LPA Pipeline protest - Crosshairs feature

In the Crosshairs

The Origins & Work of Lebanon Pipeline Awareness, Inc. in Lebanon County, PA
by Michael Schroeder, Lebanon Pipeline Awareness, Inc.
LPA Logo

Nestled in a mostly agricultural region blessed with some of the most fertile, non-irrigated farmland in the world, Lebanon County, Pennsylvania sits square in the crosshairs of a Pipeline Revolution – smack-dab in between the Marcellus Shale fracking zones in northern and western PA and the processing and export facilities of the Eastern seaboard. This Pipeline Revolution began in earnest more than four years ago, in spring 2014, when Williams/Transco announced plans to build a 200-mile, 42-inch diameter, high-pressure (1,480 p.s.i.) underground natural gas pipeline with the Orwellian-sounding name “Atlantic Sunrise” as a shortcut to whisk fracked natural gas to points south – mainly Cove Point just south of Baltimore – for export. See map below for more context.

That’s the north-south axis of the crosshairs. East-west, for starters, is the 8-inch diameter, cast-iron Mariner East pipeline, which has traversed the state since the late 1930s, carrying gasoline from the Philadelphia region to the Pittsburgh area. Also around spring 2014, Mariner East’s owner-operator, Sunoco Logistics, announced its Mariner East expansion project: to stop carrying gasoline, reverse the flow, and start streaming natural gas liquids (NGLs – mainly propane, ethane, and butane) from the fracking zones of western PA to the Marcus Hook export facility outside Philadelphia. Also planned were several new larger-volume pipelines to be laid in the same easement – Mariner East 2 and 2X – along with their corresponding pump stations.

The two major transmission pipeline projects cross on private land atop a forested hill in Lebanon County’s South Londonderry Township – making “in the crosshairs” an apt metaphor for where we stand in relation to the Pipeline Revolution.

In response to Williams/Transco’s announcement in spring 2014, activists in neighboring Lancaster County organized the grassroots citizens’ group Lancaster Against Pipelines. We soon followed suit, holding our first organizing meeting in April in humble surroundings, an artist’s loft in downtown Lebanon. After a democratic vote,we called ourselves Lebanon Against Pipelines and began meeting bi-weekly with a core group of 8-10 people.

LPA Organizing Meeting - Crosshairs

Initial organizing meeting of Lebanon Against Pipelines (soon changed to Lebanon Pipeline Awareness), downtown Lebanon, April 2014

By summer 2014, we adopted what we felt was a more positive and publicly acceptable name in our strongly conservative county, one more in keeping with our core mission of raising public awareness about the immensely destructive power of fracking and pipelines: Lebanon Pipeline Awareness.

Making Plans

Over the next year, a core leadership emerged. With the pro-bono help of a local attorney, we became a 501c(3) non-profit corporation with officers and a board of directors, making it possible to apply for much-needed grants after our meager, mostly self-funded beginnings.

Realizing the importance of strength in numbers, from the outset we reached out to collaborate with other groups. We’ve had many key allies in this fight, especially our sister organization, Concerned Citizens of Lebanon County (CCLC). Focused on Sunoco’s Mariner East projects, CCLC has focused mainly on the judicial system to challenge the absurd notion that this project merits status as a “public utility” – most notably by pursuing civil action against Sunoco for not obtaining the proper permits before building its new pump station in West Cornwall Township.

Bringing About Change

How have we worked to raise public awareness? In most every way we can think of, given our limited resources.

We still lack a website, but we have developed and curated a highly active Facebook presence (with nearly 800 “likes” at present). We’ve designed, printed, and distributed widely an attractive tri-fold brochure and our own eye-catching logo. We’ve set up tables at most every available community event (National Night Out in Campbelltown; Historic Old Annville Day; the Lebanon County Fair; and others). We’ve organized protests and demonstrations, often in tandem with Lancaster Against Pipelines and other allied groups. We have sponsored film screenings, public safety forums, speakers from allied organizations, and informational meetings for local landowners and other concerned citizens.

Public protest by LPA

Public protest with Lancaster Against Pipelines, Annville town square, December 2015

We’ve attended local municipal meetings to encourage local authorities to pass resolutions opposing the pipelines traversing their municipalities – in two cases successfully. We’ve filed dozens of Right-To-Know requests, developing a rich archive of construction violations and disseminating our findings publicly. We’ve brought our concerns to the county commissioners’ meetings, prompting them to write letters of concern to state and federal officials and add an informational “pipelines” tab to their website. We have developed a robust presence in local media outlets – issuing press releases and writing letters to the editor and op-ed pieces, and inviting reporters to the events we sponsor – including local newspapers (like the Lebanon Daily News), regional digital media platforms (like NPR’s StateImpact), local TV and radio stations, and more. We’ve even hosted a few tours for national photographers and reporters.

