Updated National Energy and Petrochemical Map
We first released this map in February of 2020. In the year since, the world’s energy systems have experienced record changes. Explore the interactive map, updated by FracTracker Alliance in April, 2021.
Ohio, West Virginia, Pennsylvania Fracking Story Map
FracTracker’s aerial survey of unconventional oil & gas infrastructure and activities in northeast PA to southern OH and central WV
EPA
Impacts of 2020 Colonial Pipeline Rupture Continue to Grow
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Mapping Gathering Lines in Bradford County, Pennsylvania
FracTracker mapped gathering lines in Bradford County, PA. Public data on gathering lines are incomplete, leaving us to fill in the gaps.
2021 Pipeline Incidents Update: Safety Record Not Improving
The map below shows 6,950 total incidents since 2010, translating to 1.7 incidents per day. Pipelines are dangerous, in part because regulation around them is ineffective.
Risky Byhalia Connection Pipeline Threatens Tennessee & Mississippi Health, Water Supply
Overview
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.
Contents
Environmental and hydrological
Demographics and disaster preparedness
Byhalia Connection Pipeline
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.
View Full Screen | Updated March, 2021
Environmental and hydrological
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.
View Full Screen | Last updated March 2021
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.
Human health
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.
Figure 2. Observed/documented oil spill-induced acute and chronic human health effects. Source: Guidance for the Environmental Public Health Management of Crude Oil Incidents, Health Canada (2018).
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).
Byhalia civic and industrial facilities
View Full Screen | Updated March, 2021
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.
Geological
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.
Figure 3: New Madrid Seismic Zone. Source: United States Geological Survey
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.
View Full Screen | Updated March 2021
Demographics and disaster preparedness
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.
View Full Screen | Updated March 2021
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.
| Demographic | Within ½ mile of Byhalia Connection Pipeline | Within 2 miles of Byhalia Connection Pipeline |
| Total population | 15,041 | 76,016 |
| Non-white population | 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?
| Facility | Within ½ mile of pipeline | Within 2 miles of pipeline |
| Child care | 4 (one within 800 feet) | 30 |
| Public school | 2 (one within 800 feet) | 26 |
| EMS | 2 | 11 |
| Hospital | 0 | 1 |
| Private school | 0 | 1 |
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.
Source: Article in commercialappeal.com
“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
And two days later, on March 16th, the Memphis City Council unanimously approved a resolution that opposes the Byhalia Connection Pipeline project.
Economics and land ownership
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
Figure 6: Homeownership in the US by race or ethnicity. Source: 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.
Pipeline Incidents
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.
View Full Screen | Updated March, 2021
You can also read more about a wider diversity of hazardous liquid materials accidents analyzed by FracTracker in an article from February 2020, entitled “Pipelines Continue to Catch Fire and Explode”.
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.
Guidance in the case of a crude oil incident
Health Canada published the information document Guidance on the Management of Crude Oil Incidents (2018), which details important information about how to deal with crude oil spills. Here are checklists on whether to evacuate or shelter in place and information on determining protective zone distances, particularly downwind of a spill from the 2016 Emergency Response Guidebook.
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
Where from here?
The Byhalia Connection Pipeline is receiving considerable scrutiny, both from media sources like the Memphis Daily News and MLK50, as well as advocacy groups including Sierra Club’s Tennessee Chapter, the Southern Environmental Law Center, Memphis Community Against the Pipeline, and Protect Our Aquifer. In a move considered egregious by a vast swath of stakeholders, in early February 2021, the US Army Corps of Engineers approved a Nationwide 12 permit to fast-track the Byhalia project, effectively cutting out public comment from the process, and lightening the environmental review requirements. Because the project touches vulnerabilities in the intersection of environment, economics, health, safety, and social justice, this discussion is not likely to easily recede into the background, despite placating claims by the companies that are poised to profit.
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.
The Takeaway
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.
References & Where to Learn More
MLK50.com maintains an archive of excellent reading materials on this controversial project that can be found here.
