New York State Department of Environmental Conservation (DEC) Oil and Gas Database includes records for nearly 45,000 wells in the state, nearly all of which are related to the oil and gas industry. Of these records, only 19,600 include drilling dates; some records simply reflect drilling permits that were applied for and expired, or were cancelled for other reasons. Of the records listed, 99% of those drilled are vertical, “conventional” wells.
Research by Bishop (2013) indicates that there could be more than 30,000 additional oil and gas wells that are not documented in the DEC’s database, and potentially not adequately plugged.
Over the past half-century, drilling activity in New York State has ebbed and flowed. In that period of time, drilling interest in oil and gas saw two main peaks: between 1975 and 1985, and — especially for gas — between 2004 and 2010. Gas drilling activity has currently tailed off to practically nothing since the ban on high-volume hydraulic fracturing was passed in late 2014.
In this article we’ll look specifically at spatial and temporal patterns in oil and gas drilling across New York State.
Every year, FracTracker updates the full state-wide dataset of oil, gas, and other assorted (non-drinking water) wells. To see the entire “big picture,” you can explore our interactive map below, which shows all wells in the New York State database, from prior to 1900 through late February 2021.
New York State Oil and Gas Wells
This map shows that, despite New York State banning high volume hydraulic, nearly 45,000 wells have been drilled, according to the Department of Environmental Conservation (DEC). Not all the wells in the DEC’s database were actually drilled; some were sites that were permitted, but never explored. Many have been plugged and abandoned. There may be nearly as many undocumented wells as there are in the database, given that record keeping in earlier years was nowhere near as comprehensive as it is today.
In order to turn layers on and off in the map, use the Layers dropdown menu. This tool is only available in Full Screen view. Data sources can be found in the Details section of the map as well as listed the end of this article.
FracTracker has also taken a more fine-grained approach to consider the patterns in drilling in New York State both spatially and temporally. Using the DEC wells database, we first filtered out well data for records that had actual spud (drilling) dates between 1970 and the present. Then, using pivot tables in Microsoft Excel, we graphed the data, and also looked for patterns around where the drilling was taking place.
Emergent from this process, we see the following.
Oil and gas hotspots are directly related to the underlying geology of a region. In New York State, the majority of oil wells have been drilled in the Chipmunk and Bradford Formations, followed by the Fulmer Valley, Glade, and Richburg Formations.
Oil Wells in NYS and Their Associated Geological Formations
Updated February 2021
Figure 1. Oil Wells in NYS and Their Associated Geological Formations. Gas wells have historically been most productive in the Medina Formation, followed by the Queenston, and also Trenton-Black River Formations. Data source: New York State DEC Oil and Gas Database.
Gas Wells in NYS and Their Associated Geological Formations
In 1982 and 1983, gas drilling in New York State surged, with 774 and 667 new wells drilled over those two years, respectively. The hot spot was in the Medina Group, which over the years, continued to be a primary focus. Well depths in this section of bedrock average around 3,400 feet at that time, although wells were exploited at a more shallow depth in subsequent years. Starting in 1995, gas was discovered in the Black River shale formation, with reservoirs more than 10,000 feet deep in some places. All of these wells were vertically oriented, but still were exploited using hydraulic fracturing technologies.
The early to mid-1980s marked a relatively high level in oil well drilling in New York State, with a peak occurring in 1984, with 153 wells drilled. After a lull of about 20 years, activity picked up again in 2005, hitting a high point in 2006 when 188 oil wells were drilled. In 2010, there was another peak with 188 wells, followed by a waning period of 4 years. Then, in 2019, interest exploded in a small area of the Bradford oil fields in Cattaraugus County, with 156 wells drilled, and an average production of 319 barrels per well over the course of that year.
According to EIA estimate from 2014, the cost of drilling an onshore oil well is between $4.9 – 8.3 million, however smaller vertical wells like those common in New York State are likely to cost more in the range of $150,000. With the price of oil at $64 a barrel in 2019, in its first year in production, the gross profit of any of these wells in New York, based on reported production, would have been between $0 and $120,000, with an average year around $20,400 per well. It’s hard to imagine how drilling for oil in recent years in New York State could have possibly been profitable, in particular with the steep drop-off in production typically seen after the first year or two.
These simple examples of a localized “oil boom” in New York State provide a stark example of exactly how unsustainable these endeavors are, particularly for small drilling operators. So, despite the enthusiastic rush to oil drilling in 2019, activity after that has been followed by a quick decline, with only 41 oil wells drilled in New York State in 2020, and only 4, so far, in 2021.
Patterns in other types of wells
The increase in dry wells seems to track with the general patterns of oil and gas exploration. Hence, in periods when a lot of oil and gas wells are being drilled, there will be a higher number of wells that are dry, or nonproductive. During the 1970s, there was also a strong peak in disposal wells drilled. We are not certain whether this is, or is not, related to the high number of gas wells drilled during this period.
New York State moving towards better stewardship of legacy wells
Some of the oil and gas wells drilled in the 19th and early 20th century were particularly poorly documented (or not documented at all), and improperly plugged. This creates a public and environmental safety hazard, with more than 30,000 of these undocumented oil and gas wells spread across the state potentially leaking methane into the air and water. Finding the abandoned and orphan wells has been a long term problem because they are often located in rough terrain across central and western New York. Fortunately, the New York State Department of Environmental Conservation has taken new measures to locate and plug these legacy wells, using drone technology. FracTracker reported on a pilot initiative a few years ago that was testing this technique, but the new program is backed by $400,000 in funding from NYSERDA, the New York State Energy Research and Development Authority, in support of New York States ambitious goals to reduce greenhouse gas emissions through the Climate Leadership and Community Protection Act.
One hundred years ago, few people expressed concerns about the environmental hazards associated with oil and gas drilling. Record-keeping was spotty, which has left us with a legacy of wells whose locations are lost to memory, or simply improperly plugged. After several periods of vigorous mineral extraction activity in the 1980s and early 2000s, oil and gas drilling has declined in its profitability, and formerly easily-accessed reserves have been depleted. Today, with unprecedented interest in clean energy sources like wind, geothermal, and solar, society can become less dependent on fossil fuels, and focus on responsibly stewarding the remnants of these “dinosaurs,” using new technologies to help clean up the damages left by them.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/New-York-State-wells-feature.jpg8331875Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2021-04-01 11:10:062021-04-15 14:08:35New York State Oil & Gas Well Drilling: Patterns Over Time
In December 2019, Plains All-American and Valero pipeline companies announced plans to build the 49-mile Byhalia Pipeline through southwestern Tennessee and northwestern Mississippi. The proposed Byhalia Connection Pipeline is a 24-inch, high pressure (1500 psi) conduit, conveying crude oil coming Oklahoma, bound for the Gulf coast. The pipeline, which is designed to carry up to 420,000 barrels of oil a day, provides a link between the Diamond Pipeline to the west and the Capline Pipeline to the east. Construction is planned to begin in early 2021, and be completed by year’s end. Plains All-American insists that all safety precautions are being considered, but the outcry among residents and environmental advocates has been considerable.
Many factors—environmental, geological, social, and economic—have emerged as reasons that this pipeline should not move ahead. And industry most certainly didn’t count on pushback from the local community. Residents, allies, and the media have risen up to challenge the project. In this article, we’ll take a look at the story from various perspectives, augmented by FracTracker’s mapping insights.
UPDATE: On Friday, July 2, 2021, Plains All American announced that it would be abandoning its plans to build the controversial Byhalia Connection Pipeline. As one activist involved in the fight proudly stated, “We’ve shown them that we aren’t the path of least resistance. We are the path of resilience.” Read more about this momentous victory for the people of South Memphis here.
This interactive map looks at the various risks associated with the proposed Byhalia Connection Pipeline. The map contains all of the data layers related to the topics in this article. Scroll down in this article to find interactive maps separated out by topic. All data sources are listed in the “Details” section of the maps, as well as at the end of this article. Items will activate in this map dependent on the level of zoom in or out.
The 49-mile route of the proposed Byhalia Connection Pipeline passes through a patchwork of rural, suburban, and urban landscapes. Along the route, the pipeline would cross seven named waterways — Johnson Creek, Hurricane Creek, Bean Patch Creek, Camp Creek, Short Brook, Camp Creek Canal, and Coldwater Creek — and also pass immediately adjacently to a nearly 5-mile-long wetlands complex that surrounds the Coldwater River. But the natural environment is home to many more waterways than those that have official names on topographic maps. According to FracTracker’s inspection of National Wetlands Inventory data collected by the United States Fish and Wildlife Service, the proposed pipeline crosses or touches 62 streams in 102 separate locations, 25 forested wetlands, an emergent wetland, 17 ponds, and one lake.
Close to the City of Memphis, 0.8 miles of the pipeline would run directly through the Davis Wellfield Wellhead Protection Zone. The proposed pipeline is located over the extraordinary Memphis Sands Aquifer, which provides potable water for more than 400,000 people. Memphis Light, Gas and Water (MLGW) Company pumps water from over 175 artesian wells in Shelby County, Tennessee, alone—right in the path of the pipeline route. The aquifer itself is a sensitive resource, already under demand by the human population of the area, as well as many industries such as breweries and as a supply of cooling water for a nearby power plant.
Memphis Sands Aquifer is part of the larger Middle Claiborne Aquifer, a groundwater and geological unit in the lower Mississippi drainage. Technically speaking, the Memphis Sands portion of the aquifer is located in Tennessee, but is continuous with the Sparta Sands Aquifer, located in Mississippi. In the eastern portion of the Byhalia Connection’s proposed route, wetlands along Coldwater River are directly part of the recharge zone of this aquifer.
Byhalia hydrologic components
To learn more about the hydrologic features that may be impacted by the proposed Byhalia Connection Pipeline, explore our interactive map. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.
The Memphis Sands Aquifer lies 350 to 1000 feet under Memphis (see Figure 1), and spans an area of 7500 square miles, roughly the size of Lake Ontario. “It’s one of the best (aquifers) in the world in terms of thickness, aerial content, quality of water”, according to Roy Van Arsdale, Professor of Geology at University of Memphis. Under Shelby County alone — where Memphis is located — the aquifer contains approximately 58 trillion gallons of clean water. Over time, the aquifer has seen threats from overpumping, as the population of Memphis grew. In addition, industrial pollution has turned up in some samples, including cancer-causing benzene. Policy protections on the aquifer have been lacking, although there is increasingly vocal public awareness about the need for more comprehensive groundwater resource protection in the area.
Figure 1. Cross-section of aquifers under Memphis, TN. Graphic modified from here.
Although water withdrawals from the aquifer have declined significantly since 2000 due, in part, to more water-efficient household appliances that reduce demand in comparison with older models, the MLGW pumped 126 million gallons a day from the aquifer in 2015. Consequently, the level of the aquifer has been rising in recent years, as the rate of recharge has exceeded use.
The courts have suggested that the water in the aquifer is an intrastate resource, and that therefore, Mississippi cannot have sole governance over the extraction of the water within its state boundaries. Instead, usage should be through “equitable apportionment.” Further arguments are still pending, as of late 2020. In short, as Figure 1 shows, withdrawal and recharge of the aquifer do not respect state boundaries.
The details of water law, and who can tap into these, and other deep, ancient aquifers, are complex questions in which agriculture, ecology, geology, and technology bump up against each other. All of these interests, not to mention human health, could be heavily impacted by a crude oil pipeline rupture or other accident that resulted in contamination of this groundwater resource.
Crude oil spills release a panoply of volatile organic compounds into the air and water that are extremely harmful to human and environmental health. These include benzene, ethylbenzene, toluene, and xylene. Polycyclic aromatic hydrocarbons (PAHs), such as carcinogenic benzo[a]pyrene, are also released. In addition, if the oil combusts, hydrogen sulfide gas, as well as heavy metals, including nickel, mercury, and cadmium, will become airborne.
The take-away is that crude oil spills from pipelines are not uncommon, result in environmental damage, impacts on the health and safety of workers and nearby residents. Most importantly, despite monitoring and inspections, pipelines fail. A partial list of pipeline failures is shown in the sidebar.
Within the 2-mile buffer of the pipeline, there are 20 facilities that the United States Environmental Protection Agency (US EPA) lists in its Toxic Release Inventory (TRI), including several chemical plants associated with hydrocarbon extraction. Carcinogens such as polycyclic aromatic compounds, benzene, styrene, dioxins, and naphthalene are just a few of the compounds produced by facilities owned by Valero Energy Corporation, Drexel Chemical Company, and other companies within the 2-mile buffer zone of the pipeline, which compound the risks to the populations there. In addition, while the TRI lists exposure to toluene and xylene from these facilities, neither are categorized by EPA’s TRI database as a carcinogen due to a lack of data; however, their deleterious impacts on the central nervous system are undeniable, and well- documented (see examples here and here).
In this interactive map, you can see sites in the proposed Byhalia Connection route that are listed in the TRI, as well as civic facilities like schools, daycare centers, and health care facilities. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.
The most active seismic fault line in the eastern United States — the New Madrid Fault — is located about 40 miles from one end of the proposed pipeline (see Figure 2). The last major earthquakes along this fault line occurred in 1811 and 1812. Although the current Richter scale was not in use at that time, first quake in mid-December 1811 was estimated to have had a magnitude of between 7.2 and 8.2, and was followed by an aftershock of about 7.4. In January and February of 1812, there were additional earthquakes of this magnitude. Obviously, at this time in history, there was relatively sparse population in the area, and little infrastructure. Were such a quake to occur today, the outcomes would be catastrophic.
According to a Wikipedia entry, “[i]n October 2009, a team composed of University of Illinois and Virginia Tech researchers headed by Amr S. Elnashai, funded by the Federal Emergency Management Agency, considered a scenario where all three segments of the New Madrid fault ruptured simultaneously with a total earthquake magnitude of 7.7. The report found that there would be significant damage in the eight states studied – Alabama, Arkansas, Illinois, Indiana, Kentucky, Mississippi, Missouri, and Tennessee – with the probability of additional damage in states farther from the New Madrid Seismic Zone. Tennessee, Arkansas, and Missouri would be most severely impacted, and the cities of Memphis, Tennessee, and St. Louis, Missouri, would be severely damaged. The report estimated 86,000 casualties, including 3,500 fatalities, 715,000 damaged buildings, and 7.2 million people displaced, with two million of those seeking shelter, primarily due to the lack of utility services. Direct economic losses, according to the report, would be at least $300 billion.” Source: University of Illinois report]
Another article on the New Madrid fault added that “….the US Geological Survey and the University of Memphis Center for Earthquake Research estimate there’s a 7 to 10 percent chance of a major quake — one with a magnitude between 7.5 and 8.0 — occurring in the region in the next 50 years….’ The scope is about as big as you could possibly have,’ said Jonathon Monken, director of the Illinois Emergency Management Agency and chairman of the Central U.S. Earthquake Consortium… ‘Putting it in a purely financial context, Hurricane Katrina was a $106 billion disaster. We estimate this would be a $300 billion disaster, the worst in the history of the United States.’”
Earthquake damage to pipelines can occur from movement on the fault itself, soil liquefaction, uplift, and landslides, resulting in potentially catastrophic situations. Engineering solutions to minimize or prevent seismic damage to pipelines do exist. These solutions must be part of the overall pipeline design, however. For example, the Trans-Alaska oil pipeline was constructed with considerations for earthquake impacts in mind. For more information, read about the solution that was implemented there.
Byhalia geological context
This map shows the New Madrid seismic zone in the context of the proposed Byhalia Connection Pipeline. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu.