Working with Others

In our interactions with local governmental authorities, we consistently act respectfully and courteously and try hard not to blindside anyone. Before attending a public meeting, we’ll send a courtesy note to the relevant authority, detailing our concerns and summarizing what we’ll be saying and asking for. When speaking at public meetings, we’re civil, crisp, and respectful – though, when necessary, we have engaged in peaceful acts of public protest (like duct-taping our mouths shut when prevented from speaking at a township meeting because we’re not township residents).

We’ve also met with all of our state representatives, either in individual meetings or during town hall-style meetings with constituents. We’ve expressed our concerns to members of Governor Tom Wolf’s staff, his Pipeline Infrastructure Task Force and other Department of Environmental Protection officials, the Susquehanna River Basin Commission, the Federal Energy Regulatory Commission, and other public bodies.

Innovative Pipeline Monitoring Program

Pipeline monitor badge

Citizen pipeline monitoring badge

More recently, with pipeline construction well underway, we’ve developed a pipeline construction monitoring program, undergoing rigorous training and developing official badges to identify ourselves and our organization. We also register all of our monitors with the county commissioners’ office (to prevent imposters from engaging in nefarious acts in our name). (See badge, right)

And it’s made a difference.

I remember well our first outreach efforts in summer 2014 at events like National Night Out in Campbelltown, where we were met with a fair amount of open hostility. “Why do you oppose American energy independence?” people would ask.  “What about all the jobs the pipelines will bring to local workers?” After four years of respectfully but insistently hammering on these issues, the public tenor has shifted. Very rarely do we encounter outright hostility anymore. The public has grown increasingly receptive to our message – especially now that construction has begun and folks can see that what we’ve predicted is now coming to pass.

Respect and Reciprocity

We’ve worked very hard to cultivate a respectable public persona and reputation, and we’ve largely succeeded. As best as we can tell, the predominant public perception is that Lebanon Pipeline Awareness is run by a group of dedicated and well-informed volunteers with an important message to share. In fact, two of our leaders were singled out last year by the local newspaper for recognition as providing a positive impact for our community. Our core group, which generally meets twice a month, has expanded to include upwards of 15 committed local activists.

We’ve also worked hard to always couple our anti-pipeline message with a positive message about renewable energy – repeatedly emphasizing that wind, solar, geothermal, and other green energies represent an increasingly viable alternative for energy and for jobs.

In It for the Long Haul

So that’s where we in Lebanon Pipeline Awareness stand at the beginning of our fifth year. Because we have every reason to expect this insane pipeline buildout to intensify, we know we’re in it for the long haul. Our goals for the coming year are to expand our membership; build on and extend our alliances even further; intensify our outreach efforts and our pipeline construction monitoring program; and continue to host public meetings for concerned property owners and citizens.

CHISPA Flyer

CHISPA Flyer – Click to enlarge

We also plan to expand our activities to include direct action campaigns like CHISPA – “Challenge in the Streets to Pipelines in PA” – where every Friday afternoon from 4-6 p.m. we’ll be lining five miles of westbound Route 422 from Lebanon to Annville with volunteers bearing provocative protest signs that challenge the thousands of passing motorists to think in fresh ways about issues like climate change, jobs, eminent domain, property rights, renewable energies, and more.

Lebanon Pipeline Awareness is but one of dozens of grassroots citizens’ organizations that have emerged across Pennsylvania over the past decade to resist the Fracking and Pipeline revolutions and insist that we follow “a better path” (the name of an emergent coalition of anti-fracking and anti-pipeline groups from across Pennsylvania). We have lost many battles against our vastly more deep-pocketed and powerful adversaries, but we’ve also made a substantial and positive difference.

Will we win the war? Yes, eventually, as global climate disruption makes increasingly clear that our most pressing need as a species is to leave the remaining stocks of fossil fuels in the ground. In the meantime, win or lose, our efforts continue – and will continue as long as these insane Fracking and Pipeline revolutions continue to imperil humankind and the web of life that sustains us all.


by Michael Schroeder, Vice President, Lebanon Pipeline Awareness, Annville, Pennsylvania

Shell Pipeline - Not Quite the Good Neighbor

Shell Pipeline: Not Quite the “Good Neighbor”

In August 2016, Shell Pipeline announced plans to develop the Falcon Ethane Pipeline System, a 97-mile pipeline network that will carry more than 107,000 barrels of ethane per day through Pennsylvania, West Virginia, and Ohio, to feed Shell Appalachia’s petrochemical facility currently under construction in Beaver County, PA.