Topics in this Article
Data Sources in this Article
- Byhalia and Diamond Pipelines
Data collected by FracTracker Alliance from https://www.eia.gov/petroleum/xls/EIA_LiqPipProject.xlsx. Nov 2019. Plans to include natural gas projects listed here https://www.eia.gov/naturalgas/pipelines/EIA-NaturalGasPipelineProjects.xlsx by early 2020. Byhalia route digitized from https://byhaliaconnection.com/wp-content/uploads/2020/07/10-BC-LargeMapPoster-Compressed-1-1-1-scaled.jpg, Diamond Pipeline route from https://pipelinetownhall.com/news/news/tag/diamond+pipeline.
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Capline PipelineData downloaded by FracTracker Alliance from US Energy Information Administration (EIA) https://www.eia.gov/maps/layer_info-m.php and adjusted to orthoimagery in area near Byhalia project, by FracTracker.
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Coldwater National Wetlands Inventory (2-mile buffer to Byhalia)National Wetlands Inventory data downloaded from https://www.fws.gov/wetlands/Data/Mapper.html by FracTracker Alliance, 27 January 2021.
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Horn Lake National Wetlands Inventory (2-mile buffer to Byhalia)National Wetlands Inventory data downloaded from https://www.fws.gov/wetlands/Data/Mapper.html by FracTracker Alliance, 27 January 2021.
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Davis Wellhead Water Protection ZoneBoundary digitized by FracTracker from a map by Southern Environmental Law Center, accessed at https://mlk50.com/2021/01/29/memphis-political-players-weigh-in-on-byhalia-pipeline/.
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Memphis Sands AquiferDownloaded from https://catalog.data.gov/dataset/middle-claiborne-aquifer-alabama-arkansas-illinois-kentucky-louisiana-missouri-missis-2006-2008 by FracTracker Alliance, 4 February 2021.
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Middle Clairborne Aquifer boundaryDownloaded from https://catalog.data.gov/dataset/middle-claiborne-aquifer-alabama-arkansas-illinois-kentucky-louisiana-missouri-missis-2006-2008 by FracTracker Alliance, 4 February 2021. Boundaries of separate units dissolved.
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New Madrid FaultLikely fault line locations of New Madrid Fault. Georeferenced and digitized by FracTracker Alliance, 5 February 2021. Sources: https://www.unavco.org/software/modeling/3d-def/example5.html and https://forms2.rms.com/rs/729-DJX-565/images/eq_new_madrid_seismic_hazard.pdf.
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1/2-mile buffer to Byhalia Connection PipelineData layer generated in ArcGIS by FracTracker Alliance.
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2-mile buffer to Byhalia Connection PipelineData layer generated in ArcGIS by FracTracker Alliance.
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Properties facing eminent domainDownloaded 1 February 2021 by FracTracker Alliance from KML file. Source: https://www.google.com/maps/d/u/0/viewer?mid=1TbVEnJyBLC2Hs-SyeDlNAuY8XjCkjFsU&ll=35.00592787424381%2C-90.09959185425845&z=15.
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Private school within 2 miles of Byhalia routeDownloaded by FracTracker Alliance from https://hifld-geoplatform.opendata.arcgis.com/datasets/private-schools, 12 April 2018.
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Public school within 2 miles of Byhalia routeThis feature class/shapefile captures Public Schools defined by the Common Core Data (CCD) for the Homeland Infrastructure Foundation-Level Data (HIFLD) database. (https://gii.dhs.gov/HIFLD). Downloaded 9 April 2020 by FracTracker Alliance. Source: https://hifld-geoplatform.opendata.arcgis.com/datasets/public-schools.
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Hospital within 2 miles of Byhalia routeThis feature class/shapefile contains Hospitals derived from various sources (refer SOURCE field) for the Homeland Infrastructure Foundation-Level Data (HIFLD) database. (https://gii.dhs.gov/HIFLD). Downloaded 9 April 2020 by FracTracker Alliance. Source: https://hifld-geoplatform.opendata.arcgis.com/datasets/6ac5e325468c4cb9b905f1728d6fbf0f_0.
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Child care facilities within 2 miles of Byhalia routeDownloaded 9 April 2020 by FracTracker Alliance. Source: https://hifld-geoplatform.opendata.arcgis.com/datasets/child-care-centers.