As eloquently reported in a series of articles in mlk50.com, the siting of the Byhalia Connection Pipeline is not only an issue environmental tied with the natural environment. This is very much an issue of environmental justice, as well. Many of the census blocks along the proposed, preferred route of the pipeline, are 99% Black. Boxtown, a community in southwest Memphis is one of places, and already has a long history of impacts by environmental contamination from the dozens of industries that operate there. Toxic waste from coal power plants includes heavy metals and radioactive materials.
The pipeline route from Memphis to its terminus in Mississippi takes a circuitous route, avoiding wealthier parts of the city and its suburbs, but goes directly through low-income areas, some of which are inhabited by a nearly 100% Black population.
FracTracker looked at US Census data along the pipeline route, and calculated a half-mile (minimum recommended) and two-mile buffer zone from the pipeline right-of-way to consider populations that might be impacted in the case of an accident.
Byhalia route demographics
Explore the the demographics along the proposed Byhalia Connection Pipeline route. When this map is viewed full-size, you can choose to view additional layers from the drop-down Layers menu, such as the non-white population ration along the proposed pipeline route.
There are 15,000 people living in the immediate evacuation zone of a half mile from the pipeline. In some parts of South Memphis, within this half-mile evacuation zone, population density is above 4,000 people per square mile, and the Black population approaches 100%. Within a two mile distance, the number climbs to over 76,000. Depending on the direction of the wind, a crude oil-induced fire could spew dangerous levels of volatile organic compounds through the air towards these populations. The disproportional risks to minority and low-income populations make the location of this pipeline — undeniably — an issue of environmental justice.
Within ½ mile of Byhalia Connection Pipeline
Within 2 miles of Byhalia Connection Pipeline
7204 (48%, although some parts of South Memphis are 99+%)
27,548 (36%, although some parts of South Memphis are 99+%)
Low income population
4272 (28%, although some parts of South Memphis are 90+%)
43,486(57%, although some parts of South Memphis are 90+%)
Table 1: Population demographics along the proposed Byhalia Connection pipeline corridor.
Key civic facilities are also located within the half-mile evacuation zone of the pipeline. Were a disaster to occur, would the schools, childcare centers and medical facilities be able to successfully usher their residents and students to safety? Would they have had regular safety trainings to prepare them for this possibility?
Within ½ mile of pipeline
Within 2 miles of pipeline
4 (one within 800 feet)
2 (one within 800 feet)
Table 2: Facilities along the proposed Byhalia Connection pipeline corridor (also shown in the interactive map here).
Al Gore calls proposed Byhalia Connection pipeline ‘reckless, racist rip-off’ at rally
Former Vice President Al Gore voiced his opposition to the Byhalia Connection and put Memphis elected officials on notice during a rally against the pipeline on March 14, 2021.
“Why is it that 64% of the polluting facilities of these pipeline communities are located in or adjacent to Black communities? Why is it that the cancer rate in SW Memphis four times higher than the national average? Why is it that Black children suffer from asthma three times more than white children? Why is it that the death rate from asthma for Black children is ten times higher than for white children?” – Former Vice President Al Gore
Approximately 300 property owners adjacent to the pipeline have already accepted monetary compensation to abandon their homes or sell property easements to make way for the pipeline. If a landowner refuses payment offered by the pipeline company for a property easement — often far under market value — the company can take the landowner to court, and seize the property (or portion of it) with no requirement of compensation. Although a majority of property owners accepted the terms of the easements drawn up by Byhalia’s developers, at least 14 did not. When numerous owners refused, nine properties were targeted for taking by eminent domain, and sued by the pipeline company. The Southern Environmental Law Center (SELC) is defending many of these property owners, claiming that the seizures — regardless of whether they are temporary or permanent — do not comply with the criteria of meeting a public good. The oil being transported in the proposed pipeline is entirely bound for export.
“The pipeline company is not created by, affiliated with or owned by the government, and the general public would have no access to the proposed crude oil pipeline… So, there is no ‘public use’ justifying the use of the condemnation power as required by Tennessee law,” said one of SELC’s attorneys. In addition, SELC has cited the illegality of the pipeline route because it runs through the municipal wellfield, and therefore violates permits issued by the Army Corps of Engineers. The Army Corp was still considering this request, as of mid-January 2021.
Furthermore, the eminent domain targeting of land owned by Black Americans in the south is a pointed question of racial justice. Historically, black and brown people throughout the United States have had far lower levels of home ownership than whites. This gap is most pronounced in lower income areas.
Figure 5: Homeownership rate in the US, by household income (2017). Source: The Urban Institute.
“The 71.9 percent white homeownership rate in 2017 represented a 0.7 percentage point decline since 2010, and the 41.8 percent black homeownership rate represented a 2.7 percentage point decline during that same period. The 30.1 percentage point gap is wider than it was when race-based discrimination against homebuyers was legal.” The Urban Institute
Losing land to eminent domain represents a loss of control for a landowner — white or black. But the loss is especially unjust when a property may have been so hard won, and sometimes the result of a multi-generational lineage of ownership, as is the case for many properties along the Byhalia right-of-way.
Crude oil spills, 2010-2021
FracTracker has created an interactive map showing the locations of crude oil spills across the United States between 2010 and 2021, using the most up-to-date information from PHMSA, the Pipeline and Hazardous Materials Safety Administration.
The litany of reports of pipeline accidents associated with the transport of crude oil bear witness to an astounding volume that leaks into the environment — much of which cannot be cleaned up. Pipelines leak. Causes range from corrosion and failed fittings and seams, to striking the pipeline accidentally with heavy machinery, to “acts of God” like landslides.
These types of accidents and spills are too many to mention, but Wikipedia and other grassroots sites list scores of incidents between 2000 and 2019, alone. During that time period, at least 8.5 million gallons of crude oil were spilled into the environment. While the Byhalia pipeline is supposed to be buried 4 feet underground, and a handful of the accidents on this list involved pipelines exposed to the air, crude oil pipeline spills occurred for numerous other reasons, including:
490,000 gallon release due to a rupture caused by a dent in the pipeline (Kentucky, 2000)
192,000 gallon release due to a break in a miter bend (Pennsylvania, 2000)
150,000 gallon release after pipeline was struck by highway maintenance equipment (Oklahoma, 2001)
252,000 gallon release into a marsh, due to pipe failure from shipping-induced cracks (Minnesota, 2002)
100,000 gallon release, some of which flowed into Nemadji River near a terminal (Wisconsin, 2003)
Multiple incidents with Enbridge pipeline spilling in excess of 26,000 gallons (Michigan, 2003)
5000 gallon release from pipeline near Yellowstone River (Montana, 2004)
36,000 gallon spill (Oklahoma, 2005)
210,000 gallon spill into Prudhoe Bay as a result of poor maintenance to remove corrosion (Alaska, 2006)
134,000 gallon release from pipeline failure (Minnesota, 2006)
63,000 gallon release into farmland and drainage ditch due to incomplete weld in pipeline (Wisconsin, 2007)
201,000 gallon spill contaminates water table after construction crew struck the pipeline (Wisconsin, 2007)
Leak and explosion (killing two workers) of pipeline due to safety, repair, and maintenance failures (Minnesota, 2007)
1,300,000 gallon spill due to a pipeline seam failure (Texas, 2008)
243,000 gallon spill due to a pipeline seam failure (Illinois, 2008)
52,500 gallon release into a farm field and nearby creek, due to pipeline rupture (Ohio, 2009)
6500 gallon release due to maintenance operation failure (Wisconsin, 2009)
159,000 gallon release from rupture of pipeline due to material defect (North Dakota, 2010)
843,444 gallon spill into wetlands due to pipe rupture. 50 homes evacuated due to dangerous benzene levels. The cost of the clean-up was $1.21 billion US (Michigan, 2010) Source: here
21,000 gallon spill near wetlands (Illinois, 2010)
84,000 gallon spill due to pipeline corrosion (Wyoming, 2010)
16,800 gallon spill due to threaded connection failure on pipeline (North Dakota, 2011)
42,000 gallon release from pipeline rupture due to internal pipeline corrosion (Oklahoma, 2011)
60,000 gallon spill into Yellowstone River due to pipeline rupture (Montana, 2011)
8400 gallon leak from pipeline (Louisiana, 2012)
38,000 gallon spill at a tank farm (Illinois, 2012)
300,000 gallon spill into yards and gutters, and towards lake. Wildlife coated, 22 houses evacuated. Failure due to hook cracks and low impact toughness of pipeline seam (Arkansas, 2013)
15,288 gallon spill when contractors struck a pipeline (Texas, 2014)
18,900 gallon spill into wildlife preserve after pipeline failure (Ohio, 2014)
189,000 gallons spilled as result of a pipeline rupture, killing wildlife (Louisiana, 2014)
30,000 gallon spill in one hour due to a broken pipeline, contaminating a public water supply (Montana, 2015)
124,000 gallon spill after a pipeline rupture (California, 2015)
4200 gallon spill into a creek after a pipeline fitting failed (Illinois, 2015)
37,800 gallon leak, two weeks after the same pipeline passed inspection (California, 2015)
42,000 gallon leak into a terminal, due to internal corrosion in the pipeline (Oklahoma, 2015)
1500 gallon spill into a creek bed (Wyoming, 2016)
21,000 gallon spill, only days after pressure was increased in a pipeline (California, 2016)
45,000 gallons of spilled from a pipeline (California, 2016)
5300 gallon spill into water after pipeline hit by a dredger (Louisiana, 2016)
319,000 gallons sprayed an area after a pipeline rupture (Oklahoma, 2016)
529,800 gallon spill into a creek after a pipeline was damaged from a landslide (North Dakota, 2016)
420,300 gallon spill when pipeline failed for unknown causes (Colorado, 2017)
42,630 gallon spill from ruptured pipeline, due to internal corrosion (Texas, 2017)
19,000 gallon release from pipeline (Oklahoma, 2017)
87,000 gallon spill after contractor hit a pipeline, resulting in an evacuation of nearby residents (Texas, 2017)
672,000 gallon spill under the Gulf of Mexico, due to a cracked pipeline (Louisiana, 2017)
276,900 gallon spill in 15 minutes, after a metal-tracked vehicle ran over a pipeline (South Dakota, 2017)
84,000 gallon leak into a pond after a pipeline ruptured (Oklahoma, 2018)
31,000 gallon leak into a creek, contaminating 5 miles of the waterway, caused by an open valve (Oklahoma, 2019)
383,000 gallon leak into a 5-acre wetland (North Dakota, 2019)
Case study of a pipeline explosion
A 2020 research paper states, “Modeling and analysis of a catastrophic oil spill and vapor cloud explosion in a confined space upon oil pipeline leaking” provides a stark example of the damage done from the leak and explosion of a crude oil pipeline operating at a third of the pressure proposed for Byhalia.
“It is obvious that the explosion caused big damages to the adjacent buildings, roads, and public structures. Moreover, the explosion, combustion, and the shock wave caused injuries and deaths of workers, pedestrians, and residents. The total affected zone spread nearly 5 km [3.1 miles].”
Note: The oil pipeline shown in Shengzhu, Xu, et al.’s paper in was 28 inches in diameter, and operating at a pressure of between 400 and 660 psi. A vapor cloud from the spill into a municipal drainage area caused this explosion, which killed 62 people and injured 136 in November 2013. The 24-inch, proposed Byhalia pipeline would operate at triple the pressure of the pipeline shown in these photos of its explosion.
(a) bird’s eye view of the location of the explosion point, (b) scene of the oil spill point after explosion, (c) scene of the nearby street, (d) scene of the drainage of the adjacent plant.
Figure 7: Scene of an oil pipeline explosion site in China. (a) bird’s eye view of the location of the explosion point, (b) scene of the oil spill point after explosion, (c) scene of the nearby street, (d) scene of the drainage of the adjacent plant. Image from Shengzhu, Xu, et al.
In case of a large spill: Consider initial downwind evacuation for at least 300 meters (1000 feet).
In case of a fire: If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions. Source: Petroleum crude oil hazards
Protests are ongoing, and just recently, on February 22, 2021, United States Congressional Representative Steve Cohen sent a direct appeal to President Biden to revoke a key permit for Byhalia, directly citing the burden the pipeline would impose on long-suffering Black neighborhoods in South Memphis. Simultaneously, the Public Works Department of Memphis is considering a resolution condemning the pipeline, and asking the Memphis Light, Gas, and Water Division to oppose the project.
This story will undoubtedly continue to evolve in the upcoming months.
Regardless of where a pipeline is sited, there are inevitably risks to the environment, and to human communities living nearby. The proposed Byhalia Connection pipeline project is situated in a particularly problematic intersection where environmental justice, hydrology, geology, and risks to human and environmental health intersect. Without taking all of these factors into consideration, a potentially catastrophic cascade of impacts may ensue. Engagement and resistance to the project by the residents in the area, as well as support by advocacy groups, will hopefully result in comprehensive consideration of all the risks. Time will tell whether the project is modified, or simply defeated.
Non-white percentage, 1/2 mile evacuation zone from Byhalia pipeline
Data downloaded 21 April 2020 from ftp://newftp.epa.gov/EJSCREEN/2019/ by FracTracker Alliance, then reprojected into UTM, clipped, and recalculated 27 January 2021. Data originally posted by US Environmental Protection Agency on 11/8/2019.
Non-white percentage, 2-mile buffer to Byhalia pipeline
Data downloaded 21 April 2020 from ftp://newftp.epa.gov/EJSCREEN/2019/ by FracTracker Alliance, then reprojected into UTM, clipped, and recalculated 27 January 2021. Data originally posted by US Environmental Protection Agency on 11/8/2019.
Low income percentage, 1/2 mile evacuation zone from Byhalia pipeline
Data downloaded 21 April 2020 from ftp://newftp.epa.gov/EJSCREEN/2019/ by FracTracker Alliance, then reprojected into UTM, clipped, and recalculated 27 January 2021. Data originally posted by US Environmental Protection Agency on 11/8/2019.
Low income percentage, 2-mile buffer to Byhalia pipeline
Data downloaded 21 April 2020 from ftp://newftp.epa.gov/EJSCREEN/2019/ by FracTracker Alliance, then reprojected into UTM, clipped, and recalculated 27 January 2021. Data originally posted by US Environmental Protection Agency on 11/8/2019.
The Falcon Ethane Pipeline System is at the center of major investigations into possible noncompliance with construction and public safety requirements and failing to report drilling mud spills, according to documents obtained from the Pennsylvania Department of Environmental Protection (PA DEP) by FracTracker Alliance. These investigations, which are yet to be released, also uncovered instances of alleged data falsification in construction reports and Shell Pipeline Company firing employees in retaliation for speaking up about these issues.
Shell’s Falcon Pipeline, which is designed to carry ethane to the Shell ethane cracker in Beaver County, PA for plastic production, has been under investigation by federal and state agencies, since 2019. The construction of the pipeline is nearing completion.
Allegations in these investigations include issues with the pipeline’s coating, falsified reports, and retaliation against workers who spoke about issues.
These investigations reveal yet another example of the life-threatening risks brought on by the onslaught of pipeline construction in the Ohio River Valley in the wake in the fracking boom. They also reveal the failure of public agencies to protect us, as documents reveal the federal agency that oversees pipeline safety did not adequately respond to serious accusations brought to its attention by a whistleblower.
These allegations are serious enough to warrant immediate action. We’re calling on the Pipeline and Hazardous Materials Safety Administration (PHMSA) to thoroughly examine these allegations and suspend construction if not yet completed, or, in the case that construction is complete, operation of the Falcon Pipeline. Furthermore, we call on state environmental regulators to fully investigate construction incidents throughout the entire pipeline route, require Shell Pipeline to complete any necessary remediation, including funding independent drinking water testing, and take enforcement action to hold Shell accountable. Read our letters to these agencies here.
