document these projects as they unfold. If massive pipelines like the MVP and OVC are ever built, they should become the most photographed, measured, scrutinized, and documented public works projects since the aqueducts first delivered water to ancient Rome. For the sake of protecting the people and environment of Wetzel County and similar communities, I hope this is the case.
Appendix: Questions to Ask When Approached by a Land Agent (Landsman)
These questions can be modified to suit your location. The abbreviation “Gas Corp.” is used below to reference a typical natural gas company or a pipeline subsidiary to a natural gas company. These subsidiaries are frequently called Midstream Companies. Midstream companies build and manage the pipelines, gas processing, and some compressor stations on behalf of natural gas companies.
Please provide a Plain English translation of your landowner initial contract.
What will Gas Corp. be allowed to do, and not allowed to do, short term and long term?
What will Gas Corp. be required to do, and not required to do?
What is the absolute minimum distance this pipeline will be placed away from any dwelling anywhere along its entire length?
What restrictions will there be on the my land after you put in the pipelines?
Who will be overseeing and enforcing any environmental restrictions (erosion and sedimentation, slips, stream crossings, etc.)?
Who will be responsible for my access road upkeep?
Who will be responsible for long term slips and settlements of surface?
When would this construction begin?
When would all work be completed?
Who would be responsible for long term stability of my land?
Will the pipeline contractor(s) be bound to any of our agreements?
Who are the pipeline contractor(s)?
What will be transported in the pipeline?
Will there be more than one pipe buried?
How wide is the temporary work RoW?
How wide is the permanent RoW?
How deep will the pipeline(s) be buried?
What size pipe will it be; what wall thickness?
How often will the welds on the individual pipe segments be inspected?
Will there be any above ground pipeline components left visible?
Where will the pipe(s) originate and where will they be going to?
What will the average operating pressure be?
What will the absolute maximum pressure ever be?
At this pressure and diameter, what is the PIR—Potential Impact Radius?
Will all pipeline and excavating and laying equipment be brought in clean and totally free from any invasive species?
How will the disturbed soil be reclaimed?
Will all top soil be kept separate and replaced after pipeline is buried?
Also, After all the above is settled, how much will I be paid per linear foot of pipeline?
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/12/Pipeline-Feature.png400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2016-02-17 10:21:412020-03-12 17:33:44A Push For Pipelines
The following guide is a simplified description of a variety of markings that are used by land surveyors. Throughout an active shale gas field, the first signs of pending expansions are the simple markings of stakes, flags, and pins. Many months or even years before the chain saw fells the first tree or the first dozer blade cuts the dirt at a well pad location, the surveyors have “marked the target” on behalf of their corporate tactical command staff.
The three most commonly used markings are the simple stakes, flags and pins. These surveyor symbols are common to any construction project and guarantee that everything gets put in the right place. In an active gas field, these marking tools are used for all aspects of exploration and production:
access roads to well pads,
widening the traveled portion of the roadway,
well locations,
ponds and impoundment locations,
temporary water pipeline paths,
surface disturbance limits,
compressor stations,
gas processing sites, and
rights-of-way for roads and pipelines.
Quite frequently these simple markings are undecipherable by themselves, especially by non-professionals. One cannot just know what is happening, what is likely to occur, or how concerned one should be. Context and additional information are usually needed. Sometimes the simple colors and combinations of colored tapes might only make sense in conjunction with similar markings nearby. Sometimes public notices in the newspaper and regulatory permits must be used to decipher what is planned.
For an example, the proposed 30″ diameter EQT pipeline called the Ohio Valley Connector seems to be regularly marked using a combination of blue and white (see figure 10 below) surveyors tape to mark the actual pipeline location, then green and white (see figure 4 below) to mark all the proposed access roads along the routes that will be used to get pipe trucks and excavation equipment into the right of way. These access roads might be public roadways or cut across private leased property.
Common surveyor symbols & signs (click on images to zoom in)
Surveyor flags and tape: Sometime the flags or streamers are just attached to trees, fence posts, or put on a stake to make them visible above the weeds. There might be no markings on the stake, or only simple generic markings. This could just mean that this is the correct road and turn here. It could also signal a proposed or approximate location for some future work.
Simple surveyor’s flags or tape
Surveyor flags and tapes: These are a selection of typical surveyor tapes, also called flags or ribbons. Many other specialty color combinations are available to the professional surveyor.