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EMS within 2 miles of Byhalia routeDownloaded 9 April 2020 by FracTracker Alliance. Source: https://hifld-geoplatform.opendata.arcgis.com/datasets/emergency-medical-service-ems-stations.
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Toxics Release Inventory sites within 2 mi of Byhalia routeData downloaded from https://www.epa.gov/toxics-release-inventory-tri-program/tri-basic-data-files-calendar-years-1987-2019? and processed from csv file into ESRI shapefile by FracTracker Alliance. 12 February 2021. Metadata here: https://www.epa.gov/sites/production/files/2019-08/documents/basic_data_files_documentation_aug_2019_v2.pdf Categories described on pages 5-17 of document.
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Non-white percentage, 1/2 mile evacuation zone from Byhalia pipelineData 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.
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Non-white percentage, 2-mile buffer to Byhalia pipelineData 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.
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Low income percentage, 1/2 mile evacuation zone from Byhalia pipelineData 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.
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Low income percentage, 2-mile buffer to Byhalia pipelineData 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.
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New Madrid Fault Shake ZoneDigitized by FracTracker Alliance from raster dataset found at https://ft.maps.arcgis.com/
home/item.html?id= c751b8471e2a4959a91345057cd1bf 0a. 3 February 2021.
Shell’s Falcon Pipeline Under Investigation for Serious Public Safety Threats
Breaking News
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.
3/17/21 Press release: https://www.fractracker.org/falcon-investigation-press-release-fractraccker-alliance/
Key Takeaways
- 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.
- Organizations are calling on public agencies to take action to protect public welfare and the environment along the entire pipeline route through Ohio, West Virginia, and Pennsylvania.
- 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 new concerns are coming to light as people across the country are demanding bold action on plastic pollution and the climate crisis through campaigns such as Build Back Fossil Free, Plastic Free President, and Future Beyond Shell. On a local level, residents in the Ohio River Valley continue to shoulder the health burdens of the fracking industry, despite a recent ban on fracking in the eastern part of Pennsylvania, which a growing body of scientific evidence verifies. The Falcon Pipeline, which would transport fracked gas for plastic production, is directly at odds with these demands.
Shell’s attempts to cut corners while constructing this 98-mile pipeline, likely motivated by the increasingly bleak economic prospects of this project, present serious public safety concerns for the thousands of residents along its route in Pennsylvania, West Virginia, and Ohio.
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.
These investigations were featured in a March 17th article by Anya Litvak in the Pittsburgh Post-Gazette.
3/18/21 update:
Additional coverage of this story was published in a Times Online article by Daveen Ray Kurutz, a StateImpact Pennsylvania article by Reid Frazier, and an Observer-Reporter article by Rick Shrum.
Pipeline workers speak out
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.
View Map Full Sized | Updated 6/16/20
PHMSA’s incomplete investigation
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.
February 2019:
April 9 - 11, 2019
April 9 - 11, 2019
Later in 2019
August 2, 2019
August 2, 2019
September 24, 2019
September 25, 2019
September 25, 2019
October 11, 2019
October 23, 2019
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
October 23, 2019
November 7, 2019:
January 28, 2020
January 28, 2020
February 26, 2020
July 16, 2020
PHMSA’s website shows that the agency opens a case into the Falcon Pipeline. PHMSA states it is basing this case on the inspection April 9-11, 2019 inspection.
July 16, 2020
August 13, 2020
September 4, 2020
September 4, 2020
Ohio and West Virginia
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.
Construction of the ethane cracker and the Falcon pipeline have forged forward during the COVID-19 pandemic. In another example of the culture of fear at the worksite, several workers expressed concern that speaking publicly about unsafe working conditions that made social distancing impossible would cost them their jobs. Yet the state has allowed work to continue on at the plant, going so far as to grant Shell the approval to continue work without the waiver most businesses had to obtain. As of December 2020, over 274 Shell workers had contracted the coronavirus.
Weak outlook for Shell’s investment
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.
A June 2020 report by the Institute for Energy Economics and Financial Analysis (IEEFA), stated that:
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?