FracTracker has covered the proposed Falcon pipeline extensively in recent months. Our Falcon Public EIA Project explored the project in great detail, revealing the many steps involved in risk assessments and a range of potential impacts to public and environmental health.

This work has helped communities better understand the implications of the Falcon, such as in highlighting how the pipeline threatens drinking water supplies and encroaches on densely populated neighborhoods. Growing public concern has since convinced the DEP to extend public comments on the Falcon until April 15th, as well as to host three public meetings scheduled for early April.

Shell’s response to these events has invariably focused on their intent to build and operate a pipeline that exceeds safety standards, as well as their commitments to being a good neighbor. In this article, we investigate these claims by looking at federal data on safety incidents related to Shell Pipeline.

Contrary to claims, records show that Shell’s safety record is one of the worst in the nation.

The “Good Neighbor” Narrative

Maintaining a reputation as a “good neighbor” is paramount to pipeline companies. Negotiating with landowners, working with regulators, and getting support from implicated communities can hinge on the perception that the pipeline will be built and operated in a responsible manner. This is evident in cases where Shell Pipeline has sold the Falcon in press releases as an example of the company’s commitment to safety in public comments.

Figure 1. Shell flyer

A recent flyer distributed to communities in the path of the Falcon, seen in Figure 1, also emphasizes safety, such as in claims that “Shell Pipeline has a proven track record of operating safely and responsibility and remains committed to engaging with local communities regarding impacts that may arise from its operations.”

Shell reinforced their “good neighbor” policy on several occasions at a recent Shell-sponsored information meeting held in Beaver County, stating that, everywhere they do business, Shell was committed to the reliable delivery of their product. According to project managers speaking at the event, this is achieved through “planning and training with first responders, preventative maintenance for the right-of-way and valves, and through inspections—all in the name of maintaining pipeline integrity.”

Shell Pipeline also recently created an informational website dedicated to the Falcon pipeline to provide details on the project and emphasize its minimal impact. Although, curiously, Shell’s answer to the question “Is the pipeline safe?” is blank.

U.S. Pipeline Incident Data

Every few years FracTracker revisits data on pipeline safety incidents that is maintained by the Pipeline and Hazardous Materials Safety Administration (PHMSA). In our last national analysis we found that there have been 4,215 pipeline incidents resulting in 100 reported fatalities, 470 injuries, and property damage exceeding $3.4 billion.

These numbers were based on U.S. data from 2010-2016 for natural gas transmission and gathering pipelines, natural gas distribution pipelines, and hazardous liquids pipelines. It is also worth noting that incident data are heavily dependent on voluntary reporting. They also do not account for incidents that were only investigated at the state level.

Shell Pipeline has only a few assets related to transmission, gathering, and distribution lines. Almost all of their pipeline miles transport highly-volatile liquids such as crude oil, refined petroleum products, and hazardous liquids such as ethane. Therefore, to get a more accurate picture of how Shell Pipeline’s safety record stacks up to comparable operators, our analysis focuses exclusively on PHMSA’s hazardous liquids pipeline data. We also expanded our analysis to look at incidents dating back to 2002.

Shell’s Incident Record

In total, PHMSA data show that Shell was responsible for 194 pipeline incidents since 2002. These incidents spilled 59,290 barrels of petrochemical products totaling some $183-million in damages. The below map locates where most of these incidents occurred. Unfortunately, 34 incidents have no location data and so are not visible on the map. The map also shows the location of Shell’s many refineries, transport terminals, and off-shore drilling platforms.

Open the map fullscreen to see more details and tools for exploring the data.


View Map Fullscreen | How FracTracker Maps Work

Incidents Relative to Other Operators

PHMSA’s hazardous liquid pipeline data account for more than 350 known pipeline operators. Some operators are fairly small, only maintaining a few miles of pipeline. Others are hard to track subsidiaries of larger companies. However, the big players stand out from the pack — some 20 operators account for more than 60% of all pipeline miles in the U.S., and Shell Pipeline is one of these 20.

Comparing Shell Pipeline to other major operators carrying HVLs, we found that Shell ranks 2nd in the nation in the most incidents-per-mile of maintained pipeline, seen in table 1 below. These numbers are based on the total incidents since 2002 divided by the number of miles maintained by each operator as of 2016 miles. Table 2 breaks Shell’s incidents down by year and number of miles maintained for each of those years.