According to documents obtained through a public records request, a whistleblower contacted PHMSA in 2019 with serious concerns about the Falcon, including that the pipeline may have been constructed with defective corrosion coating. PHMSA is a federal agency that regulates pipeline operation. The whistleblower also shared environmental threats occurring within the DEP’s jurisdiction, prompting the PA DEP and Pennsylvania Attorney General’s Office to get involved.
Many of the issues with the Falcon relate to a construction method used to install pipelines beneath sensitive areas like roads and rivers called horizontal directional drilling (HDD). Shell Pipeline contracted Ellingson Trenchless LLC to complete over 20 HDDs along the Falcon, including crossings beneath drinking water sources such as the Ohio River and its tributaries. FracTracker and DeSmog Blog previously reported on major drilling mud spills Shell caused while constructing HDDs and how public agencies have failed to regulate these incidents.
Falcon Pipeline Horizontal Directional Drilling locations and fluid losses
This map shows the Falcon Pipeline’s HDD crossings and spills of drilling fluid spills that occurred through 3/5/2020. To see the data sources, click on the information icon found in the upper right corner of the map header as well as under the map address bar.
Correspondence between the PA DEP and PHMSA from February 26, 2020 reveal the gravity of the situation. While PHMSA conducted an inquiry into the whistleblower’s complaints in 2019 and concluded there were no deficiencies, PA DEP Secretary Patrick McDonnell wrote that his agency felt it was incomplete and urged PHMSA to conduct a more thorough investigation. Secretary McDonnell noted the PA DEP “has received what appears to be credible information that sections of Shell’s Falcon Pipeline project in western PA, developed for the transportation of ethane liquid, may have been constructed with defective corrosion coating protection,” and that “corroded pipes pose a possible threat of product release, landslide, or even explosions.”
FracTracker submitted a Freedom of Information Act request with PHMSA asking for documents pertaining to this inquiry, and was directed to the agency’s publicly available enforcement action webpage. The page shows that PHMSA opened a case into the Falcon on July 16, 2020, five months after Secretary McDonnell sent the letter. PHMSA sent Shell Pipeline Company a Notice of Amendment citing several inadequacies with the Falcon’s construction, including:
inadequate written standards for visual inspection of pipelines;
inadequate written standards that address pipeline location as it pertains to proximity to buildings and private dwellings;
compliance with written standards addressing what actions should be taken if coating damage is observed during horizontal directional drill pullback; and
inadequate welding procedures
Shell responded with its amended procedures on July 27, 2020, and PHMSA closed the case on August 13, 2020.
Of note, PHMSA states it is basing this Notice on an inspection conducted between April 9th and 11th, 2019, when construction on the Falcon had only recently started. PHMSA has confirmed its investigation on the Falcon is ongoing, however we question the accuracy of self reported data given to PHMSA inspectors should be questioned
The PA DEP also brought the matter to the attention of the US Environmental Protection Agency.
Timeline of events in the Falcon investigation
Public knowledge of these investigations is limited. Here’s what we know right now. Click on the icons or the event descriptions for links to source documents.
Shell confirms that the “instruments do not record data in real time and that site personnel record the information ‘contemporaneously with drilling operations’,” and propose to continue operations with this method
The Falcon pipeline also crosses through Ohio and briefly, West Virginia. While we do not know how these states are involved in these investigations, our past analyses raise concerns about the Ohio Environmental Protection Agency’s (OEPA) ability to regulate the pipeline’s HDD crossings.
One of the focuses of the Pennsylvania DEP’s investigation is the failure to report drilling fluid spills that occur while constructing a HDD crossing. The PA DEP shut down all HDD operations in November, 2019 and forced Shell to use monitors to calculate spills, as was stated in permit applications.
A horizontal directional drilling (HDD) construction site for the Falcon Pipeline in Southview, Washington County, Pennsylvania. You can see where the drilling mud has returned to the surface in the top left of the photo. Photo by Cyberhawk obtained by FracTracker Alliance through a right-to-know request with the Pennsylvania Department of Environmental Protection.
The Falcon Pipeline’s HDD locations are often close to neighborhoods, like the HOU-02 crossing in Southview, Washington County, Pennsylvania. Photo by Cyberhawk obtained by FracTracker Alliance through a right-to-know request with the Pennsylvania Department of Environmental Protection.
To our knowledge, the OEPA did not enforce this procedure, instead relying on workers to manually calculate and report spills. Shell’s failure to accurately self-report raises concerns about the safety of the Falcon’s HDD crossings in Ohio, including the crossing beneath the Ohio River, just upstream of drinking water intakes for Toronto and Steubenville, Ohio.
Public water system wells, intakes, and Drinking Water Source Protection Areas nears the Falcon Pipeline Route. Note, the pipeline route may have slightly changed since this map was produced. Source: Ohio EPA
The Shell ethane cracker
The Falcon is connected to one of Shell’s most high-profile projects: a $6 billion to $10 billion plastic manufacturing plant, commonly referred to as the Shell ethane cracker, in Beaver County, Pennsylvania. These massive projects represent the oil and gas industry’s far-fetched dream of a new age of manufacturing in the region that would revolve around converting fracked gas into plastic, much of which would be exported overseas.
Many in the Ohio River Valley have raised serious concerns over the public health implications of a petrochemical buildout. The United States’ current petrochemical hub is in the Gulf Coast, including a stretch of Louisiana known colloquially as “Cancer Alley” because of the high risk of cancer from industrial pollution.
While the oil and gas industry had initially planned several ethane crackers for the region, all companies except for Shell have pulled out or put their plans on hold, likely due to the industry’s weak financial outlook.
Royal Dutch Shell owes a more complete explanation to shareholders and the people of Pennsylvania of how it is managing risk. Shell remains optimistic regarding the prospects for its Pennsylvania Petrochemical Complex in Beaver County, Penn. The complex, which is expected to open in 2021 or 2022, is part of a larger planned buildout of plastics capacity in the Ohio River Valley and the U.S. IEEFA concludes that the current risk profile indicates the complex will open to market conditions that are more challenging than when the project was planned. The complex is likely to be less profitable than expected and face an extended period of financial distress.
Many of Pennsylvania’s elected officials have gone to great lengths to support this project. The Corbett administration enticed Shell to build this plastic factory in Pennsylvania by offering Shell a tax break for each barrel of fracked gas it buys from companies in the state and converts to plastic (valued at $66 million each year). The state declared the construction site a Keystone Opportunity Zone, giving Shell a 15-year exemption from state and local taxes. In exchange, Shell had to provide at least 2,500 temporary construction jobs and invest $1 billion in the state, giving the company an incredible amount of power to decide where resources are allocated in Pennsylvania.
Would the state have asked Shell for more than 2,500 construction jobs if it knew these jobs could be taken away when workers spoke out against life-threatening conditions? Will the politicians who have hailed oil and gas as the only job creator in the region care when workers are forced to hide their identity when communicating with public agencies?
States fail to regulate the oil and gas industry
The PA DEP appears to have played a key role in calling for this investigation, yet the agency itself was recently at the center of a different investigation led by Pennsylvania Attorney General Josh Shapiro. The resulting Investigating Grand Jury Report revealed systematic failure by the PA DEP and the state’s Department of Health to regulate the unconventional oil and gas industry. One of the failures was that the Department seldom referred environmental crimes to the Attorney General’s Office, which must occur before the Office has the authority to prosecute.
The Office of Attorney General is involved in this investigation, which the PA DEP is referring to as noncriminal.
The Grand Jury Report also cited concerns about “the revolving door” that shuffled PA DEP employees into higher-paying jobs in the oil and gas industry. The report cited examples of PA DEP employees skirting regulations to perform special favors for companies they wished to be hired by. The watchdog research organization Little Sis listed 47 fracking regulators in Pennsylvania that have moved back and forth between the energy industry, including Shell’s Government Relations Advisor, John Hines.
National attention on pipelines and climate
The Falcon Pipeline sits empty as people across the nation are amping up pressure on President Biden to pursue bold action in pursuit of environmental justice and a just transition to clean energy. Following Biden’s cancellation of the Keystone XL pipeline, Indigenous leaders are calling for him to shut down other projects including Enbridge Line 3 and the Dakota Access Pipeline.
Over a hundred groups representing millions of people have signed on to the Build Back Fossil Free campaign, imploring Biden to create new jobs through climate mobilization. Americans are also pushing Biden to be a Plastic Free President and take immediate action to address plastic pollution by suspending and denying permits for new projects like the Shell ethane cracker that convert fracked gas into plastic.
If brought online, the Falcon pipeline and Shell ethane cracker will lock in decades of more fracking, greenhouse gasses, dangerous pollution, and single-use plastic production.
Just as concerning, Shell will need to tighten its parasitic grip on the state’s economic and legislative landscape to keep this plant running. Current economic and political conditions are not favorable for the Shell ethane cracker: financial analysts report that its profits will be significantly less than originally presented. If the plant is brought online, Shell’s lobbyists and public relations firms will be using every tactic to create conditions that support Shell’s bottom line, not the well-being of residents in the Ohio River Valley. Politicians will be encouraged to pass more preemptive laws to block bans on plastic bags and straws to keep up demand for the ethane cracker’s product. Lobbyists will continue pushing for legislation that imposes harsh fines and felony charges on people who protest oil and gas infrastructure, while oil and gas companies continue to fund police foundations. Shell will ensure that Pennsylvania keeps extracting fossil fuels to feed its ethane cracker.
The Falcon pipeline is at odds with global demands to address plastic and climate crises. As these new documents reveal, it also poses immediate threats to residents along its route. While we’re eager for more information from state and federal agencies to understand the details of this investigation, it’s clear that there is no safe way forward with the Falcon Pipeline.
Royal Dutch Shell has been exerting control over people through the extraction of their natural resources ever since it began drilling for oil in Dutch and British colonies in the 19th Century. What will it take to end its reign?
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/03/Falcon-Ohio-River-Crossing-Feature-A.LauschkeLightHawk-scaled.jpg6671500Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngErica Jackson2021-03-17 08:48:432021-04-15 15:11:21Shell’s Falcon Pipeline Under Investigation for Serious Public Safety Threats
This article focuses on the city of Arvin as an example to show how some Frontline Communities in California are completely surrounded by an unrelenting barrage of carcinogenic and toxic air pollutants from oil and gas wells. Kern County’s proposed environmental impact report (EIR) would streamline the approval of an additional 67,000 new oil and gas wells in the County and thus further degrade air quality. We provide several recommendations for how local and state decision-makers can better protect public health from these serious threats.
Upstream greenhouse-gas and volatile organic compound (VOC) emissions from oil and gas extraction have been drastically under-reported throughout the United States, and California’s emissions regulations for oil and gas production wells are not comprehensive enough to protect Frontline Communities. The contribution of VOCs from the oil and gas extraction sector is responsible for California’s central valley and Kern County communities being exposed to the worst air quality in the country. As carcinogens, air toxics, and precursors to ozone, VOC’s present a myriad of health threats.
The contribution of VOCs from the well-sites in Kern, in addition to the cumulative burden of the Central Valley’s degraded air quality, puts Kern residents at considerable risk. Obvious loopholes in the California Air Resources Board’s oil and gas rule must be addressed immediately, and revised to prevent the cumulative impact of multiple exposure sources from causing additional documented negative health impacts. Additionally Kern County’s proposed environmental impact report (EIR) would streamline the approval of an additional 67,000 new oil and gas wells in the County and thus further degrade air quality. It is crucial that the EIR is instead revised to eliminate extraction near sensitive populations. (For more details on this proposal, see our more in depth environmental justice analysis of Kern County and our article on the proposed EIR.)
In support of establishing new public health rules that protect Frontline Communities, Earthwork’s Community Empowerment Project, in collaboration with the Central California Environmental Justice Network and FracTracker Alliance, has focused on documenting the uncontrolled emissions from extraction sites within and surrounding the small city of Arvin, California. Using infrared cameras with state of the art optical gas imaging (OGI) technology, the team documented major leaks at multiple well-sites. Footage from Arvin spans the years from 2016-2020. A collection of this footage has been compiled into the interactive story map that follows.
Toxic Emissions Filmed at Oil and Gas Wells in Arvin, CA
This StoryMap explores how current California regulations fail to stop emissions from tanks on oil and gas well-sites by looking at examples of emissions from well-sites in Arvin, California. Place your cursor over the image and scroll down to advance the StoryMap and explore a series of maps charting the fracking-for-plastic system. Click on the icon in the bottom left to view the legend.
The cases of uncontrolled emissions in the story map provides just an example of the inventory of uncontrolled emissions sources in Kern County, and California at large. Finding and filming emissions sources while using OGI cameras in California is not at all uncommon, otherwise there would not be seven prime examples just in the City of Arvin. Prior to 2018, emissions from these well-sites went completely unregulated. While the California oil and gas rule (COGR) was developed to address greenhouse gas emissions from small sources, certain aspects of the rule are not being enforced by the local air districts. Rather than requiring tanks to have closed evaporation systems the air districts allow operators to set pressure/vacuum hatches to open and emit toxic and carcinogenic vapors when pressure builds inside tanks. While this is a safety mechanism on tanks, in practice it allows tanks to be consistent sources of exposure that put neighboring communities at risk. Specifically, California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, § 95669, Leak Detection and Repair, Paragraph I states that “Hatches shall remain closed at all times except during sampling, adding process material, or attended maintenance operations.”
While the COGR rule is a step in the right direction to reduce emissions, oil and gas’s legacy of degradation to ambient air quality has placed the Central Valley in the worst categories for these pollutants in the country. This puts Kern residents at considerable risk. The local health department continues to report improved conditions and increased numbers of healthy air days, but the truth is the mean, median and maximum values of ozone concentrations at US EPA monitoring locations in Kern County have remained relatively constant at harmful levels from 2015-2019. Expanding the data to 2020 shows a two sharp decreases in ambient levels of pollutants that correspond to decreases in reported production volumes for the county. The first decrease in 2016 corresponds to a drop in production following the institution of State Bill requirements for fracking permits. The decrease in 2020 is a result of the slowed production and burning of fossil fuels related to the Covid-19 Pandemic, as shown below in Figure 1.
Figure 1. Plot of annual Maximum 1 hour Ozone concentrations at all monitoring locations in western Kern County. Ozone concentrations are presented in parts per million. Annual trends in ambient concentrations of ozone. Note the decrease in concentrations in 2016 and in 2020. Both events correlate to decreases in production.
Using the U.S. EPA’s AirData mapping portal, air quality data for Kern County was exported, compiled and plotted to show trends over time. Above in Figure 1, annual ambient concentrations of ozone are shown. The trends of ambient concentrations follow similar trends in the spatial and temporal distribution of CalGEM reported production volumes. FracTracker Alliance is conducting more thorough analyses of these correlations, so stay tuned for future reports.
The locations of these monitoring locations are shown below in the map in Figure 2. Note that there are not any monitors in northwestern Kern, near large oil fields including North Belridge and Lost Hills. The communities near these fields, such as the City of Lost Hills are predominantly Latinx with elevated levels of linguistic isolation and poverty.
Figure 2. Map of Air Quality Monitors in Kern County.
Permitting new oil and gas wells in Kern County is certain to degrade the already harmful local and regional ambient air quality of the Central Valley. Kern County’s proposed EIR, as it stands will streamline an additional 67,000 sources of VOCs to the inventory of emissions already impacting communities. The health impacts from concentrations of ozone are well established, and the release of VOCs are major risk driver for communities living closest to oil and gas extraction operations as well as for regional public health. Together, these primary and secondary pollutants create a major risk driver for Kern County communities. Globally, these emissions are responsible for upwards of 8 million premature deaths annually. The burden on Frontline Communities in Kern County is likely much higher, and will only grow if the currently drafted EIR is passed. Additional air quality monitoring stations in northwestern Kern County should be installed immediately to help track air quality impacts.