References & Where to Learn More
- FracTracker Petrochemicals & Plastics articles and imagery: https://www.fractracker.org/categories/by-content/petrochemicals/
- FracTracker Falcon EIA webpage: https://www.fractracker.org/projects/falcon-public-eia/
- FracTracker June 16, 2020 article Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
- Future Beyond Shell Campaign: https://futurebeyondshell.org/ (see this campaign’s social media toolkit here)
Topics in this Article
Health & Safety | Legislation & Politics | Petrochemicals & Plastics | Pipelines
Mapping Gathering Lines in Ohio and West Virginia
As a spring 2020 intern with FracTracker, my work mostly involved mapping gathering lines in West Virginia and Ohio. Gathering lines are pipelines that transport oil and gas from the wellhead to either compressor stations or storage/processing facilities. The transmission pipelines (which are often larger in diameter than gathering lines) take the oil and gas from the processing facilities to other storage facilities/compressor stations, or to distribution pipelines which go to end users and consumers. As you can see from Figure 2 in the map of Doddridge County, WV, many gathering lines eventually converge at a compressor station. You can think of gathering lines like small brooks and streams that feed transmission pipelines. The transmission lines are the main arteries, like a river, moving larger quantities of gas and oil over longer distances.
PROJECT DESCRIPTION
The main project and goal of my internship was to record as many gathering pipelines as I could find in Ohio and West Virginia, since gathering lines are not generally mapped and therefore not easily available for the public to view. For example, the National Pipeline Mapping System’s public map viewer (created by the Department of Transportation Pipeline and Hazardous Materials Safety Administration) has a note stating, “It does not contain gas gathering or distribution pipelines.” Mapping gathering lines makes this data accessible to the public and will allow us to see the bigger picture when it comes to assessing the environmental impact of pipelines.
After collecting gathering line location data, I performed GIS analysis to determine the amount of acreage of land that has been clearcut due to gathering pipeline installations.
Another analysis we could perform using this data is to count the total number of waterways that the gathering lines cross/interact with and assess the quality of water and wildlife in areas with higher concentrations of gathering pipelines.
Figure 1. This map shows an overview of gathering line pipelines in the Powhatan Point, Ohio and Moundsville, West Virginia of the Ohio River Valley.
PIPELINE GATHERING LINE MAPPING PROCESS
I worked with an aerial imagery BaseMap layer (a BaseMap is the bottommost layer when viewing a map), a county boundaries layer, production well location points, and compressor station location points. I then traced lines on the earth that appeared to be gathering lines by creating polygon shapefiles in the GIS application ArcMap.
My methodology and process of finding the actual routes of the gathering lines included examining locations at various map scale ranges to find emerging line patterns of barren land that connect different production well points on the map. I would either concentrate on looking for patterns along well pad location points and look for paths that may connect those points, or I would begin at the nearest gathering line I had recorded to try to find off-shoot paths off of those pipelines that may connect to a well pad, compressor station or previously recorded gathering line.
I did run into a few problems during my search for gathering lines. Sometimes, I would begin to trace a gathering line path, only to either loose the path entirely, or on further inspection, find that it was a power line path. Other times when using the aerial imagery basemap, the gathering line would flow into an aerial photo from a year prior to the pipeline installation and I would again lose the path. To work around these issues, I would first follow the gathering line trail to its end point before I started tracing the path. I would also view the path very closely in various scale ranges to ensure I wasn’t tracing a road, waterway, or powerline pathway.
ACREAGE ANALYSIS
In the three months that I was working on recording gathering pipeline paths in Ohio and West Virginia, I found approximately 29,103 acres (3,494 miles) of barren land clearcut by gathering pipelines. These total amounts are not exact since not all gathering lines can be confirmed. There are still more gathering lines to be recorded in both Ohio and West Virginia, but these figures give the reader an idea of the land disturbance caused by gathering lines, as shown in Figures 1 and 2.
In Ohio, I recorded approximately 10,083 acres (641 miles) with the average individual gathering pipeline taking up about 45 acres of land. With my gathering line data and data previously recorded by FracTracker, I found that there are 28,490 acres (1,690 miles) of land spanning 9 counties in southeastern Ohio that have been cleared and used by gathering lines.