Table 1: U.S. Pipeline operators ranked by incidents-per-mile

Operator HVL Incidents HVL Pipeline Miles Incidents Per Mile (2016)
Kinder Morgan 387 3,370 0.115
Shell Pipeline 194 3,490 0.056
Chevron 124 2,380 0.051
Sunoco Pipeline 352 6,459 0.049
ExxonMobile 240 5,090 0.048
Colonial Pipeline 244 5,600 0.044
Enbride 258 6,490 0.04
Buckeye Pipeline 231 7,542 0.031
Magellan Pipeline 376 12,928 0.03
Marathan Pipeline 162 5,755 0.029

Table 2: Shell incidents and maintained pipeline miles by year

Year Incidents Pipeline Miles Total Damage Notes
2002 15 no PHMSA data $2,173,704
2003 20 no PHMSA data $3,233,530
2004 25 5,189 $40,344,002 Hurricane Ivan
2005 22 4,830 $62,528,595 Hurricane Katrina & Rita
2006 10 4,967 $11,561,936
2007 5 4,889 $2,217,354
2008 12 5,076 $1,543,288
2009 15 5,063 $11,349,052
2010 9 4,888 $3,401,975
2011 6 4,904 $2,754,750
2012 12 4,503 $17,268,235
2013 4 3,838 $10,058,625
2014 11 3,774 $3,852,006
2015 12 3,630 $4,061,340
2016 6 3,490 $6,875,000
2017 9 no PHMSA data $242,800
2018 1 no PHMSA data $47,000 As of 3/1/18

Cause & Location of Failure

What were the causes of Shell’s pipeline incidents? At Shell’s public informational session, it was said that “in the industry, we know that the biggest issue with pipeline accidents is third party problems – when someone, not us, hits the pipeline.” However, PHMSA data reveal that most of Shell’s incidents issues should have been under the company’s control. For instance, 66% (128) of incidents were due to equipment failure, corrosion, welding failure, structural issues, or incorrect operations (Table 3).

Table 3. Shell Pipeline incidents by cause of failure

Cause Incidents
Equipment Failure 51
Corrosion 37
Natural Forces 35
Incorrect Operation 25
Other 20
Material and/or Weld Failure 15
Excavation Damage 11
Total 194

However, not all of these incidents occurred at one of Shell’s petrochemical facilities. As Table 4 below illustrates, at least 57 incidents occurred somewhere along the pipeline’s right-of-way through public areas or migrated off Shell’s property to impact public spaces. These numbers may be higher as 47 incidents have no mention of the property where incidents occurred.

Table 4. Shell Pipeline incidents by location of failure

Location Incidents
Contained on Operator Property 88
Pipeline Right-of-Way 54
Unknwon 47
Originated on Operator Property, Migrated off Property 3
Contained on Operator-Controlled Right-of-Way 2
Total 194

On several occasions, Shell has claimed that the Falcon will be safely “unseen and out of mind” beneath at least 4ft of ground cover. However, even when this standard is exceeded, PHMSA data revealed that at least a third of Shell’s incidents occurred beneath 4ft or more of soil.

Many of the aboveground incidents occurred at sites like pumping stations and shut-off valves. For instance, a 2016 ethylene spill in Louisiana was caused by lightning striking a pumping station, leading to pump failure and an eventual fire. In numerous incidents, valves failed due to water seeping into systems from frozen pipes, or large rain events overflowing facility sump pumps. Table 5 below breaks these incidents down by the kind of commodity involved in each case.

Table 5. Shell Pipeline incidents by commodity spill volumes

Commodity Barrels
Crude Oil 51,743
Highly Volatile Liquids 6,066
Gas/Diesel/Fuel 1,156
Petroleum Products 325
Total 59,290

Impacts & Costs

None of Shell’s incidents resulted in fatalities, injuries, or major explosions. However, there is evidence of significant environmental and community impacts. Of 150 incidents that included such data, 76 resulted in soil contamination and 38 resulted in water contamination issues. Furthermore, 78 incidents occurred in high consequence areas (HCAs)—locations along the pipeline that were identified during construction as having sensitive environmental habitats, drinking water resources, or densely populated areas.

Table 6 below shows the costs of the 194 incidents. These numbers are somewhat deceiving as the “Public (other)” category includes such things as inspections, environmental cleanup, and disposal of contaminated soil. Thus, the costs incurred by private citizens and public services totaled more than $80-million.

Table 6. Costs of damage from Shell Pipeline incidents

Private Property Emergency Response Environmental Cleanup Public (other) Damage to Operator Total Cost
$266,575 $62,134,861 $11,024,900 $7,308,000 $102,778,856 $183,513,192

A number of significant incidents are worth mention. For instance, in 2013, a Shell pipeline rupture led to as much as 30,000 gallons of crude oil spilling into a waterway near Houston, Texas, that connects to the Gulf of Mexico. Shell’s initial position was that no rupture or spill had occurred, but this was later found not to be the case after investigations by the U.S. Coast Guard. The image at the top of this page depicts Shell’s cleanup efforts in the waterway.