To reduce this harm to Frontline Communities, California Senator Scott Weiner has submitted a new senate bill. Senate Bill 467 would stop the issuance of hydraulic fracturing permits and create a public health setback distance of 2,500 feet from homes, schools and other health care facilities for all new drilling permits. The bill would also create a program to provide new training and job opportunities for workers who would be negatively impacted by the bill. Senate Bill 467 provides the first step for a green transition away from the health impacts resulting from fossil fuel industries.
The Take Away
Built on sound data and ample research, FracTracker recommends the following measures be taken to protect the health of California’s overburdened Frontline Communities: Kern County should revise its environmental impact report to address the onslaught of harmful oil and gas emissions (EIR), California Air Resources Board’s oil and gas rule should close its loophole allowing emissions from the pressure/vacuum hatch on the tank to be exempt from regulation, and legislators should educate themselves on the importance of 2,500 foot setbacks requirements for oil and gas wells.
References & Where to Learn More
FracTracker’s public comments regarding recommendations to modify the Kern County Draft Environmental Impact Report (EIR): https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/03/Kern.EIR_.comments_FracTrackerAlliance_3.8.21_compressed.pdf
Access to reliable data is crucial to our understanding of risky fracking waste disposal, and in turn, our ability to protect public health. But when it comes to oil and gas liquid waste disposal wells in Pennsylvania, despite monitoring by two separate agencies, we are left with an incomplete and inaccurate account.
If we were to emulate the Charles Dickens classic, this article might begin, “It was the best of datasets, it was the worst of datasets.” Unfortunately, even that would be too generous when it comes to describing available data around oil and gas liquid waste disposal wells in Pennsylvania. To fully understand the legacy and current state of these wells, it is necessary to query the two agencies that have a role in overseeing them, the United States Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (DEP).
Given the relatively small inventory of these wells compared to other oil and gas producing states, the problems with the two datasets are enormous. Before jumping into these issues, however, it would be useful to review the nature of these wells, why there are two regulatory agencies involved, and why there are so few of them in Pennsylvania in the first place, relatively speaking.
Disposal Wells Categories
To further our industrial exploits of the planet, humans have found it useful to inject all kinds of things into the earth. In the United States, this ultimately falls under the jurisdiction of EPA’s Underground Injection Control (UIC) program, and the point of injection is known as an injection well. Altogether, there are six classes of injection wells, with those related to oil and gas operations falling into Class II.
There are three categories of Class II injection wells, including waste disposal, enhanced recovery, and hydrocarbon storage. There is also an infamous exemption known as the “Haliburton Loophole,” which has allowed oil and gas companies to inject millions of gallons of hydraulic fracturing fluid into oil and gas wells in order to stimulate production without any federal oversight at all.
When most people speak of “injection wells” in an oil and gas context, they are usually referring to waste disposal wells, and this is our focus here. This well type is also referred to as Class II-D (disposal) and salt water disposal wells (SWD). This latter term is used by a majority of state regulators, so we will use that abbreviation here, even though considering this type of toxic and radioactive fluid “salt water” is surely one of the industry’s most egregious euphemisms.
Dealing with Dangerous Fluids
There are two main types of liquid waste that are disposed of at SWD injection wells. As always, these waste types have a number of different names to keep everyone on their toes but for the sake of simplicity will call them “flowback” and “brine,” and both are problematic materials to handle. Additionally, the very act of industrial-scale fluid injection presents problems in its own right.
As mentioned above, when operators pump a toxic stew of water, sand, and chemicals into a well to stimulate oil and gas production, that mixture is known as hydraulic fracturing fluid, or fracking fluid. Some of these chemicals are so secretive that even the operators of the well don’t know what is included in the mix, let alone nearby residents or first responders in the event of an incident.
Between 10% and 100% of this fluid will return to the surface, and is then known as flowback fluid, becoming a waste stream. In Pennsylvania, the average amount of fracking fluid injected into production wells exceeds 10 million gallons in recent years according to data from the industry’s self-reporting registry known as FracFocus. With more than 12,000 of these wells drilled statewide, disposing of this waste stream becomes an enormous concern.
In addition to flowback fluid, there are pockets of ancient fluids encountered by the drilling and fracking processes that return to surface as well. These solutions are commonly referred to as brine due to their extremely high salt content, although this is not the type of fluid that you’d want to baste a Thanksgiving turkey with. Total salt concentrations can reach up to 343 grams per liter, roughly ten times the salt concentration of sea water. These brines include but are not limited to the familiar sodium chloride that we use to season our food, but include other components as well, including significant bromide and radium concentrations.
When Pennsylvania experimented with our public health by authorizing disposal of these fracking brines in municipal plants designed to treat sewer sludge, the bromides in that drilling waste stream became problematic as they interacted with disinfectants to cause a cancerous class of chemicals known as trihalomethanes. This ended the practice of surface “treatment” from these sites into streams in 2011, and along the way caused many water authorities to switch from chlorine to chloramine disinfectant processes. This, in turn, may have exacerbated lead exposure issues in the region, as the water disinfected with chloramine often eats away at the calcium scale deposits covering lead pipes and solder in the region’s older homes.
Marcellus and Utica wastewater are also very high in a radioactive isotope of radium known as Ra-226, which has a half-life of 1600 years. After that amount of time, half of the present radium will have emitted an alpha particle, which can cause mutations in strands of DNA when introduced inside the body, through contaminated drinking water, for example. After the hazardous expulsion of the alpha particle, the result become radon gas, which is estimated to cause 20,000 lung cancer deaths per year in the United States. Further down the decay chain is Polonium 210, which was infamously used in the assassination of Russian spy Alexander Litvinenko in London in 2006.
None of this should be injected into formations beneath people’s homes, near drinking water supplies, streams, or really anywhere that we aren’t comfortable sacrificing for the next few thousand years.
On top of all the problems with the water chemistry of both produced water and brine, the very act of injecting these fluids into the ground has triggered a large number of earthquakes in areas with frequent or large volumes of waste injection. This human-caused phenomenon is known as induced seismicity. The most well-known example of this is the previously stable state of Oklahoma which surged to have more magnitude 3.0+ earthquakes than California for a number of years during a drilling boom in that region. The largest of these was the magnitude 5.8 Pawnee earthquake in 2016.
Figure 3. PA Earthquakes and Potential Causes: 1/2000 – 2/2021, Magnitude 2.0 or Greater. Most earthquakes in the eastern portion of the state are associated with Quaternary faults. In the western portion, the causes are less straightforward, and include zipper fracking, mine blasting or collapse, and faults that are more ancient and deeper than the Quaternary faults, many of which remain unmapped. As the use of SWD wells increases, seismic activity may increase as well.
Manmade earthquakes are not limited to Oklahoma. For example, there were approximately 130 seismic events in one year period in the Youngstown, Ohio area due to SWD activity, including one measuring 4.0 on the last day of 2011. Over the years, the regulatory reaction to induced earthquakes seems to walking along the slippery slope from “that can’t happen” to “that can’t happen here” to “they’re all small earthquakes” to “we can mitigate the impact,” despite all evidence to the contrary.
So who gets to be in charge of this dumpster fire? As mentioned above, this is ultimately under the umbrella of EPA’s Underground Injection Control program. However, they have a complicated arrangement with the various states defining who has primary enforcement authority for this type of well.
In Pennsylvania, such wells must obtain a permit from EPA before obtaining a second permit from DEP. In a 2017 hearing in Plum Borough, Allegheny County, furious residents concerned with a variety of issues with a proposed SWD well were told that in Pennsylvania, EPA could only consider whether or not the well would violate the 1972 Clean Water Act when considering the permit, and that the correct audience for everything else would be DEP. Both permits for this well that is near and undear to me were ultimately issued, and operations are expected to begin in the next month if Governor Wolf does not instruct the DEP to reconsider their permit.
There is some precedent for overturning such a permit. In March of 2020, DEP yanked a permit for a SWD well in Grant Township, Indiana County, suddenly respecting a home-rule charter law that the agency had previously sued the Township over.
Without the prospect of royalties or impact fees, no community wants these wells and regulators know that they are nothing but problems. However, the reality is that the regulators oversee an industry that produces a tsunami of this toxic waste – more than 61.8 million barrels of it from unconventional wells in Pennsylvania in 2020 according to self-reported data, which is almost 2.6 billion gallons of the stuff, or slightly more than the capacity of Beaverdam Run Reservoir in Cambria County, a 382 acre lake with an average depth of 20 feet.
Nationally, injection wells are quite common, with over 740,000 such wells in the EPA inventory for 2018 and Class II (O&G) wells represent about a quarter of this figure. Of these Class II injection wells, roughly 20% are for fluid disposal, giving us an estimated 37,000 SWD wells nationwide. This number is expected to go up, as more than three-quarters of the 8,600 permits issued in 2018 were for oil and gas purposes.
However, in Pennsylvania, there have been quite few of these, compared to other states. The primary reason for this is its geology, which has largely been considered unsuitable for this type of activity. For example, a 2009 industry analysis states:
“The disposal of flowback and produced water is an evolving process in the Appalachians. The volumes of water that are being produced as flowback water are likely to require a number of options for disposal that may include municipal or industrial water treatment facilities (primarily in Pennsylvania), Class II injection wells [SWDs], and on-site recycling for use in subsequent fracturing jobs. In most shale gas plays, underground injection has historically been preferred. In the Marcellus play, this option is expected to be limited, as there are few areas where suitable injection zones are available.”
I discussed this topic in a phone call with an official from EPA, who largely confirmed this point of view, but preferred the phrase, “the geology is complicated” instead of the word “unsuitable.” When the UIC program was established from the 1974 Safe Drinking Water Act, there were only seven such wells in operation, and according to EPA’s data, there were still just 11 active SWD wells in the Commonwealth but with more on the way. I was cautioned that the geology wasn’t the only reason, however. Neighboring Ohio had hundreds of these wells, many of which are clustered close to the border with Pennsylvania. The two states have different primacy and permitting arrangements, which is a factor as well.
I have not come across sources mentioning why Pennsylvania’s geology was so unsuitable – or complicated, if we are being generous. However, there are numerous widespread issues that could be a factor, including voids created by karst and legacy coal mines, and formations that might have otherwise trapped gasses and fluids being punctured with up to 760,000 mostly unplugged oil and gas wells and more than one million drinking water wells.
Even when these fluids have been pumped deep underground, they are not necessarily out of sight and out of mind. For example, an abandoned well in Noble County Ohio suddenly began spewing gas field brine just a few weeks ago, resulting in a fish kill in a nearby stream. The incident is believed to be related to SWD wells in the general vicinity even though the closest of these is miles away from the toxic geyser. The waste fluids injected beneath the surface will exploit any pathway available through crumbling or porous rocks to alleviate the pressure built up from the injection process. These fluids don’t care whether the target is an old gas well, mine void, or drinking water aquifer.
Of course, we could ask the question in reverse, and ask what makes the injection of oil and gas fluids suitable in other locations, and the aggregated evidence would lead us to “nothing” as our answer. Nothing, other than the fact that drilling and fracking produces billions of gallons of liquid waste, and that it has to go somewhere.
Although EPA play a major role in permitting and regulating SWD wells in Pennsylvania, they do not publish data related to these wells on their website. FracTracker started hearing rumors about a spate of new SWD permits all over the state that were not accounted for in DEP data. As it turns out, many of these turned out to be other oil and gas wastewater processing facilities, and the public’s confusion about these is completely understandable because these facilities lacked the proper public notice process. These facilities are concerning in their own right – and residents of Pennsylvania should look here to see if one of these 49 facilities are in their neighborhoods – but these are not disposal wells.
To clear up the confusion, I submitted a Freedom of Information Act request to EPA for a spreadsheet of their Class II injection wells in Pennsylvania. This was apparently an onerous task that would require more than ten hours of labor on their behalf. When I mentioned that I was mostly interested in disposal wells, that sped the process up considerably.
Ultimately, I received a portion of the data fields that I had asked for.
Well API Number
Class II Category (disposal, recovery, storage)
Date application received
Application status (e.g., pending, complete)
Application result (e.g., approved, rejected)
Application result date (date of EPA’s decision)
Well status (e.g., active, plugged)
Well county name
Well municipality name
Table 1 – Summary of fields requested and received in FracTracker’s FOIA submission with EPA.
I started to compare the EPA dataset to DEP’s SWD well dataset, which is a part of its conventional well inventory. Each source had 23 records. We were off to a good start, but this data victory turned out to be limited in scope as the discrepancies between the two datasets continued to grow. Inconsistencies between the two datasets are as follows:
DEP Well Name
EPA API Match
EPA Name Match
HARRY L DANDO 1
COLUMBIA GAS OF PENNA INC CGPA5
KENNETH A DIEHL D1
Not on EPA List
THE PEOPLES NATURAL GAS CO 4627X
Not on EPA list
FRANK & SUSAN ZELMAN 1
DEP / EPA API Number mismatch
No EPA API No.
IRVIN A-19 FMLY FEE A 19
SPENCER LAND CO 2
FEE SENECA RESOURCES WARRANT 3771 38268
FEE SENECA RESOURCES WARRANT 3771 38282
DEP / EPA API Number mismatch
NORBERT CROSS 2
HAMMERMILL PLT 1
Not on EPA List
Not on EPA List
Not on EPA List
Not on DEP list. EPA Permit PAS2D210BGRE – no API to match
MARJORIE C YANITY 1025
T H YUCKENBERG 1
W SHANKSVILLE SALT WATER DISP 1
MORRIS H CRITCHFIELD 1
H A HEINRICK RW-55
Category Anomaly – Not on DEP SWD list – does appear as Plugged OG Well (consistent w/ EPA status notes)
API Mismatch (But does match Bittinger #1) Lat/Long match site name
JOSEPH BITTINGER 1
API Mismatch (But does match Bittinger #4) Lat matches site name, Long slightly off
JOSEPH BITTINGER 2
JOSEPH BITTINGER 3
Category Anomaly – Not on DEP SWD list – does appear as “Injection”
SMITH/RAS UNIT 1
Category Anomaly – Not on DEP SWD list – does appear as “Observation”
LEROY STODDARD & FRANK COFFA 1 WELL
Not on DEP list of all wells. Does appear on eFACTS. No location data
Table 2 – Discrepancies between EPA and DEP data for SWD wells in PA.
Altogether, there was at least one data discrepancy on 17 out of 28 wells (61%) on the combined inventories, and this is allowing for significantly different formatting of the well’s name. The DEP list contained five records that were not on the EPA dataset at all, four records where the well’s API number did not match, three instances where the DEP well type was different from EPA’s listing, two wells with matching API numbers but different well names, two wells that were missing the API number on the EPA list, and one well that was on the EPA list that I have not been able to find in any of DEP’s inventories. These last two wells could not be mapped due to the lack of location data.
It isn’t always possible to know which dataset is erroneous, but the EPA list has several obvious omissions and one instance where the API number and well name are in the wrong columns. The quality of DEP data has improved over the years and appear to have some data controls in place to avoid some of these basic errors. For that reason, I suspect that most of the problems stem from the EPA dataset, and I have used DEP coordinates to map these wells.
Waste Disposal Wells in Pennsylvania
This map contains numerous layers that explore the current state of Class II-D Salt Water Disposal (SWD) injection wells for oil and gas waste in Pennsylvania. View the map “Details” tab below in the top left corner to learn more and access the data, or click on the map to explore the dynamic version of this data.