For West Virginia, I was able to record approximately 19,020 acres (1,547 miles) of gathering lines, with the average gathering line taking up about 48 acres of space each. With previous data recorded in West Virginia by FracTracker, the total we have so far for the state is 22,897 acres (1,804 miles), although that is only accounting for the 9 counties in northern West Virginia that are recorded.
Figure 2. This aerial view map shows connecting gathering line pipelines that cover a small portion of Doddridge County, WV.
CONCLUSION
I was shocked to see how many gathering lines there are in these rural areas. Not only are they very prevalent in these less populated communities, but it was surprising to see how concentrated and close together they tend to be. When most people think of pipelines, they think of the big transmission pipeline paths that cross multiple states and are unaware of how much land that the infrastructure of these gathering pipelines also take up.
It was also very eye-opening to find that there are at least 29,000 acres of land in Ohio and West Virginia that were clearcut for the installation of gathering lines. It is even more shocking that these gathering pipelines are not being recorded or mapped and that this data is not publicly available from the National Pipeline Mapping System. While driving through these areas you may only see one or two pipelines briefly from your car, but by viewing the land from a bird’s eye perspective, you get a sense of the scale of this massive network. While the transmission pipeline arteries tend to be bigger, the veins of gathering lines displace a large amount of land as well.
I was also surprised by the sheer number of gathering lines I found that crossed waterways, rivers, and streams. During this project, it wasn’t unusual at all to follow a gathering line path that would cross water multiple times. In the future, I would be interested to look at the number of times these gathering pipelines cross paths with a stream or river, and the impact that this has on water quality and surrounding environment. I hope to continue to record gathering lines in Ohio and West Virginia, as well as Pennsylvania, so that we may learn more about this infrastructure and the impact it may have on the environment.
About Me
I first heard of FracTracker three years ago when I was volunteering with an environmental group called Keep Wayne Wild in Ohio. Since learning about FracTracker, I have been impressed with their eye-opening projects and their ability to make the gas and oil industry more transparent. A few years after first hearing about FracTracker, and as my interest in the GIS field continued to grow, I began taking GIS classes and reached out to them for this internship opportunity.
By Trevor Oatts, FracTracker Spring 2020 Data & GIS Intern
Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
Part of the Falcon Public Environmental Impact Assessment – a FracTracker series on the impacts of Falcon Ethane Pipeline System
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
A drilling fluid spill from Falcon Pipeline construction near Moffett Mill Road in Beaver County, PA. Source: Pennsylvania DEP
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Figure 1. An HDD operation – Thousands of gallons of drilling fluid are used in this process, creating the potential for spills. Click to expand. Source: Enbridge Pipeline
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
- Loss of circulation
- Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
- Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
- Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
- 15 losses in Ohio – totaling 73,414 gallons
- 34 losses in Pennsylvania – totaling 172,116 gallons
- Inadvertent return
- Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
- Cause: Inadvertent returns are also frequent during HDD construction and are caused by many of the same factors as losses of circulation.
- Construction of the Falcon has caused at least 20 inadvertent returns, releasing at least 5,581 gallons of drilling fluid. These incidents include:
- 18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
- 2,639 gallons into water resources (streams and wetlands)
- 2 inadvertent returns Ohio – totaling 35 gallons
- 35 gallons into water resources (streams and wetlands)
- 18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
- Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
However, according to the Ohio EPA, Shell is not required to submit reports for losses of circulation that are less than the definition of an inadvertent return, so many losses may not be captured in the list above. Additionally, documents reveal inconsistent volumes of drilling mud reported and discrepancies in the way releases are regulated by the Pennsylvania DEP and the Ohio EPA.
Very few of these incidents were published online for the public to see; FracTracker obtained information on them through a public records request. The map below shows the location of all known drilling fluid releases from that request, along with features relevant to the pipeline’s construction. Click here to view full screen, and add features to the map by checking the box next to them in the legend. For definitions and additional details, click on the information icon.