Another incident found that a Shell crude oil pipeline ruptured twice in less than a year in the San Joaquin Valley, CA. Investigations found that the ruptures were due to “fatigue cracks” that led to 60,000 gallons of oil spilling into grasslands, resulting in more than $6 million in environmental damage and emergency response costs. Concerns raised by the State Fire Marshal’s Pipeline Safety Division following the second spill in 2016 forced Shell to replace a 12-mile stretch of the problematic pipeline, as seen in the image above.

Conclusion

These findings suggest that while Shell is obligated to stress safety to sell the Falcon pipeline to the public, people should take Shell’s “good neighbor” narrative with a degree of skepticism. The numbers presented by PHMSA’s pipeline incident data significantly undermine Shell’s claim of having a proven track record as a safe and responsible operator. In fact, Shell ranks near the top of all US operators for incidents per HVL pipeline mile maintained, as well as damage totals.

There are inherent gaps in our analysis based on data inadequacies worth noting. Incidents dealt with at the state level may not make their way into PHMSA’s data, nor would problems that are not voluntary reported by pipeline operators. Issues similar to what the state of Pennsylvania has experienced with Sunoco Pipeline’s Mariner East 2, where horizontal drilling mishaps have contaminated dozens of streams and private drinking water wells, would likely not be reflected in PHMSA’s data unless those incidents resulted in federal interventions.

Based on the available data, however, most of Shell’s pipelines support one of the company’s many refining and storage facilities, primarily located in California and the Gulf states of Texas and Louisiana. Unsurprisingly, these areas are also where we see dense clusters of pipeline incidents attributed to Shell. In addition, many of Shell’s incidents appear to be the result of inadequate maintenance and improper operations, and less so due to factors beyond their control.

As Shell’s footprint in the Appalachian region expands, their safety history suggests we could see the same proliferation of pipeline incidents in this area over time, as well.

NOTE: This article was amended on 4/9/18 to include table 2.

Header image credit: AFP Photo / Joe Raedle

By Kirk Jalbert, FracTracker Alliance

Mariner East 2: More Spills & Sinkholes Too?

The Mariner East 2 (ME2) pipeline, currently being built by Sunoco Pipeline (Energy Transfer Partners), is a massive 350-mile long pipeline that, if completed, will carry 275,000 barrels of propane, ethane, butane, and other hydrocarbons per day from the shale gas fields of Western Pennsylvania to a petrochemical export terminal located on the Delaware River.

ME2 has faced numerous challenges from concerned citizens since Sunoco first announced plans for the project in 2014. Fights over taking private property by eminent domain, eyebrow raising permit approvals with known technical deficiencies, as well as nearly a hundred drilling mud spills — inadvertent returns (IRs) — at horizontal directional drilling (HDD) sites have occurred since work began in 2017.

This article and the accompanying map brings us up-to-date on the number, location, and status of ME2’s HDD spills. We also summarize the growing list of violations and settlements related to these events. Finally, we highlight the most recent concerns related to ME2’s construction: sinkholes emerging along the pipeline’s path in karst geological formations.

Map of ME2 Updated HDDs, IRs & Karst

The map below shows an updated visual of ME2’s IRs, as of the DEP’s latest tally on March 1, 2018. Included on this map are HDDs where DEP ordered Sunoco reevaluate construction sites to prevent additional spills. Also identified on this map are locations where Sunoco was ordered to notify landowners in close proximity to certain HDDs prior to additional drilling. Finally, the below map illustrates how sinkholes are not a problem unique to one site of construction but are, in fact, common to many areas along ME2’s route. These topics are discussed in greater depth below.

Open the map full-screen to view additional layers not available in the embedded version below.

View Map Fullscreen | How FracTracker Maps Work

HDDs & Inadvertent Returns – Redux

In July 2017, the PA Environmental Hearing Board granted a two week halt to ME2’s HDD operations. The temporary injunction was in response to petitions from the Clean Air CouncilMountain Watershed Association, and the Delaware Riverkeeper Network following IRs­­ at more than 60 sites that contaminated dozens of private drinking water wells, as well as nearby streams and wetlands. FracTracker first wrote about these issues in this prior article.

HDD IR in Washington County
(image: Observer-Reporter)

Despite these issues, and despite Sunoco being cited for 33 violations, ME2 was allowed to proceed under an August 7th agreement that stated Sunoco must reevaluate their HDD plans to minimize additional spills. These studies were to include re-examining the site’s geology and conducting seismic surveys. Sites for reevaluation were selected based on factors such as proximity water supplies, nearby streams and wetlands, problematic geologic conditions, and if an IR had occurred at that site previously. Of ME2’s 230 HDDs, 64 were ordered for reevaluation — 22 of these were selected due to prior IRs occurring at the site.