In the early 1970s, it was recognized that industrial injection of oil and gas waste underground could lead to risks to human health and the environment, so several major protective laws were put in place, including the Clean Water Act of 1972, the Safe Drinking Water Act of 1974, and the Pennsylvania’s 1971 Environmental Rights Amendment. Decades later, it feels like the Pennsylvania Department of Environmental Protection and the United States Environmental Protection Agency don’t take their regulatory responsibilities very seriously when it comes to oil and gas liquid waste disposal wells. While the state does have fewer of this type of well than other states, there are five that are currently under construction, according to the EPA dataset. Many of these, like the Sedat 3A well in Allegheny County, have come after significant community opposition, and many of the residents’ concerns have not been addressed by either agency.
There will undoubtedly be more of these disposal wells proposed in the near future. Residents would do well to hassle their municipalities to update their ordinances for this type of well if they happen to live in a place where such ordinances are possible. Solicitors should be instructed to regularly scour the Pennsylvania Bulletin and be in contact with EPA for the earliest possible notification of a proposed site, so that there is time to respond within the comment periods.
Additionally, the sloppiness of the datasets calls all sorts of questions into play regarding the co-regulation of these wells. In the case of an incident, it’s not even clear that both agencies have the information on hand to even locate the site in the field. Meanwhile, a 61% error rate between the sites name, API number, and status does not inspire confidence that agencies are keeping a close eye on these facilities, to say the least.
Above all, we must all realize that it isn’t safe to assume that someone will let us know when these types of facilities are proposed. Regulators have shown us through their actions that they are thinking far more about the billions of gallons of waste that needs to be disposed of than of the well-being of dozens or even hundreds of neighbors near each toxic dump site.
References & Where to Learn More
Data supporting this article, as well as the static map in Figure 3, can be found here.
FracTracker Pennsylvania articles, maps, and imagery: https://www.fractracker.org/map/us/pennsylvania/
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/02/Waste-Disposal-Wells-in-Pennsylvania-feature-scaled.jpg6671500Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2021-02-26 12:23:392021-04-15 14:08:41Pennsylvania’s Waste Disposal Wells – A Tale of Two Datasets
Kyle Ferrar, Western Program Coordinator for FracTracker Alliance, contributed to the December 2020 memo, “Recommendations to CalGEM for Assessing the Economic Value of Social Benefits from a 2,500’ Buffer Zone Between Oil & Gas Extraction Activities and Nearby Communities.”
The purpose of this memo is to recommend guidelines to CalGEM for evaluating the economic value of the social benefits and costs to people and the environment in requiring a 2,500 foot setback for oil and gas drilling (OGD) activities. The 2,500’ setback distance should be considered a minimum required setback. The extensive technical literature, which we reference below, analyzes health benefits to populations when they live much farther away than 2,500’, such as 1km to 5km, but 2,500’ is a minimal setback in much of the literature. Economic analyses of the benefits and costs of setbacks should follow the technical literature and consider setbacks beyond 2,500’ also.
The social benefits and costs derive primarily from reducing the negative impacts of OGD pollution of soil, water, and air on the well-being of nearby communities. The impacts include a long list of health conditions that are known to result from hazardous exposures in the vulnerable populations living nearby. The benefits and costs to the OGD industry of implementing a setback are more limited under the assumption that the proposed setback will not impact total production of oil and gas.
The comment letter submitted by Voices in Solidarity against Oil in Neighborhoods (VISIÓN) on November 30, 2020 lays out an inclusive approach to assessing the health and safety consequences to the communities living near oil and gas extraction activities. This memo addresses how CalGEM might analyze the economic value of the net social benefits from reducing the pollution suffered by nearby communities. In doing so, this memo provides detailed recommendations on one part of the broader holistic evaluation that CalGEM must use in deciding the setback rule.
This memo consists of two parts. The first part documents factors that CalGEM should take into account when evaluating the economic benefits and costs of the forthcoming proposed rule. These include factors like the adverse health impacts of pollution from OGD, the hazards causing them and their sources, and the way they manifest into social and economic costs. It also describes populations that are particularly vulnerable to pollution and its effects as well as geographic factors that impact outcomes.
The second part of this memo documents the direct and indirect economic benefits of the proposed rule. Here, the memo discusses the methods and data that should be leveraged to analyze economic benefits of reducing exposure to OGD pollution through setbacks. This includes the health benefits, impacts on worker productivity, opportunity costs of OGD activity within the proposed setback, and the fact that impacted communities are paying the external costs of OGD.
The fossil fuel industry has historically taken advantage of the nation’s mineral estate for private profit, while outsourcing the public health debts of degraded environmental quality to Frontline Communities. While President Biden has recently ordered the Department of Interior to put a 60-day halt on permitting new oil and gas drilling permits on federal lands, no such policy exists for state lands in California. Governor Newsom’s administration has allowed the California Geological Energy Management Division to issue rework and new drilling permits on California state lands, bringing the total number of operational oil and gas wells on state lands up to a total of 178, almost half of which are “idle.” This number pales in comparison to the number of California oil and gas wells on federal lands; a total of 6,997 operational wells.
FracTracker Alliance has mapped out the operational oil and gas wells located on state lands in California, using the California Protected Areas Database. The areas containing the highest concentrations of oil and gas wells on state lands include two sensitive ecosystem environments. Figure 1 shows the 102 operational oil and gas wells located in Southern California’s Bolsa Chica Ecological Preserve. The wells are part of the Huntington Beach oil field. The preserve shares marine habitat with a marine protected area (MPA) and is habitat for numerous rare and several endangered species. More sensitive habitat also threatened by oil and gas extraction; Figure 2 shows the oil and gas production wells on the Sacramento River Delta, just upriver of the Bay Area. It is habitat for several threatened and endangered species such as the Delta Smelt and Giant Garter Snake.
California needs Governor Newsom to take a stand against the further exploitation of California’s public lands. A ban on permitting new wells on state land and a commitment to plug existing wells would set an example for Biden’s administration to make the current 60-day freeze a permanent policy.
Figure 1. The Bolsa Chica Ecological Preserve hosts over 100 operational oil and gas wells that put the preserve’s ecological habitat at risk.
Figure 2. There are 50 operational oil and gas wells permitted on California state lands in the Sacramento River Delta.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/02/Figure-2.-There-are-50-operational-oil-and-gas-wells-permitted-on-California-state-lands-in-the-Sacramento-River-Delta-feature-scaled.jpg6671500Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2021-02-12 17:42:002021-04-15 14:08:43Oil and Gas Wells on California State Lands
Southwest Detroit and neighboring South Rockwood in Monroe County could not be more different demographically, but one thing they have in common is a consistent battle with the extractives industry.
With environmental advocates Theresa Landrum and Doug Wood, FracTracker created a Story Map to document what this infrastructural buildout in Southeastern Michigan looks like from the air, how it has displaced entire neighborhoods, and how it has forever changed their quality of life, in the name of short-term profiteering.
“Marathon is a prime example of corporate polluters continuing
to choose profit over safeguards for our public health.”
– Congresswoman Rashida Tlaib
Each year, FracTracker Alliance gives out its Community Sentinel Award for Environmental Stewardship. We had an amazing group of candidates this year, and the four winners are extremely brave, persistent, insightful, and collaborative activists representing diverse communities all over the country.
I have had the good fortune to interact with two of the winners – Theresa Landrum and Brenda Jo McManama – quite frequently over my time at FracTracker. This year’s Sentinel Award winners and all its previous recipients are passionate and persistent fighters for environmental justice in their own backyards and around the United States.
It is around this time of year that all the negativity involved in the fight against fossil fuel industries dissolves away for me as I find myself inspired and humbled by the Sentinel winners. Theresa and Brenda Jo constantly inspire me and FracTracker to strive to do more, do better, and remain cleareyed as to whom we serve. All the Community Sentinel nominees are exemplars of what it is to walk authentically and humbly through life.
However, I am going to spend the next couple paragraphs speaking specifically about Ms. Landrum, because it is she that I have come to know and work quite well with since COVID-19 was something we thought would be gone by June.
“Marathon is a prime example of corporate polluters continuing to choose profit over safeguards for our public health. It is time to say enough is enough of Marathon’s constant disregard of the health and safety of residents who live, work, and visit the surrounding communities. Marathon has perpetrated numerous incidents detrimental to our communities and must be held accountable – they clearly cannot be trusted to protect our health. I look forward to discussing the need to hold Marathon and other entities who poison our community accountable and solutions to make our communities breathe and live free at the upcoming congressional field hearing I am hosting with other members of Congress, experts, and grassroots activists here in Detroit.”
Southeastern Michigan Environmental Activists Doug Wood and Theresa Landrum at Detroit’s 48217 Kimeny Park with Marathon’s Refinery in the Background, June, 2020
Anti-Frac Sand mine signage created by Monroe County, Michigan activist Doug Wood, June, 2020
No Dumping signage erected by Marathon Oil in Detroit’s Oakwood Neighborhood adjacent to the company’s oil refinery
Concerned Citizen and Sylvania Minerals mine neighbor Doug Wood
It did not take more than 30 seconds for me to realize that Theresa was an authentic and persistent fighter for her community, and that she belongs on the Mt. Rushmore of EJ advocates – as does Doug Wood and all of the Community Sentinel nominees past, present, and future.
After meeting at the recreation center, I followed Theresa around with my drone, capturing footage and images of the worst actors in the 48217 zip code of Southwest Detroit, as well as of River Rouge and Ecorse. This turned out to be the first of three trips to meet with Theresa throughout the summer and fall of 2020.
During each trip and across dozens of phone conversations, Theresa explained to me what industry has done to Southwest Detroit, how she has gone about combatting it, and the way that Lansing treats Wayne County.
It struck me that much of her experience overlaps with the stories I have heard in disparate demographics, from soybean farmers in LaSalle County, Illinois, to dairy farmers in Western Wisconsin, all the way to coalminers in Central Appalachia.
Their stories illustrate the near universal tale of how industry needs and welfare demands take precedence over the rights of citizens. It is the story of globalization, shareholder returns, and political/economic elites ignoring, mocking, or being deaf and blind to the needs of their constituents and the crimes being committed in the name of progress and Gross Domestic Product (GDP).
One thing Theresa and I have spent quite a bit of time discussing is the overlap in environmental justice across demographics, and how superficial differences have been weaponized to divide us, leaving only corporations and their political handmaids to benefit. Industry beneficiaries and politicians have colluded to declare in the words of Thomas Frank’s latest book “The People, No!” Yet, it is people like Theresa, Doug, Brenda Jo, and all the other environmental activists we celebrate who are and will be instrumental in bridging those divides, and guiding the citizenry to pivot, to identify and defeat the real Leviathan – the Hydrocarbon Industrial Complex in all its manifestations and with all its tentacles spread out across this country.
The best way I know how to return the favor to folks like Theresa is to continue to do what FracTracker does best, and what I hope I am doing well, which is documenting the infrastructure and landscapes that are or have been in the crosshairs of industry, whether it be steel, coal, oil, or in the case of our name – fracked natural gas.
I have been working with Theresa and Doug on a Story Map that illustrates the scale and scope of industrial impacts in southeastern Michigan, from US Steel’s Zug Island to Sylvanian Mineral’s frac sand mine in South Rockwood. As I mentioned above, we have outlined the plight of Doug and Dawn Wood in their fight against their neighbor Sylvanian Minerals. However, with respect to Southwest Detroit, it is critical that we give a bit of background to the region’s cultural significance. For that, I am going to refer to Ms. Landrum’s own words, shared below:
A Historical Perspective of Wayne County Michigan’s Tri-Cities Region
By Theresa Landrum
During the first and second waves of the early 20th Century Great Migration, African Americans came from the South to Michigan’s communities of Ecorse (48229), River Rouge (48218), and Southwest Detroit (48217), AKA the “Triple Cities,” seeking factory jobs in the surrounding industries; U.S. Steel (formerly Great Lakes Steel), Ford Motor Company, Zug Island, Dana Corporation, and BASF Chemicals. During this time, many white men enlisted in the armed forces, and employers needed workers – so companies recruited southern African Americans to fill the jobs.
This region is one of the first African American settlements in Michigan after World War II, where Black people could actually buy homes, which helped establish metro Detroit’s Black middle class.
By the 1930s and 40s it was a self-sustaining area rich with opportunities, a mecca for Black-owned businesses, like gas stations, stores, jazz clubs, restaurants, hotels, laundromats, dry cleaners, and much more. It was also the home of Black professionals: doctors, pharmacists, policemen, florists, bakers, dentists, teachers, lawyers, and realtors thrived here, and was the site of one of Michigan’s first Black hospitals, Sidney A. Sumby Memorial Hospital, built by Black doctors.
The thread that ties these three communities/zip codes together is their formation of (what was then) Ecorse Township. Their division came after the City of Detroit expressed interest in annexing the River Rouge area. River Rouge incorporated into a village to ward this off, but Detroit was able to annex the Southwest 48217 area in 1922, thus segmenting Ecorse Township into three parts.
Fast forward to the 1950s, when Detroit’s landscape changed forever with the government’s declaration of “Eminent Domain” that claimed many African American homes for construction of the I-75 Expressway, which runs right through the center of Southwest Detroit’s (SWD) 48217 community. As I-75 was constructed, Ohio Oil (which officially became Marathon Oil in 1962) also increased its footprint in the area by acquiring nearly 100 acres and destroying a wetland habitat to expand its storage tank farm, which to date has over 100 storage tanks.
Marathon expanded again in 2007 with the announcement of the $2.2 billion Detroit Heavy Upgrade Project (DHOUP), where they would transition to refining dirty tar-sands from Alberta, Canada. This increased production to 120,000 barrels of crude per day, and thus increased the expulsion of harmful, pollutive emissions into the nearby neighborhoods. The project was completed in 2012, which also resulted in Marathon buying over 400 homes in the SWD 48217 (Oakwood Heights) area, further encroaching into residential communities.
Theresa was a recipient of the 2020 Community Sentinel Award for Environmental Stewardship, presented by FracTracker Alliance and Halt the Harm Network. Read more about her story here.
The Thoughts of Dawn & Doug Wood About Living Next to a Frac Sand Mine
I asked Dawn and Doug Wood to send me their thoughts on what it is like living next to Sylvanian Minerals and US Silica’s frac sand mine in South Rockwood, Michigan. I extracted (and clarified where necessary) the excerpts below that clearly illustrate their frustrations with their community, local, and federally elected officials, as well as the mine operators:
“[The] list of insurmountable mini-nightmares of living next to a frac sand mine [is endless at this point]. [Ten] years ago, they wanted to annex this quarry. [Our] village government has exercised no control over this corporation. [T]he village and the quarry refuse to do any air monitoring, [and] the residents who voted [in favor of] this quarry continue to be silent against any controls over this quarry. Residents seem to fear retaliation if they speak out against [the] village/quarry, [and to this day we] can’t quite explain the community’s lack of outrage … [We] have been shaking our head for years about this … It’s like the pandemic, it is invisible, yet it is killing people … [and] we are living in a polluted community, so our lungs are already taxed [which amplified the impacts of COVID]. [We] have been petitioning for air monitors and dust controls for four years, [and to add insult to injury] after ten years of this bull- – – -, the industry proposes Senate Bill 431 to totally strip communities of their controls, allowing mines to expand whenever they want, and new quarries to just be approved wherever they want [which has prompted the industry to correctly assume] they are entitled. PURE MICHIGAN is the state slogan. We think that’s PURE BULL- – – -!!”
A Southwestern Detroit and Neighboring Monroe County Industrial Impacts Story Map
Southwest Detroit and neighboring South Rockwood in Monroe County could not be more different demographically, but one thing they have in common is a consistent battle with the extractives industry.