Jefferson County, Ohio
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
Figure 2. Losses of circulation that occurred at the SCIO-06 horizontal directional drill (HDD) site along the Falcon Pipeline in Jefferson County Ohio. Data Sources: OH EPA, AECOM
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
Figure 3. The SCIO-06 HDD site, which may be changed from an HDD crossing to an open cut trench and conventional bore to cross Wolf Run Rd, Wolf Run stream (darker blue), an intermittent stream (light blue) and a wetland (teal). Click to expand.
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
- when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
- when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
- whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.” In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Figure 4) HOU-10 HDD location on the Falcon Pipeline, where 50 gallons were released on the drill pad on 7/9/2019
Figure 5) SCIO-05 HDD location on the Falcon Pipeline, where 160 gallons were released on 6/10/19, within the pipeline’s LOD (limit of disturbance)
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
Despite the issues Shell experienced during construction, work on the Falcon continued over the past months during state shelter-in-place orders, while many businesses were forced to close.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
New Yorkers mount resistance against North Brooklyn Pipeline
By Kim Fraczek (Sane Energy Project), with input and mapping by Karen Edelstein (FracTracker Alliance)
Despite overwhelming concern about the impacts of fossil fuels on climate chaos, pipeline projects are springing up all over the country in an effort find markets for the surplus of fracked gas extracted from the Marcellus region in Pennsylvania. New Yorkers are directly impacted by these problematic supply chains. The energy company, National Grid, is proposing to raise New Yorkers’ monthly bills in order to complete a new, 30-inch high-pressure fracked gas transmission pipeline through Brooklyn, New York. National Grid euphemistically named the 350-psi pipeline the “The Metropolitan Reliability Pipeline Project.” Gas moving through this pipeline is destined for a National Grid Depot on Newtown Creek, which divides Brooklyn from the borough of Queens. National Grid plans to expand liquefied natural gas (LNG) storage and vaporizer operations at the Depot. The Depot expansion will also facilitate trucking transport of gas to and from North Brooklyn to destinations in Long Island and Massachusetts.
For an industry explanation on how vaporizers work, click here.
National Grid Depot is located on the western bank of Newtown Creek. Source: Google Maps
National Grid is asking the New York State Public Service Commission (PSC) to approve:
- A charge of $185 million to rate-payers in order to finish the current pipeline phase under construction in Bushwick. Pipeline construction would continue north into East Williamsburg and Greenpoint (other sections of Brooklyn)
- $23 million to replace two old vaporizers at National Grid’s Greenpoint LNG facility
- $54 million to add two new vaporizers to the Greenpoint LNG facility
- $31.5 million over the next 4 years to add “portable LNG capabilities at the Greenpoint site that will allow LNG delivered via truck to on-system injection points.” National Grid is currently seeking a variance from New York City for permission to bring LNG trucks onto city property. Currently, this sort of activity is illegal due to high risk of fires and explosions.
Impacts on the community, resistance to the pipeline
Pipelines also present risks of catching fire and exploding. On average, a 350-psi gas pipeline has an evacuation radius of approximately 1275 feet. FracTracker Alliance created the interactive map, below, using 2010 census data to show population density in the neighborhoods within this blast zone. According to FracTracker, there were 614 reported pipeline incidents in the United States in 2019 alone, resulting in the death of 10 people, injuries to another 35, and about $259 million in damages.
View map fullscreen | How FracTracker maps work
There is widespread community opposition to this pipeline, LNG expansion, and trucking proposal because it will:
- Threaten the health and safety of nearly 153,000 people living in the evacuation zone. Concerns include air quality impacts from fugitive methane that could especially impact those with asthma, and functional logistics around safe evacuation in the event of a leak or explosion.
- Within the evacuation zone, using federal data, FracTracker determined that there are also:
Opponents of this pipeline project also raise objections that the pipeline will:
- Become a stranded asset leaving residents to foot the bill for the pipeline as city and state climate laws are implemented
- Contribute carbon monoxide and methane to the atmosphere, thereby accelerating climate change and its impacts on coastal metropolises like New York City
Project Status
National Grid is currently constructing Phase 4 of the pipeline. However, public pressure and concern about COVID-19 safety measures forced them to stop construction on March 27, 2020. After Governor Cuomo issued an executive order to halt all non-essential work, neighbors reported the company was not mandating personal protective equipment (PPE) nor social distancing for its workers.