The DEP mandated that Sunoco’s reevaluation studies be put out for public comment. A table of which HDD studies are currently out for comment can be found here. DEP’s settlement also required Sunoco to notify landowners in proximity to certain HDDs prior to commencing construction due to elevated risks. Of the 64 HDD sites under review, Sunoco must notify 17 residents within 450ft of an HDD site, and 22 residents within 150ft of other sites. The HDD reevaluation sites are shown on the FracTracker map above. Below is an illustration of one site where Sunoco is required to notify landowners within 450ft.

One issue residents have raised with these notifications is that Sunoco is allowed to offer landowners the option to connect their homes to a water buffalo during drilling as an alternative to using their groundwater well. The catch is that, if their well does become contaminated, they would also waive their right to have Sunoco drill them a new replacement well.

“Egregious Violations”

In January 2018, the DEP again suspended ME2’s construction, this time indefinitely revoking their permits, due to even more IRs. DEP also cited Sunoco for “egregious and willful” permit violations —mainly executing HDDs at sites where they had no permission to do so. The DEP noted of their decision that, “a permit suspension is one of the most significant penalties DEP can levy.”

Nevertheless, Sunoco was again allowed to resume construction on February 8, 2018, after paying a $12.6 million fine. The DEP press release accompanying the decision assured the public that, “Sunoco has demonstrated that it has taken steps to ensure the company will conduct the remaining pipeline construction activities in accordance with the law and permit conditions, and will be allowed to resume.”

A few weeks later, Sunoco ran a full-page advertisement in the Harrisburg Patriot-News, shown above, lauding their safety record. Among other notables, the piece boasts, “State and federal regulators spent more than 100 inspection days during 2017 on the Mariner East project, more inspection days than on any other pipeline in Pennsylvania.” Critics have noted that the inordinate number of inspections are due to the comedy of errors associated with ME2’s construction.

Karst Formations & Sinkholes

Which brings us to the current ME2 debacle. Last week, the PA Public Utility Commission (PUC) ordered a temporary shutdown of Mariner East 1 (ME1), another natural gas liquids pipeline owned by Sunoco/ETP. ME1 was built in the 1930s and its right-of-way is being used for most of ME2’s route across the state. This latest construction setback comes in the wake of numerous sinkholes that emerged beginning in December along Lisa Drive in West Whitehead Township, a suburb of Philadelphia in Chester County.

The most recent of these sinkholes grew into a 20ft-deep, 15ft-wide chasm that exposed portions of ME1 and came within 10ft of a house. It is worth noting that, until only a few days ago, ME1 was an operational 8in pipeline with a potential impact radius (aka “blast zone”) of some 500ft. The PUC ordered that Sunoco must now run a line inspection on ME1 for a mile upstream and a mile downstream from the sinkhole sites along Lisa Drive, seen in the image below. Note the proximity of these sinkholes to Amtrak’s Keystone rail lines (connecting Pittsburgh to Philadelphia), under which ME2 also runs. The Federal Railway Administration only recently learned of the sink holes from a nearby resident.

The Lisa Drive sinkholes are being credited to Sunoco executing an HDD in an area known to have karst geological formations. Sunoco has been ordered by the PUC to conduct more geophysical testing and seismic analyses of the area because of this. Karst is often called the “Swiss cheese” of geology — notorious for caves, sinkholes, and underground rivers. As these geological formations change shape, pipelines can bend and settle over time, ultimately leading to potentially dangerous gas leakages or explosions. For instance, the 2015 Atex-1 pipeline explosion in Follansbee, WV, was ultimately determined by the Pipeline and Hazardous Materials Safety Administration (PHSA) as having been caused by ground settling. That explosion released some 24,000 barrels of ethane, burning more than five acres of surrounding land.

The US Geological Survey (USGS) maintains fairly detailed maps of rock formations for most states, including formations known to have karst. In PA, there are a number of “carbonate” rock families known for karst features and settlement issues: limestone and dolostone, and, to a lesser extent, shale. Meanwhile, the PA Department of Conservation and Natural Resources (DCNR) has maintained a record of karst “features” — sinkholes and surface depressions — documented since 1985. A great explanation of the different types of karst features can be found here.

Underestimating the Risks

What is concerning about the Lisa Drive sinkholes is that Sunoco had supposedly already conducted additional karst geological reviews of the area as part of the August DEP settlement, subsequently ranking a nearby HDD (#PA-CH-0219) as “low risk” for running into karst issues—despite knowing the HDD runs through a karst formation with sinkholes and surface depressions in the area. For the HDD that runs the length of Lisa Drive (#PA-CH-0256), the study rated its risk as “very low.” These two HDDs are shown below, along with the area of ME1 now under structural review.