A selection of surveyor tapes
Stakes with simple markings: Flags with some type of identification (it might be names or numbers). This one was used for a proposed well pad access road location. There are no dimensions given on these.
Stake with simple markings
Stakes with simple flags and basic identification: The stakes shown here all indicate an access route to be used for equipment and trucks to get to a proposed pipeline right of way. The “H310″ is the EQT name for the 30” OVC pipeline.
Stakes indicating an access route
Control points: These three stakes are identifying a control point that is outside the limits of disturbance (LoD). These markings surround a pin to be used for reference.
Control point stakes
Controls points: This stake is also identifying a control point location. All control points will have some type of driven metal rod, usually with a plastic cap identifying the surveyor. Frequently there are three stakes with extra flags or tape. They are always set off to the side of the intended work area. They are not to be disturbed.
Control point stake and pin
Control points: Another set of three stakes marking a Control Point location. It is common to see triple stakes with elaborate, multiple flags. Even if only two stakes are present, there always will be a driven steel pin and identifying cap.
Control point stakes and pin
Control points: This shows a close-up of the identifying cap on a metal driven steel pin. Control point locations are not meant to be disturbed as they are for future and repeated reference. They might give the latitude and longitude on the stake plus the altitude above sea level.
Control point pin and cap
Control points: This is another, older control point location. This represents a typical arrangement where the stakes somewhat try to protect the metal pin from a bulldozer blade by warning its operator.
Control point pin protection
Limit of disturbance: The “L O D” here means the limits of disturbance. Beyond this point there should not be any trees cut or dirt moved. The stakes shown here indicates that this is the outside limit of where the contractor will be disturbing the original contour of the surface soil.
Limit of disturbance stakes
Limit of disturbance: The “L O D” means the limits of disturbance of the proposed pipeline right of way. Beyond this point there should not be any trees cut or dirt moved. This could also be used for the outside edge of well pads or access roads or pond locations.
Limit of disturbance ROW stakes
Pipelines: Stakes with flags and “center line” markings are usually for pipelines. Here you see the symbol for center line: a capital letter “C” imposed on the letter “L”.
Pipelines center line
Pipelines: Again you see the capital letter “C” super imposed on top of the letter “L” used frequently for pipe line center lines, but can also be used for proposed access roads.
Pipelines center line
Pipelines: As shown here, “C” and “L” center line flags can also be used for future well pad access roads.
Road access center line
Precise location markings: Stakes like this will usually have a steel pin also associated with it. This stake gives the latitude, longitude, and elevation of the site.
Precise location stake
Permanent property lines: You may also find markings, like this one inch steel rod with an alum cap, that denote permanent property lines and corners of property.
Permanent property rod
Permanent property lines: Another kind of permanent property line or corner marker is the “boundary survey monument.” This is likely an aluminum cap on top of a one inch diameter steel bar.
Over the past seven years, there has been a very strong upswing in domestic oil production coming from Bakken Formation in North Dakota. Extraction rates increased over 700% between November 2007 and November 2015, to over 1.2 million barrels per day. With all this oil coming out of the North Dakota oil fields, the challenge is how to get that oil to port, and to refineries. For the large part, the method of choice has been to move the oil by rail. Annual shipments out of North Dakota have jumped from 9500 carloads in 2008 to close to a half million carloads by 2013.
Nearly 25% of oil leaving the Bakken Formation is destined for east coast refineries located in New Jersey, Philadelphia, and Delaware. Trains carrying the crude enter New York State along two routes. A southern route, passes through Minneapolis, Chicago, Cleveland, and Buffalo, and on to Albany. A northern route, which originates in the oil fields of southern Manitoba and Saskatchewan Provinces in Canada, passes through Toronto, Montreal, and then south to Albany.
Currently, once the oil reaches Albany, it is transported south through the Hudson Valley, either by barge or by train. Two “unit trains” per day, each carrying 3 million gallons in 125-tank car trains, are bound for Philadelphia-area refineries. In addition, a barge per day, carrying 4 million gallons, heads to New Jersey refineries. Environmental groups in New York’s Hudson Valley, including Hudson RiverKeeper, have registered alarm and opposition about the potential impacts and risks of the transport of this process poses to the safety of residents of the Hudson Valley, and to the health of the Hudson River. More background information is available in this Pilgrim Pipelines 101 webinar.