We built this Story Map to identify the industrial bad actors and census-level indicators such as mean annual income, and most importantly, to present a growing library of georeferenced drone footage and imagery we have collected over the years.
There have been dozens of other industrial projects foisted on the Triple Cities area of Detroit during this period and to the present day. The goal of this Story Map was to document with drone photography what this infrastructural buildout looks like from the air, how it has displaced and been incorporated directly into neighborhoods – and in the case of Sylvanian Mineral’s South Rockwood facility operating adjacent to good people like the Woods – how it has forever changed their quality of life, in the name of short-term profiteering.
We will continue to “infill” and expand this Story Map in the coming months and years, especially throughout greater Wayne County and the surrounding counties, as southeastern Michigan continues to act as a chokepoint for all manner of industrial and fossil fuel operators and activities. Furthermore, this collaborative effort with Ms. Landrum demands her community’s involvement and acceptance. We also strive to make this project a valuable resource for Michigan-based environmental NGOs and the state’s excellent journalists, like Steve Neavling at Detroit MetroTimes, and Evan Kutz at Great Lakes Beacon.
We plan to update this Map with more culturally significant imagery from the Detroit Public Library and The Wayne State Walter Reuther Library to include media focusing on labor strife, police violence, and the rich tradition and history of the region’s artistic heritage. Additionally, we will expand the depth and breadth of our drone imagery library, as well as continue our nascent effort to collect the stories of regional elders who speak to Southwest Detroit as one of the fulcrums of African American culture, and who explore how industrial colonialism has decimated much the area’s sense of place and community pride.
However, I am confident and hopeful that with progressive voices like Congresswoman Tlaib, committed journalists like those previously mentioned, and activists like Ms. Landrum passing the torch to a younger generation of activists, Southwest Detroit’s condition will take a turn for the better.
Footnote on Michigan’s Senate Bill 431
We wrote about the impacts that SB 431 would have on Michigan’s community and ecosystems last summer, when we were outlining some of the industry’s efforts in Statehouses across the country to weaken environmental regulations – and in some cases, the democratic process itself. SB 431, in particular, would have made the process of operating a sand and gravel mine in Michigan much easier, by way of removing local participation. As the Metamora Land Preservation Alliance (MLPA) wrote in opposition to the bill, this legislation would have allowed for “uncontrolled gravel mining” throughout the state. However, in a bit of good news, a large coalition of Michigan environmental organizations was able to defeat this bill with the MLPA, writing the following on its Facebook page:
“KILLER GRAVEL BILLS DEFEATED!!!
SENATE BILLS 431/849 DEFEATED!
NO SENATE VOTE THIS YEAR – BILLS ARE DEAD!
After almost 18 months of battling in Lansing – Senate Bills 431 & 849 (sponsored by Senator Hollier (D) Detroit) – have been defeated. They will not be coming up for a vote this calendar year, and by Senate rules they will therefore expire. Thus ending, for this year, the dire threat of uncontrolled gravel mining, endangerment of our groundwater, and loss of control of how our communities grow and develop. Make no mistake – this was a serious threat to Michigan’s citizens and communities – and it was a no-holds-barred fight in Lansing.”
Wins for communities over corporations like this are rare, indeed, and should be celebrated. Congratulations to the Woods, MLPA, and all the Michigan communities and organizations that pushed back against this bill. You are true Community Sentinels!
Theresa Landrum, of Detroit, Michigan, 48217. The Original United Citizens of Southwest Detroit; 48217 Community and Environmental Health Organization; Michigan Advisory Council on Environmental Justice; Sierra Club Detroit Chapter, MEJC Clean Air Council; Michigan PFAS action response team
This report focuses on the two immediate stakeholders impacted by oil and gas well drilling setbacks: Frontline Communities and oil and gas operators. First, using U.S. Census data this report helps to define the Frontline Communities most impacted by oil and gas extraction. Then, using GIS techniques and California state data, this report estimates the potential impact of a setback on California’s oil production. Results and conclusions of these analyses are outlined below.
Previous statewide and regional analyses on proximity of oil and gas extraction to various demographics, including analyses included in Kern County’s 2020 draft EIR, have inadequately investigated disparate impacts, and have published erroneous results.
This analysis shows that approximately 2.17 million Californians live within 2,500’ of an operational oil and gas well, and about 7.37 million Californians live within 1 mile.
California’s Frontline Communities living closest to oil and gas extraction sites with high densities of wells are predominantly low income households with non-white and Latinx demographics.
The majority of oil and gas wells are located in environmental justice communities most impacted by contaminated groundwater and air quality degradation resulting from oil and gas extraction, with high risks of low-birth weight pregnancy outcomes.
Adequate Setbacks for permitting new oil and gas wells will reduce health risks for Frontline Communities.
Setbacks for permitting new oil and gas wells will not decrease existing California oil and gas production.
Phasing out wells within setback distances will further decrease health risks for Frontline Communities.
Phasing out wells by disallowing rework permits within a 2,500’ setback distance will have a minimal impact on overall statewide oil production, estimated at an annual maximum loss of 1% by volume.
Setbacks greater than 2,500’ in combination with other public health interventions are necessary to reduce risk for Frontline Communities.
Based on the peer reviewed literature, a setback of at least one mile is recommended.
The energy focused on instituting policies to protect the health of Frontline Communities in California from the negative impacts of oil and gas extraction is at an all-time high. In August 2020, Assembly Bill 345 was heard in the State Senate’s Natural Resources Committee, but was blocked from reaching the Senate floor for a vote. The bill would have required the Geologic Energy Management Division in the Department of Conservation (CalGEM) to establish a minimum setback distance between oil and gas production and related activities and sensitive receptors like homes, schools, and hospitals. While this strong effort to establish health and safety setbacks through the state legislature may have failed, the movement has paved the way for local actions. Additionally, California is in the midst of a statewide public health rule-making process to address the health impacts of oil and gas extraction currently experienced by Frontline Communities.
In related advocacy, Frontline Community groups in California recommended a minimum 2500’ setback based on scientific studies, including a 2015 report by the California Council on Science and Technology which identified “significant” health risks at a distance of one-half mile from drill sites. A recent grand jury report from Pennsylvania recommended 5,000’ setbacks, with 2,500’ as a minimum requirement to address the most impacted communities. Additionally, the state of Colorado has recently adopted 2,000’ setbacks for homes and schools, while the existing 2,000’ setback has had minimal impacts on oil and gas production.
In September 2020, Governor Newsom declared the deadline for the first draft of the pre-regulatory rule-making report will be the first of January 2021. FracTracker Alliance has therefore completed an updated assessment of the Frontline Communities most impacted by oil and has projected the potential impact on oil and gas extraction operations. An interactive map of oil and gas activity and Frontline Communities is shown below in Figure 1. The map identifies the operational (active, idle, and new) oil and gas wells located within 2,500’ and 1 mile buffer zones from sensitive receptors, defined as homes, schools, licensed daycares and healthcare facilities.
The impacts of oil and gas drilling do not stop at 2,500’, as regional groundwater contamination and air quality degradation of ozone creation and PM2.5 concentrations are widespread hazards of oil and gas extraction. Phasing out wells within 2,500’ of homes will reduce the negative health effects for the Frontline Communities bearing the brunt of the risks associated with living near oil and gas wells, as well as reduce regional environmental hazards. These risks include over 24 categories of health impacts and symptoms associated with 14 bodily systems, including eyes, ears, nose, and throat; mental health; reproduction and pregnancy; endocrine; respiratory; cardiovascular and pulmonary; blood and immune system; kidneys and urinary system; general health; sexual health; and physical health among others. The most regularly documented health outcomes include mortality, asthma and respiratory outcomes, cancer risk including hematological (blood) cancer, preterm birth, low birth weight and other negative birth outcomes.
The interactive map below in Figure 1 shows the operational oil and gas wells located within 2,500’ of sensitive receptors, including homes, schools, healthcare facilities, prisons, and permitted daycares. Overall in the state of California, 16,724 operational (8,618 active, 7,786 idle, and 320 new) wells are located within the 2,500’ setback. Of the total ~105,000 operational (62,000 active, 37,400 idle, and 6,000 new), about 16% are within the setback. These wells accounted for 12.8% of the total oil/condensate produced in California in 2019. Table 1 below shows the counties where these wells are located, by well permit status. It bears noting that these figures on well location and production represent only a snapshot of current industry activity. As discussed below, current setback proposals would provide a phase out period for existing wells that would greatly reduce any immediate impact on production. Further, directional and even horizontal drilling is common in California, meaning operators can relocate their surface drilling equipment to safer distances and still access oil and gas reserves to maintain production.
Table 1. Status of wells within the 2,500’ setback zone, by county. The table shows the counts of wells located within the 2,500’ setback from homes and other sensitive receptors, broken out by the status of the wells.
Figure 1. Map of California operational oil and gas wells with 2,500’ and one mile setback distances. One mile setbacks are included as a minimum recommendation of this report based on peer reviewed literature. This report recommends the state of California consider one mile as a minimum setback distance to protect Frontline Communities. As you zoom into the map additional, more detailed layers will appear.
Methods (Quick Overview)
In this article we conducted spatial analyses using both the demographics of Frontline Communities and the amount of oil produced from wells near Frontline Communities. This assessment used CalGEM data (updated 10/1/20) to map the locations of operational oil and gas wells and permits, as shown above in Figure 1. The analyses of oil production data utilized CalGEM’s annual production data reporting barrels of oil/condensate. GIS analyses were completed using ESRI ArcGIs Pro Ver. 2.6.1 with data projected in NAD83 California Teale Albers.
We used block group level “census designated areas” from American Community Survey (2013-2018) demographics to estimate counts of Californians living near oil and gas extraction activity. Census block groups were clipped using the buffered datasets of operational oil and gas wells. A uniform population distribution within the census blocks was assumed in order to determine the population counts of block groups within 2,500’ of an operational oil and gas well, 2,500’ to 1 mile from an operational well, and beyond 1 mile from an operational well. Census demographics and total population counts were scaled using the proportion of the clipped block groups within the setback area (Areal percentage = Area of block group within [2,500’; 2,500’-1 mile; Beyond 1 mile] of an operational well / Total area of block group).
This conservative approach provided a general overview of the count and demographics of Californians living near extraction operations, but does little to shed light on most impacted Frontline Communities; specifically urban areas with dense populations near large oil fields. More granular analyses at the local level were necessary to address the spatial bias resulting from non-uniform census block group dimensions and population density distributions, as well as the distribution of operational oil and gas wells within the census block groups. Consequently, we conducted further analysis utilizing customized sample areas for each oil field, which were selected manually using remote sensing data. Full census blocks were used to summarize the actual areas and the urban populations constituting the majority of Frontline Communities.
In the localized, static maps that follow, the census blocks included in the population summaries are shown in pink, while the surrounding census blocks are shown in blue. As seen in Table 2, census data for this initial environmental justice assessment was limited to “Race” (Census Table XO2), “Hispanic or Latino Origin” (Census Table XO3) and several other indicators including “Annual Median Income of Households” (Census Table X19) and “Poverty” (Census Table X17).
Results and Discussion
California Statewide Analysis
As a baseline, it is important to provide statewide estimations to track the total number of Californians living near oil and gas extraction operations. This analysis showed that about 2.17 million Californians live within 2,500’ of an operational oil and gas well, and about 7.37 million Californians live within 1 mile. The demographics of these communities at and between these distances is shown below in Table 2, alongside demographic estimates of the California population living beyond 1 mile from an oil and gas well. Census block groups closer to oil and gas wells have higher proportions of Non-white (calculated by subtracting “White Only” from “Total Population”) and Latinx (“Hispanic or Latino Origin”) populations, as well as higher proportions of low-income households, based on both median annual income and poverty thresholds. The analysis show that communities living closer to oil and gas wells have higher percentages of non-white and Latinx populations when compared to the population living beyond 1 mile from an operational oil and gas wells. Communities closer to oil and gas wells are also more likely to be closer to the poverty threshold with lower median annual household incomes.
Table 2. The table shows statewide demographics at multiple distances from operational oil and gas wells. Included are estimates of the non-white and Latinx proportions of the populations within set distances from operational oil and gas wells. The percentage of populations within several poverty thresholds were also summarized, along with median annual household income and age.
CalEnviroScreen data, like U.S. Census data, is also aggregated at the census block group level. While this data can also suffer from the same spatial bias as the statewide analysis above, CES is still very useful to visualize and map the regional pollution burden to assess disparate impacts. The results of the analysis are shown below in Table 3. Counts of operational oil and gas wells for ranges of CES percentile scores. Higher percentiles represent increased environmental degradation or negative health impacts as specified. Of note, the majority of operational oil and gas wells are located in census tracts with the worst scores for air quality degradation and high incidence of low birth weight.
The large number of wells located in the 60-80th percentile rather than the worst (80-100th percentile) is a result of spatial bias, and the many factors that are aggregated to generate the CES Total Scores. These factors include relative affluence and other indicators of socio-economic status. The majority of the worst (80th-100 percentile for Total CES Score) census block groups are located in low-income urban census block groups, many in Northern California cities that do not host urban drilling operations.
This spatial bias results from edge effects of census block groups, where communities living near oil and gas extraction operations may not live in the same census block groups as the oil and gas wells, and are therefore not counted. The authors would recommend future analyses be designed that use CES data to assess disparate impacts in the census block groups most impacted by oil and gas extraction. Neighboring census block groups that do not physically contain operational wells still suffer the consequences of proximity.
For the asthma rankings, the majority of wells are located in the best CES 3.0 percentile (0-20th percentile) for Asthma. While there is much urban drilling in Los Angeles, the spatial bias in this type of analysis gives more weight to the majority of oil and gas wells that are located in rural areas, which historically have much lower asthma rates. This is a result of the very high incidence of asthma in cities without urban drilling such as the Bay Area and Sacramento (80-100th percentile).
Table 3. Counts of operational oil and gas wells in select CalEnviroScreen 3.0 indicators census tracts.
Operational Well Counts by CES3.0 Percentile
PM2.5 Air Quality Degradation
Ozone Air Quality Degradation
Contaminated Drinking Water
High Incidence of Low Birth Weight
High Incidence of Asthma
Total CES 3.0
Using census data to assess the demographics of those communities most affected by oil and gas drilling can produce misleading results both because of how census designated areas (census tracts and block groups) are designed and because of the uneven distribution of residents within tracts. For example, the majority of Californians who live closest to high concentrations of oil and gas extraction, such as the Kern River oil field, do so in residentially zoned cities and urban settings. In most Frontline Communities the urban census designated areas do not actually contain many wellsites. Instead urban census designated areas are located next to the “estate” and “industrial” (including petroleum extraction) zoned census designated areas that contain the well-sites.
Estate and industrially zoned census designated areas contain the majority of well-sites in Kern County. They are much larger than residentially zoned areas with very low population densities and higher indicators of socioeconomic status. Population centers within the estate zoned areas are often located on the opposite end and farther from well sites than the lower income communities and communities of color living in the neighboring, residentially-zoned census designated areas (e.g., Lost Hills and Shafter). In these cases the statewide demographic summaries above misrepresent the Frontline Communities who are truly closest to extraction operations. Localized environmental justice demographics assessments can also be manipulated in this way.
For instance, The 2020 Kern County draft EIR (chapter 7 PDF pp. 1292-1305) used well counts aggregated by census tracts to conclude that wells in Kern County were not located in disparately impacted communities. Among other requirements for scientific integrity, the draft Kern EIR fails to take into account how the shape, size, and orientation of census designated areas affect the results of an environmental justice assessment. In addition, the EIR uses low-resolution data summarized at the census tract level. Census tracts are much too large to be used to investigate localized health impacts or disparities. Using these blatantly inadequate methods, the draft EIR even claimed Kern County’s oil and gas wells are predominantly located in higher income, white communities, which is outright wrong. For more specific criticisms of the Draft EIR read the FracTracker analysis of the 2020 Kern County EIR.