The likely result of these inaccurate assessments led to two IRs at Lisa Drive, one in October and another in November 0f 2017. DEP’s writeup of these events note that the total volume of drilling muds spilled remains unknown because Sunoco didn’t report the incident. Then, only a month later, sinkholes emerged in the same locations. An image of the November HDD IR is shown below.

It is important to note two additional things of Sunoco’s karst study, an except of which is seen in their map of the West Whiteland area below. First, Lisa Drive is just on the edge of a karst limestone formation. USGS data suggest the location is actually mica schist, but the USGS data is also only a rough estimate of different formations. This underscores why pipeline companies must be required to conduct detailed geotechnical analysis of all HDD sites at the onset of their projects.

The other notable aspect of Sunoco’s study is that it does not fully represent all rock formations known to have karst features. In Sunoco’s map, we see orange shading for limestone, but this does not include dolostone that underlies the many surface depressions and sinkholes surrounding West Whiteland. FracTracker’s map includes these formations for greater accuracy.

Takeaways

Interestingly, as Anya Litvak of the Pittsburgh Post-Gazette observed in her reporting on the Lisa Drive incident, Sunoco’s updated karst assessment ranked the entire route of the ME2 pipeline through the state as “low to very low” risk for potential issues. Furthermore, Sunoco has tried to downplay the Lisa Drive incident, stating that “all areas have been secured,” and that additional incidents are unlikely to occur.

But the overall relationship between Mariner East 2’s IRs, HDD sites, and known karst features tells a very different story than Sunoco’s about the potential risks of ME2. In addition to the concerns about new sinkholes near Lisa Drive, FracTracker found the following in our analysis:

  • 7 sinkholes and 386 surface depressions are within 1,500ft of a ME2 HDD site.
  • Of the 230 HDDs, 87 are located in carbonate rock areas (52 in limestone/dolostone, 35 in shale).
  • Of the 99 IRs, 39 have occurred in carbonate rock areas (23 in limestone/dolostone, 16 in shale).

In other words, nearly half of the IRs caused by ME2 HDDs were located in areas known to have karst formations. Worth noting is that an additional 15 occurred in sandstone formations, also known to cause settlement over time. The remaining IRs are split across nine other formation types.

Considering that the DEP’s current review of Sunoco’s ability to safely execute future HDDs are based on the same karst study that missed the Lisa Drive HDD and ranked nearby HDDs as a “low” risk, one can only assume that additional spills will occur. There are many more HDD sites yet to be drilled, and also not likely studied fully for potential karst risks. As illustrated by the continuing saga of spills, violations, and omissions, it is clear that Sunoco has not maintained a high standard of construction in building ME2 from the onset.

We thank Eric Friedman from the Middletown Coalition for Community Safety for supplying photos of the Lisa Drive site used in this article.

By Kirk Jalbert, FracTracker Alliance

Falcon Public EIA Project feature image

Wingspan of the Falcon Pipeline

A Public EIA of Shell’s Ethane Cracker Pipeline

Pittsburgh, Pennsylvania – Jan. 29 – FracTracker Alliance has released a detailed environmental impact assessment (EIA), including digital maps, of the Falcon Ethane Pipeline being built to feed Shell Appalachia’s ethylene cracker plant in Beaver County, PA.

FracTracker’s Falcon Public EIA Project offers a rich series of interactive maps and articles detailing the Falcon’s proposed route through PA, WV, and OH, likely impacts to waterways, potential blast zones, ecological footprint, proximity to hazardous industrial areas, and more.

Given the issues associated with Mariner East 2 – a PA-based natural gas liquids pipeline whose history has been fraught with citations, public scrutiny is a crucial facet of pipeline construction. The Falcon Public EIA Project represents the first time that public stakeholders have been given such a significant amount of time and detail to investigate a proposed pipeline, including access to specific location information. Public comments are being accepted by the PA Department of Environmental Protection on the Falcon’s permit until February 20th.

“Companies are generally not required to publicly disclose GIS data when applying for permits,” remarked Kirk Jalbert, project lead and Manager of Community Based Research and Engagement at FracTracker. “While concerned citizens can stitch together paper maps provided by companies in their applications, that process can be complex and very labor intensive.”

With FracTracker’s project, however, digital maps and figures are front and center.