Additionally, funding to build north of Montrose Avenue in Bushwick through to Greenpoint—neighborhoods in northeastern Brooklyn on the border with Queens that make up the fifth phase of the pipeline construction—is pending a decision by the Public Service Commission. The approval of the fifth phase of the pipeline would allow it to reach the LNG facility at Greenpoint.
Generalized map of Brooklyn neighborhoods. Source: Wikipedia.
The current National Grid rate case proceeding is in its last stage of discovery, testimony, cross-examination, and final briefs from parties to the rate case. The Administrative Law Judges overseeing the proceeding will review all parties’ information, and make a recommendation to the Public Service Commission, a five-person panel appointed by New York State Governor Cuomo to regulate our utilities. This decision will most likely happen at the monthly meeting on June 18, 2020, where they also may make a decision on National Grid’s Long Term Plan proceeding that could determine the future of LNG expansion in North Brooklyn.
What are the broader economic and political concerns for stopping this, and other new pipeline projects?
Sane Energy Project has laid out a clear and cogent set of arguments. These include:
- This project is not about “modernizing” our system for heating and cooking. This is about an expansion to charge rate-payers an increase and to grow profits for National Grid’s shareholders.
- This is a transmission pipeline, not a gas distribution line. It will not service the affected community where the already trafficked main thoroughfares and already stressed trucking routes for local businesses will be dug up.
- Gas pipelines are not safe. According to the United States Pipeline and Hazardous Safety Materials Administration (PHMSA), between 2016 and 2018, an average of 638 pipeline incidents per year resulted in a total of 43 fatalities and 204 injuries . The cost to the public for these incidents over those three years was nearly $2.7 billion. [For more analysis on national pipeline incidents, see FracTracker’s February 2020 article.]
- Fracking exacerbates climate change. Methane is a potent greenhouse gas. Over a 20 year period, it contributes 86 to 100 times more atmospheric warming than equivalent amounts of carbon dioxide. Climate change is destroying Earth’s ability to sustain life.
- This project holds New York State back on our renewable energy goals. We should be mandating any gas pipelines should be replaced with geothermal energy, along with energy efficiency measures in our buildings.
- The industry coined the term “natural” gas to create the sense that it is clean, but the extraction, transport and burning of this gas creates air pollution, disturbs ecosystems, contaminates drinking water sources, and disproportionately affects lower income communities and communities of color.
- A report authored by Suzanne Mattei, former DEC Region 2 Chief, notes National Grid does not have gas supply constraints–the situation where consumer demand exceeds the supply. Mattei contends that this is a manufactured crisis to maintain business-as-usual, keep us hooked on fossil fuels, and charge rate-payers for construction well after the lifespan of this pipeline. This makes local constituents pay for the company’s stranded assets. National Grid themselves report that they are able to handle yearly peak demand through existing supplemental gas sources. What’s more, the EIA expects for natural gas demand to remain flat over the course of the next decade, refuting National Grid’s claim that their massive pipeline project is necessary to respond to the few hours of peak demand experienced each year.
- This is actually a substantial project, which avoided more stringent permitting and discussion by breaking the work into five separate projections, a process known as “segmentation”. The North Brooklyn Pipeline project is disguised as a local upgrade by segmentation, while in reality, it is a much larger project leading to an LNG (Liquefied Natural Gas) depot, CNG (Compressed Natural Gas) and other fracking infrastructure facilities in Greenpoint.
- National Grid is requesting almost 185 million ratepayer dollars over the next three years to complete the project.
What’s next?
As gas prices continue to drop and renewable energy technologies are more accessible and wide-spread, the whole equation that relies on a fossil fuel-based economy becomes more desperate and unsustainable. Many communities are also saying “no” to new pipelines in their communities, so industry is looking to ship fracked gas over land by truck. Another method for disposing of surplus gas is to compress it into LNG (liquefied natural gas) and ship it to international markets by boat.
For more updates on the North Brooklyn Pipeline, check Sane Energy Project’s website. If you live in the New York/Metropolitan area and want to get involved in this fight, there are numerous ways in which you can work with Sane Energy. Click here for details.
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