Results from these types of analyses can be very misleading. Using generalized methods of attributing wells to specific census designated areas does little to identify the communities most impacted by the localized environmental degradation resulting from oil and gas extraction operations, particularly when large census areas such as census tracts are used.
This report therefore takes a different approach, focusing directly on California’s most heavily drilled communities. To understand who and which communities are most harmed by the large-scale industrial oil and gas extraction operations in California, spatial analyses must be refined to focus individually on the communities closest to the highest density extraction operations. For the analyses below, census block groups within 2,500’ of ten different Frontline Communities, all located near some of California’s largest oil and gas fields, were manually identified. The selected block groups’ major population centers were all located within the 2,500’ buffers. Unlike the statewide analysis above, the localized analyses below do not assume homogenous population distributions. Using these methods, FracTracker has identified and demographically described some of the most vulnerable California communities most at risk to the impacts of oil and gas extraction. In the maps below, the “case” census block groups used to generate descriptive demographic summaries of at risk communities bordering extraction operations are outlined in pink, while surrounding census block groups are outlined in light blue.
The analyses above are important to understand some of the public health risks of living near oil and gas drilling in California. Yet the methods above used statewide aggregation of well counts and static buffers that do not not show the spectrum of risk resulting from well density. Numerous Frontline Communities in California are within 1 mile or even 2,500’ of literally thousands of oil and gas wells. Conversely, there are many census areas in California that have been included within the spatial analysis of the full state, as described above, located near a single low producing well. Therefore the above methods conservatively summarize demographics and dilute the signal of disparate impacts for low income communities of color. Those methods are not able to differentiate between such scenarios as living near one low-producing well in the Beverly Hills golf course versus living in the middle of the Wilmington Oil Field.
As with any toxin, the dosage determines the intensity of the poison. In environmental sciences, increasing exposure to toxins by increasing the number of sources of a toxin can increase the dosage and therefore the severity of the health impact. The impact of well density has been documented in numerous epidemiological studies as a significant indicator of negative health outcomes, including recently published reports from Stanford University and The University of California – Berkeley linking adverse birth outcomes with living near oil and gas wells in California (Tran et. al 2020, Gonzalez et. al 2020). Therefore the rest of this report focuses on the Frontline Communities living near large oil extraction operations–i.e., oil fields with high densities of operational oil and gas wells.
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The City of Shafter, California, is located near more than 100 operational wells in the North Shafter oil field, as shown below in the map in Figure 2. Technically, the wells are located within a donut-shaped census block group (outlined in blue) that surrounds the limits of the urban census block groups (outlined in pink). Shafter’s population of nearly 20,000 is over 86% Latinx, but the surrounding “donut” with just 2,000 people is about 70% Latinx, much wealthier, and with very low population density. The other neighboring rural census areas housing the rest of the Shafter oil field wells follow this same trend.
An uninformed analysis, such as the Kern County EIR, would conclude that the 2,000 individuals who live within the blue “donut” are at the highest risk, because they share the same census designated area as the wells. Notably, the only population center of this census block group (or census tracts, which follow this same trend) is at the opposite end of the block group, farthest from the Shafter oil field. Instead, the most at-risk community is the urban community of Shafter with high population density; the census block groups within the pink hole of the donut contain the communities and homes nearest the North Shafter field.
Figure 2. The City of Shafter, California is located just to the south of the North Shafter oil field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Lost Hills, Arvin, & Taft
The cities of Lost Hills, Arvin, and Taft are all very similar to Shafter. The cities have densely populated urban centers located within or directly next to an oil field. In the maps below in Figures 3 readers can see the community of Lost Hills next to the Lost Hills oil field. Lost Hills, like the densely populated cities of Arvin and Taft, are located very close to large scale extraction operations. Census block groups that include the most impacted area of Lost Hills is outlined in pink, while surrounding low population density census block groups are shown in blue. The majority of the areas outlined in blue are zoned as “estate” and “agriculture” areas. The outlines of the city boundaries are also shown, along with 2,500’ and 1 mile setback distances from currently operational oil and gas wells.
Lost Hills is another situation where a donut-shaped census area distorts the results of low resolution demographics assessments, such as the one conducted by Kern County in their 2020 Draft EIR (PDF pp. 1292-1305). Almost all of the wells within the Lost Hills oil fields are just outside of a 2,500’ setback, but the incredibly high density of extraction operations results in the combined impact of the sum of these wells on degraded air quality. While stringent setback distances from oil and gas wells are a necessary component of environmental justice, a 2,500’ setback on its own is not enough to reduce exposures and risk for the Frontline Community of Lost Hills. For these Frontline Communities, a setback needs to be much larger to reduce exposures. In fact, limiting a public health intervention to a setback requirement alone is not sufficient to address the environmental health inequities in Lost Hills, Shafter, and other similar communities.
Lost Hill’s nearly 2,000 residents are over 99% Latinx, and over 70% of the households make less than $40,000 in annual income (which is substantially less than the annual median income of Kern County households [at $52,479]). The map in Figure 3 shows that the Lost Hills public elementary school is located within 2,500’ of the Lost Hills oil field and within two miles of more than 2,600 operational wells, in addition to the 6,000 operational wells in the rest of the field.
The City of Arvin has 8 operational oil and gas wells within the city limits, and another 71 operational wells within 2 miles. Arvin, with nearly 22,000 people, is over 90% Latinx, and over 60% of the households make less than $40,000 in annual income.
Additionally the City of Taft, located directly between the Buena Vista and Midway Sunset Fields, has a demographic profile with a Latinx population at least 10% higher than the rest of southern Kern County.
Lost Hills, Arvin, and Taft are among the most impacted densely populated areas of Kern County and represent the most Kern citizens at risk of exposure to air quality degradation from oil and gas extraction.
In all of these cases, if only census tract well counts are considered, like in the 2020 Kern County draft EIR, these Frontline Communities will be completely disregarded. Census tracts are intentionally drawn to separate urban/residential areas from industrial/estate/agricultural areas. The census areas that contain the oil fields are very large and sparsely populated, while neighboring census areas with dense population centers, such as these small cities, are most impacted by the oil and gas fields.
Figure 3. The Unincorporated City of Lost Hills in Kern County, California is located within 2,500’ of the Lost Hills Oil Field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
The City of Bakersfield is a unique scenario. It is the largest city in Kern County and as a result suburban developments surround parts of the city. Urban flight has moved much of the wealth into these suburbs. The suburban sprawl has occurred in directions including North toward the Kern River oil field, predominantly on the field’s western flank in Oildale and Seguro. In the map below in Figure 4, these areas are located just to the north of the Kern River.
This is a poignant example of the development of cheap land for housing developments in an area where oil and gas operations already existed; an issue that needs to be considered in the development of setbacks and public health interventions and policies. This small population of predominantly white, middle class neighborhoods shares similar risks as the lower-income Communities of Color who account for the majority of Bakersfield’s urban center. Even though these suburban communities are less vulnerable to the oppressive forces of systemic racism, real estate markets will continue to prioritize cheap land for development, moving communities closer to extraction operations.
Regardless of the implications of urban sprawl and suburban development, it is important to no disregard the risks to the demographics of the at-risk areas of the city of Bakersfield are predominantly Non-white (31%) and Latinx (60%), particularly as compared to the city’s suburbs (15% Non-white and 26% Latinx). About 33,000 people live in the city’s northern suburbs, and another 470,000 live in Bakersfield’s urban city center just to the south of the 16,500 operational wells in the Kern River, Front, and Bluff oil fields. The urban population of Bakersfield is a large Frontline Community exposed to the local and regional negative air quality impacts of the Kern River and numerous other surrounding oil fields.
Figure 4. Map of the city of Bakersfield in Kern County, California located between several major oil fields including the Kern Front oil field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
The City of Ventura and the proximity of the Ventura oil field is a similar situation to cities in Kern. The urban center of Ventura is bisected by the Ventura oil field’s nearly 1,200 operational wells. While over 70% of the city’s population is Latinx, the very sparsely populated census areas also containing portions of the oil field are 34% Latinx.
In the map below in Figure 5, take note of the population distribution within the portion of the city closest to the oil field versus the census areas to the east. While a statewide or less granular analysis would assume an evenly distributed population density, in this localized analysis, it is clear that the most vulnerable Frontline Communities are the urban centers closest to the oil fields. Even though the census blocks to the east contain oil and gas wells, the populations are less at risk because the population centers are located farther from the oil field.
Figure 5. Ventura Oil Field in Ventura, California census areas within the 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
In Los Angeles County, Inglewood, Wilmington, Long Beach, and Los Angeles City are some of the largest oil and gas fields. There are many areas in Los Angeles where a single low-producing well is located in an upper middle class suburb, on a golf course, or next to the Beverly Hills High School.
While all well sites present sources of exposure to volatile organic compounds (VOCs) and other air toxics, these four oil fields have incredibly high densities of oil and gas wells in urban neighborhoods. The demographics of the Frontline Communities located within 2,500’ of these major fields are presented below in Table 4. These areas are additionally lower income communities; for example, over 50% of annual household incomes in the census areas surrounding the Los Angeles City oil field are below $40,000, while the Los Angeles County median annual income is over $62,000.
Table 4. Demographics for Frontline Communities living within 2,500’ of Los Angeles’s major oil and gas fields along with counts of operational wells in the fields are shown in the table. The demographic “Latinx” is the count of “Hispanic or Latino Origin” population, and “non-white” was calculated by subtracting “white only” from “total population.”
Los Angeles City
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Figure 6. Inglewood Oil Field Frontline Community, Inglewood, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Figure 7. Wilmington Oil Field Frontline Community, Wilmington, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Figure 8. Long Beach Oil Field Frontline Community, Long Beach, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Los Angeles City
Figure 9. Los Angeles City Oil Field Frontline Community census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
The creation of public health policies such as 2,500’ setbacks to help protect Frontline Communities is controversial in California as many state legislators are still beholden to the oil and gas industry. The industry itself pushes back strongly against any proposal that could affect their bottom line, no matter how insignificant the financial impact may be. When AB345 was proposed, the industry’s lobbying organization Western States Petroleum Association claimed that institution of 2500’ setbacks would immediately shut down at least 30% of California’s total oil production. This number is an outright fabrication.
As shown in Table 1 above, a 2,500’ setback would impact the less than 9,000 active and new wells; 42% in Kern County and 29% in Los Angeles County. Ventura and Orange Counties are a distant 3rd and 4th, respectively. These counts are further broken down by field in Table 5 below. Statewide these wells accounted for just 12.8% of California’s current oil production by volume (as reported in barrels of oil/condensate by CalGEM), which is much smaller than the wholly unsubstantiated 30% decline claimed by industry.
Table 5. Counts of wells by well status for operational (active, idle, and new) oil and gas wells located within a 2,500’ setback. Fields include the count of wells within the 2,500’ setback and the amount of oil produced from those wells within the setback. The percentage of total oil from that field is also included.
Well Ct % of Total
2019 Oil Prod (BBLS)
Oil Prod % of Total
Santa Fe Springs
In the case that setback regulations are crafted both to prohibit new drilling and to phase out existing operations within the setback distance, the industry would have the opportunity to respond with measures that preserve the majority of production volumes, particularly in the Central Valley. For example, in Kern County, the overwhelming majority of new wells drilled in 2020 are directional or horizontal; these drilling technologies would allow operators to access the same below ground resources from surface locations that are further away from and safer for communities. Further, for existing wells within the 2,500’ setback, current proposals would institute a phase out period. Existing wells could be allowed to continue to operate under the terms of their current permits but not allowed to expand or rework their operations to increase or extend production; alternatively (or in addition), well operators could continue for a prescribed timeframe formulated to allow them to recoup their investment (called “amortization”).
It is clear that the oil fields of Los Angeles would be the most impacted if setbacks phased out the wells responsible for the highest risk to Frontline Communities. The majority of Los Angeles’s urban oil fields are located entirely within 2,500’ of homes, schools, healthcare facilities and daycares.
As shown above in Table 5, wells within the setback produce 96% of the oil in the Inglewood fields, 84% in the Long Beach field, and 100% of the oil in several other smaller fields. With the phase out of these wells, oil extraction would cease in these fields. Most of these fields produce very low volumes of oil and already have high counts of idle wells, 28% idle in Wilmington, 25% in Inglewood, and 56% in Long Beach for example. The sole outlier of this trend is the Wilmington field. The majority of production in the Wilmington field comes from wells located in the Long Beach harbor, enough of them located outside of the 2,500’ setback such that while 83% of the Wilmington field wells are within the 2,500’ setback, these wells account for only 22% of the field’s overall production.
The situation in Kern County is quite the opposite of Los Angeles, where the majority of operational wells are located within 2,500’ of homes, residences, and other sensitive receptors like healthcare facilities. In Kern, the overwhelming majority of wells are located beyond 2,500’ and even 1 mile from sensitive receptors. While the Midway-Sunset and Kern River fields have the most wells within the 2,500’ setback area, those wells make up a small percentage of the total operational wells in the fields. As can be seen in the map in Figure 1, wells within the 2,500’ setback zone in the large Kern oil fields are entirely located on the borders of the fields. Overall, a 2,500’ setback in Kern County would only affect 7.1% of active/new wells, accounting for 5.97% of the county’s production.
The oil and gas industry and operators in states including Texas, Colorado, North Dakota, Pennsylvania, Ohio, West Virginia, New Mexico, and Oklahoma are very vocal of their ability to avoid surface disturbance and target oil and gas pools located under sensitive receptors (homes, schools, healthcare facilities, endangered species habitat etc.) using directional drilling. According to the industry, directional drilling has been used for nearly a century to extract resources from areas where surface disruption would impact sensitive communities and habitats.
The same is true for California, especially in Kern County and especially recently. An October 2020 draft environmental impact report by the Kern County Planning and Natural Resource Department disclosed that in a dataset of 9,803 wells drilled from 2000 to 2020 by the California Resources Corporation, the majority of wells were drilled directionally (46%) or horizontally (10%), as opposed to vertically. More recent wells in the County have utilized directional and horizontal drilling even more heavily: a 2020 dataset of wells drilled county-wide indicates that 76% were drilled directionally and an additional 7% were drilled horizontally; only 17% were drilled vertically. These statistics indicate that, even if all wells neighboring Frontline Communities in Kern County were to be phased out (itself a small percentage of the total number of wells in the county), there would only be a small impact on Kern County oil production owing to the prevalence of non-vertical techniques that allow operators the flexibility to access reserves from different surface locations. As noted previously, if all oil production from within the 2,500’ setback zone were to be immediately eliminated statewide, it would mean a maximum decrease of just 12.8% of California’s current annual oil production. But the availability of directional and horizontal drilling in Kern County, where the lion’s share of all drilling statewide occurs, means it is more likely that the decrease in production will be significantly less than 12.8% and likely much less than 10%.
Existing Well Phase Out
Any assertion that a 2,500’ setback would immediately affect oil production is baseless because current setback proposals would institute a phase out period for existing wells. For example, existing permitted wells could be allowed to continue to operate under the terms of their current permits but not allowed to expand or rework their operations to increase or extend production. Alternatively, under a policy approach known as amortization, well operators could continue for a prescribed timeframe formulated to allow them to recoup their investment.