What are the Pilgrim Pipelines?
The proposed Pilgrim Pipelines are two parallel 18-24-inch pipelines that would run from the Port of Albany to Linden, NJ, alongside the New York State Thruway (I-87) for 170 miles just to the west of the Hudson River, with nearly 80% of the pipeline within the public right-of-way. The rest of the pipeline would traverse private property and some utility areas.
The pipeline running south from Albany would carry the light, explosive crude to refineries in NJ, Philadelphia, and Delaware. After the oil is refined, the North-bound pipeline would carry the oil back to Albany, moving 200,000 barrels (8.4 million gallons) of oil in each direction, every day. Touted by Pilgrim Pipeline Holdings, LLC as a central component in “stabilization of the East Coast oil infrastructure,” the project proposes to:
provide the Northeast region of the United States with a more stable supply of essential refined petroleum products… and… provide the region with a safer and more environmentally friendly method of transporting oil and petroleum products.
The Controversy
The Pilgrim company is lead by two individuals with deep ties to the energy industry. Both the company president, Errol B. Boyles, as well as vice-president, Roger L. Williams, were in the upper echelon management of Wichita, Kansas-based Koch Industries.
Proponents of the project claim that it includes environmental benefits, such as 20% lower greenhouse gas emissions than would be generated moving the same quantity of oil via barge, and even claim that the proposed Pilgrim Pipelines “will produce a net air quality benefit to the region.” Of course, this argument is predicated on the belief that the unbridled oil extraction from the Bakken Formation is both environmentally desirable, and nationally required.
Economic benefits described by the pipeline company include the faster rate the petroleum products can be pumped through existing terminals in New York, and also meet a hoped-for demand surge for petroleum products. Naturally, the company would also create some construction jobs (albeit somewhat temporary and for out-of-state firms), and increase fuel available to consumers at lower prices because of proposed transportation savings. However, the Albany Business Review indicated that the pipeline could actually create a net loss of jobs if the pipeline were to make the Port of Albany less active as a shipping location.
Project opponents cite both short- and long-term impacts of the project on human and environmental health, the local and regional economy, property values, nearly a dozen threatened and endangered wildlife species, water quality, ecology of the pristine Hudson Highlands Region, and contributions that the project invariably makes to accelerating climate change, both through local impacts, and as an infrastructure component supporting the extraction of crude from the East Coast all the way to the Bakken Fields of North Dakota. Groups also cite the high rate of “non-technical” pipeline failures, due to excavation damage, natural force damage, and incorrect operation.
Communities in Action
Close to 60 municipalities along the pipeline route have passed local resolutions and ordinances expressing their opposition to the pipeline. Residents assert that the local communities would bear most of the risks, and few, if any, of the benefits associated with the Pilgrim Pipeline. These communities, represented by over a million people in New York and New Jersey, are shown in the map below. Other groups – including the New Jersey State Assembly and Senate, numerous county boards in both New York and New Jersey, and several school districts – have also passed resolutions opposing the project.
Access links to the resolution documents for individual towns by clicking on the town location in the map below.
The New York State Thruway Authority was initially the sole lead agency on the State Environmental Quality Review (SEQR) of the project, a decision that was decried by impacted municipalities, environmental groups, and the Ramapough Lenape Nation. Dwain Perry, Ramapough Lenape chief, urged that the New York State Department of Environmental Conservation be the lead agency, instead, saying:
…DEC has a much more thorough outlook into different things that can happen….[and]..is looking out for everyone’s interest.
However, in a development announced in late December 2015, the New York State Department of Environmental Conservation revealed that they, along with the NYS Thruway Authority, would jointly lead the environmental review of the project. This decision has perplexed many groups involved in the debate, and environmental groups such as Scenic Hudson, Environmental Advocates of New York, Hudson Riverkeeper, and Coalition Against the Pilgrim Pipeline expressed their dismay over this choice, and urged that the SEQR review address whether the project will be consistent with NY Governor Cuomo’s aggressive goals to reduce carbon emissions that are driving climate disruption.
DEC’s own guidelines advise against creating co-lead agencies in projects particularly because there is no prescribed process for resolution of disputes between two such agencies. Nonetheless, a DEC spokesperson, Sean Mahar, tried to assure critics that because the two lead agencies have “unique and distinct expertise” few problems would arise.
We’ll post updates as the project’s SEQR process gets underway.
There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.