If wells within the setback distance are phased out pursuant to a “no rework” policy, operators would be afforded some time to maximize production in order to ensure that operators receive a sufficient return on their investment under the terms of their existing permits before they shut down. Under such an approach, older wells with increasing risks of fugitive emissions through leaks at the surface and well casing failures could be sequentially phased out by placing a ban on rework permits not required for maintenance or safety. CalGEM permitted well reworks, including sidetracks and deeper drills, increase production and the lifespan of wells. The catalog of rework permits can be found on the CalGEM website.
Based on CalGEM’s production data from 2018 and 2019, a phase out effectuated by disallowing well reworks would result in an annual reduction of less than 1% of total oil production. Of the 52,997 wells reporting oil/condensate production volumes in 2018, 338 received a rework permit in the same year. In 2019, of the 48,860 wells reporting oil production volumes, 285 received rework permits. By volume, the wells that received rework permits accounted for 0.87% of oil production in 2018 and just 0.04% in 2019.
The oil and gas industry in California has consistently pushed back against Frontline Communities who demand public health protections against emissions from oil and gas operations. This occurs even when there will be little to no impact reducing production. It is an industry policy to refuse any concessions and oppose all measures, even to protect public health, by leveraging the industry’s wealth at every level of the political hierarchy.
Fatefully, 2020 has resulted in multiple wins for public health in California. While the failure of AB345 made it clear that the California state legislature is still beholden to the fossil fuel industry, the momentum has continued. Community grassroots groups in Ventura County successfully passed a 1,500’ setback ordinance for occupied dwellings and 2,500’ setbacks for sensitive receptor sites including healthcare facilities and schools. Just south of Ventura, the County of Los Angeles is also in the midst of a rule-making process that is considering multiple setbacks, including 1,000’ to 2,500’ distances. And a committee of the Los Angeles City Council just voted to develop a proposal that would phase out oil drilling across the city as a non-conforming use.
While Ventura and Los Angeles are making progress, Kern County is creating a new process to streamline oil and gas well permitting and has even proposed to decrease the existing zone-specific 300’ setbacks from homes to 210’.
Kern County Frontline Communities and the rest of California also deserve the same consideration as residents of Ventura and Los Angeles Counties. The research is clear that a setback of at least one mile in addition to more site specific public health interventions are necessary to reduce the negative health impacts resulting from these industrial operations within and neighboring Frontline Communities.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/12/CASetbacksMappic.jpg6141500Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2020-12-17 13:45:242021-04-15 14:16:02People and Production: Reducing Risk in California Extraction
Working with the environmental nonprofit Earthworks, FracTracker Alliance filmed emissions from oil and gas sites that have been issued permits in California under Governor Gavin Newsom since the beginning of 2019. Using state-of-the-art technology called optical gas imaging (OGI), we documented otherwise invisible toxic pollutants and greenhouse gas emissions (GHGs) being released from oil and gas wells and other infrastructure. This powerful technology provides further evidence of the negative consequences that come from each issued permit. Every single permit approval enabled by decisions made under Newsom can have substantial, visible impacts on local and regional air quality, contributes to climate change, and potentially exposes communities to health-harming pollution.
Despite a stated commitment to transition rapidly off fossil fuels, California has issued 7,625 permits to drill new oil and gas wells and rework existing wells since the beginning of 2019 — that is, on Governor Gavin Newsom’s watch. This expansion of the industry has clear implications for climate change and public health, as this article will demonstrate.
In collaboration with Consumer Watchdog, FracTracker Alliance has been periodically reporting on the number and locations of oil and gas wells permitted by Governor Newsom in California. In July of 2019, we showed how the rate of fracking under Governor Newsom had doubled, as compared to counts under former Governor Brown. Since then we have continued tracking the numbers and updating the California public via multiple news stories, blog reports, and with a map of new permits on NewsomWellWatch.com, where permitting data for the third quarter of 2020 has just been posted.
Now again, the rate of new oil and gas well permits issued by the California Geologic Energy Management division (CALGEM) continues to increase even faster in 2020, with permits issued to drill new oil and gas production wells nearly doubling since 2019. But what exactly does this mean for Frontline Communities and climate change? To answer this question, FracTracker Alliance and Consumer Watchdog teamed up with Earthworks’ Community Empowerment Project (CEP).
CEP’s California team worked with community members and grassroots groups to film emissions of methane and other volatile organic compounds (VOCs) emitted from oil and gas extraction sites, including infrastructure servicing oil and gas production wells such as the well-heads, separators, compressors, crude oil and produced water tanks, and gathering lines. Emissions of GHGs, such as methane, are a violation of the California Air Resources Board’s (CARB) California oil and gas rule (COGR), California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, § 95669, Leak Detection and Repair.
The emissions were filmed by a certified thermographer with a FLIR (Forward Looking Infrared) GF320 camera that uses optical gas imaging (OGI) technology. The OGI technology allows the camera to film and record visualizations of VOC emissions based on the absorption of infrared light. It is the exact same technology required by the U.S. EPA under the rule for new source performance standards and the by California Air Resources Board for Leak Detection and Repair (LDAR) to properly inspect oil and gas infrastructure. The video footage clearly shows the presence of a range of VOCs, methane, and other gases that are otherwise invisible to the naked eye.
The footage shown below is in greyscale and can appear grainy when the camera is being operated in high sensitivity modes, which is sometimes necessary to visualize certain pollution releases. The descriptions preceding each video explain what the trained camera operator saw and documented. A map of these sites is presented at NewsomWellWatch.com.
Newsom Well Watch interactive map
Navigate to the next slide using the arrows at the bottom of the map.
Find the story map, and more by clicking the image below.
Case Studies on Permitted Sites
Cat Canyon Tunnell Well Pad.
Earthworks’ California CEP thermographer visited this site in December of 2019, and just happened to arrive while the operator (oil and gas company) was conducting activities underground, including drilling new wells and reworking existing wells. In 2019 the operator, Vaquero Energy, was approved to drill 10 new cyclic steam wells and rework 23 existing oil and gas production wells at this site.
The footage shows significant emissions coming from an unknown source near the wellheads on the well pad; most likely these emissions were coming directly from the open boreholes of the wells. The emissions potentially include a cocktail of VOCs and GHGs such as methane, ethane, benzene, and toluene. This footage provides a candid view of what is released during these types of activities. The pollution shown appears to be the result of an uncontrolled source commonly resulting from drilling and reworking wells
Additionally, inspectors are rarely, if ever, present during these types of activities to ensure that they are conducted in accordance with regulations. The CEP camera operator reported the emissions and provided the OGI video to the Santa Barbara County Air Pollution Control District. By the time the inspector arrived, however, the drilling crew had ceased operations. The inspector did not detect any of these emissions, and as a result the operator was not held accountable for this large pollution release.
In the footage below, the emissions can be seen traveling over the fenceline of the well pad, swirling and mixing with the wind. This site is a clear example of what to look for in the following videos, since the emissions are so obvious. Fortunately, there are no homes or buildings in close proximity to this site, which potentially limited direct pollution exposure — although the pollution still degrades air quality and can pose an occupational health risk to oil field workers.
South Los Angeles Murphy Drill Site
The Murphy Drill Site in Los Angeles has been a long-standing nuisance and source of harmful pollution for neighbors in Jefferson Park. The site houses 31 individual operational wells, including 9 enhanced oil recovery injection wells and 22 oil and gas production wells, as shown below in the map in Figure 1. The wells are operated by Freeport-McMoran, while the site is owned by the Catholic archdiocese of Los Angeles. The site is within 200 feet of homes, playgrounds and a health clinic. There are over 16,000 residents within 2,500’ of the site, as well as a special needs high school, an elementary school, a hospice facility, and a senior housing complex.
Figure 1. Map of the Murphy drill site
The neighborhoods near the Murphy Site are plagued with strong chemical odors, including those linked to oil and gas operations (such as the “rotten egg” smell of health-harming hydrogen sulfide), most likely from the toxic waste incinerators on site. Community members have suffered from respiratory problems, chronic nosebleeds, skin and eye irritation, and headaches. The operators have received multiple violations, including for releasing emissions at concentrations 400% over the allowable limit of methane and VOCs. Some of these violations were the direct result of complaints from the community and the Earthworks CEP team, which filmed pollution from the site on multiple occasions. Yet despite receiving “Notices of Violations” and fines, Freeport-McMoran has been allowed to continue operations. In OGI footage, emissions are visible continuously escaping from a vent on the equipment. While this leak has been addressed by regulators, each new visit to this site tends to result in finding new uncontrolled emissions sources.
South Los Angeles Jefferson Drill Site
The Jefferson drill site is very similar situation to the Murphy Site. The sites have the same operator, Freeport-McMoran, and surrounding neighborhoods in both locations have suffered from exposure to toxic pollution as well as odors, truck traffic, and noise. The Jefferson site has 49 operational wells, including 15 enhanced oil recovery wells, as shown below in Figure 2. In 2013 the operator reported using over 130,000 pounds of corrosive acids and other toxic chemicals for enhanced oil recovery operations. Regardless, an environmental impact report has never been completed for this site.
Figure 2. Map of the Jefferson drill site in South Los Angeles.
The site is located 3 feet from the nearest home, and the surrounding residential buildings are considered “buffers” for the rest of the neighborhood, which also includes an elementary school about 700 feet away. The site was nearly shut down by the City of Los Angeles in 2019, but is currently still operational. In 2019 the site was even issued a permit to rework an existing well in order to increase production from the site. The footage below shows a large, consistent release of pollution from equipment on the well pad. The plume appears above the site and is visible against the background of the sky. The Earthworks CEP team reported the pollution to the South Coast Air Quality Management District (SCAQMD), which conducted an inspection, stopped the leak, and issued a notice of violation and a fine. It is not clear exactly how long this pollution problem had gone unnoticed or unaddressed, and it is not unlikely that another leak will occur without being quickly identified.
Wilmington E&B Resources WNF-I Site on Main St
The WNF-I drilling site is located in Carson in the City of Los Angeles. Operated by E&B Natural resources in the Wilmington oil and gas field, the site houses 35 operational oil and gas wells, including 12 enhanced oil recovery wells and a wastewater disposal well. There is also extensive above-ground infrastructure on the well site, including a large, high-volume tank battery used to store oil and wastewater produced from numerous oil and gas wells in the area.
Using OGI, Earthworks identified a large pollution release from the top of the largest tank. In the video footage, the plume or cloud of gases (likely methane and VOCs) can be seen hovering over the site and slowly dispersing over the fence-line into the communities of West Carson and Avalon Village. Despite clear operational problems, CalGEM approved this site for two rework permits in 2019 and then three re-drills (known as sidetracks) of existing wells in 2020 in order to increase production. The SCAQMD reports that they have inspected this facility, but it is not clear whether this major uncontrolled source has been stopped.
Long Beach Signal Hill Drill Site
At an urban drilling site in the neighborhood of Signal Hill in Los Angeles County, Earthworks filmed and documented pollution releases from numerous pieces of equipment. The site includes 15 operational oil and gas wells operated by Signal Hill Petroleum and The Termo Company. Emissions of gases (likely methane and VOCs) were documented on infrastructure from both operators. At this site, Signal Hill Petroleum received a permit in April 2019 to rework an operational well to increase production. That well is located less than 70’ from a home.
While this site is located within Los Angeles County, it is outside the jurisdiction of the city itself. Any local protections for drilling sites within the Los Angeles city limits are not afforded to communities such as Signal Hill. This area that includes the Signal Hill oil field and the Signal Hill portion of the Long Beach oil field, where many well sites are unmaintained and oversight is limited — conditions that in turn can result in corrosion and pollution leaks. The SCAQMD inspected this site and reported that these uncontrolled sources of emissions have been addressed by the operator, but it is not clear if the emission have stopped.
Midway-Sunset Crail Tank Farm
This tank farm, located in Kern County, services a number of wells operated by Holmes Western Oil Corporation on the outskirts of the Mid-Way Sunset Field. Of the wells serviced by this site, permits were issued to four active oil and gas production wells in 2019. The permits authorized the operator to rework the wellbores in order to increase production. The site contains nine operational oil and gas wells, including eight production wells pumping oil to the surface and one wastewater disposal well. There are multiple homes near this site, within 400’ to the west and within 300’ to the northeast.
For each gallon of oil produced, another ten gallons of contaminated wastewater are brought to the surface. Using diesel or gas generators this wastewater is pumped back into the ground. California regulators have a bad track record of managing underground injection of wastewater, which is now under the U.S. EPA’s oversight. The groundwater in this area of Kern County is largely contaminated and considered a sacrifice zone.
The emissions from this site are from the pressure release valves on the tops of multiple tanks. The tanks store both crude oil and wastewater. The infrared spectrum allows the camera to film the tank levels, which are nearly full. As the tanks fill with more crude oil and hydrocarbon contaminated wastewater the head space of the tank pressurizes with more VOC’s. This footage was also filmed at night when emissions are typically much lower. During the day heat from the sun (radiative energy) heats the tanks and increases the head space pressure resulting in greater emissions. While the San Joaquin Valley Air Pollution Control District (SJVAPCD) was notified of these uncontrolled sources of emissions, their own inspections of the site did not identify an actionable offense on the part of the operator and these uncontrolled emissions continue to be released.
Crude oil and wastewater storage tanks are a common source of fugitive emissions and represent the majority of emissions presented in this report. Some tanks and well-sites use best practices that include closed vapor recovery systems to prevent venting tanks from leaking, but the vast majority do not and vent directly to the atmosphere. In all cases, tanks and pipeline infrastructure use pressure release valves to vent emissions when pressure builds too high. This venting is permitted as strictly an emergency activity to prevent hazardous build-up of pressure. Vents are even designed to open and reset themselves automatically. Consequently, tank venting is a common practice and operators seem to often leave these valves open.
While the recently enacted California Oil and Gas Rule (COGR) places limits on GHG emissions from all oil and gas facilities, internal policy of the San Joaquin Air Valley Air Pollution Control District has previously exempted tanks at low-producing well sites from having to be kept in a leak-free condition, creating a regulatory conflict that air districts and CARB need to resolve. This type of emissions source is also difficult for regulators to identify during inspections, for a number of reasons. These valves are typically located on the tops of large tanks where they are difficult to access and view, and inspections and sampling can only occur by chance (i.e., when the valve in open). Further, these valves can be immediately closed by operators during or upon notification of an upcoming inspection.
New Permits: Moving in the Wrong Direction
When Earthworks CEP uses OGI cameras to inspect an oil and gas site in California, finding and documenting pollution releases is so common that it is the default expectation. Because of access and proximity limitations, it is possible that more pollution is being released from sites than CEP can identify. All of these examples of pollution, including releases of methane and VOCs, add up to potentially degrade air quality and expose Frontline Communities to health risks — as well as many others just like them. This summary represents a small collection of leaking well sites visited by Earthworks CEP, which have coincidentally received new permits to operate and rework existing wells since January 1, 2019. CEP has also documented many other hazardous cases, such as the Jewett 1-23 site in Arvin (shown in the footage below), that is persistently exposing elementary school students to VOCs. These sites surely make up only a small proportion of the polluting oil and gas sites in California that harm climate and health.
From the initial drilling of an oil and gas well, during production, and into subsequent reworks, all phases of a well’s lifetime result in unpermitted and undocumented fugitive emissions. Regulating emissions from oil and gas extraction operations has not been effective in California. Regardless of notices of violations and fines, polluting facilities and well sites continue to operate and even receive new permits. Even the COGR rule, lauded as the most stringent GHG emissions regulation in the nation is technically unable to eliminate or even identify these uncontrolled sources. It is clear that the only ways to reduce exposures to these emissions for Frontline Communities is to institute protective setbacks and stop permitting the drilling of new wells and the reworking of aging wells.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/08/EQT-Tioga-Wide-7.gif300800Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2020-11-18 12:40:132021-04-15 14:16:04Documenting emissions from new oil and gas wells in California