Early access to what is being proposed for the Falcon pipeline will enable nearby communities to better understand how its construction and the associated ethane cracker facility, which will produce 1 million tons of ethylene annually for making plastics, will affect their lives. Upon analyzing the data, FracTracker uncovered a number of particularly noteworthy statistics, for example:

  • There are 97.5 miles of pipeline proposed to be built through 22 townships in 3 states.
  • 2,000 properties have been surveyed; 765 easements executed.
  • Falcon will intersect 319 streams and 174 wetlands, with hundreds more proximate to work areas.
  • 550 family residences, 20 businesses, 240 groundwater wells, 12 public parks, 5 schools, 6 daycare centers, and 16 emergency response centers are within potential risk areas.
  • Learn more

“Extreme levels of risk and injustice are commonplace in petrochemical pipeline siting, as well as in where their contents come from and how they get used. This project provides context for the importance of reducing these impacts, both for curtailing environmentally unfriendly plastics as well as for moving away from fossil fuel dependencies,” said Brook Lenker, Executive Director of FracTracker.

The Falcon Public EIA Project is meant to expand public dialogue about what should be included in EIAs and how they should apply to petrochemical pipelines. The project also serves as a model for how regulatory agencies can be more transparent with data when engaging the public. This is especially important in the case of the Falcon pipeline, which will be exempt from Federal Energy Regulatory Commission (FERC) scrutiny and, therefore, not be subject to a full environmental impact assessment.

The Falcon: Routes, Facilities & Easements

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project, we first focus on the route of the pipeline and prior routes that were considered. We take a closer look at the properties along the route that required easement agreements from landowners. Finally, we locate facilities that will be built as part of the project, such as metering stations and shut-off valves, as well as the pipeline’s construction areas and access roads.

Quick Falcon Facts

  • 97.5 miles of proposed pipeline (an additional 200+ miles surveyed during the process)
  • 2,000 parcels of land surveyed; 765 easements executed; 469 will be needed to execute the route
  • Five meter pads and 18 shut-off valves
  • 111 temporary access roads, 21 permanent access roads
  • 1,273 acres required for construction space; 650 acres for the permanent right-of-way

Map of Falcon pipeline routes, properties, and facilities

The following map will serve as our guide in breaking down these first components. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible at closer zoom levels. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work


Finding a Right-of-Way

Pipeline operators must consider a variety of factors when searching for a viable right of way (ROW) for their project—the continuous stretch of land needed to construct, maintain, and operate the pipeline. This process begins with reviewing data and maps made available by federal, state, and local agencies in order to identify features that would complicate the project. These might include such things as protected wetlands, drinking water sources, abandoned mines, or heavily populated areas.

A second step is to conduct manual field surveys along their planned route. During this stage, engineers do precise measurements to determine how the pipeline will cross individual properties as well as locate site-specific concerns that need to be accounted for, such as the presence of endangered species or archeological sites. FracTracker previously produced a guide to pipeline surveying, which can be found here.

The process of finding a viable pipeline route can undergo dozens of revisions and take months or years to complete. The example image seen below, taken from our interactive map at the top of the page, shows a few of the many different 50ft. ROWs considered by Shell. These were documented every few months as the data changed.

A section of the Falcon route with prior routes considered

The most recent route is highlighted in red, totaling 97.5 miles (Shell’s original press releases stated 94 miles). Segments that represent alternative routes considered in certain places are shown in blue (these earlier divergences total 19 miles). Other areas surveyed at some point in the process are shown in dotted purple (totaling 91.3 miles). Given that the route has changed very little in recent months, as well as the fact that Shell has submitted their permit applications for project, we believe that the route in red is likely the route proposed to regulatory agencies.

Note that, in the interactive map, there is an additional “Air Liquide” pipeline (this is the name of a gas products company) proposed by Shell that will run from the ethane cracker south for about .5 miles. Based on comments made by Shell at public hearings, we assume this will be a nitrogen pipeline feeding the plant from an unknown source.

Acquiring Easements

Perhaps the most significant factor that can determine a pipeline route is finding landowners amenable to having their land surveyed and, ultimately, willing to sign easements to allow the pipeline on their property. In some instances, pipeline companies can be granted eminent domain as a “public utility” to take land by force (ME2). However, Shell has stated publicly that eminent domain in not an option for Falcon, due to the fact that the pipeline services a private facility. FracTracker previously produced a guide for landowners who might be approached by pipeline operators seeking to survey their properties.

The Falcon pipeline will have a permanent ROW of 50ft that will cross 10 municipalities in Pennsylvania, 12 townships in Ohio, as well as northern Hancock County, West Virginia. More than 2,000 individual parcels of land were surveyed across this region. Of those 2,000, Shell approached landowners for 765 unique parcels at some point in the process to obtain easements, either for the pipeline ROW itself or for access roads.

To date, Shell has executed 572 easements. Of these, 469 will be needed to execute the current proposed route. However, as of this time, 14 parcels along the proposed route are still listed as “landowner contacted,” meaning that the easement has not yet been executed. The image below is a page from Shell’s permit applications to the PA DEP listing properties pending in Pennsylvania.

Pending PA easements from Shell’s permit applications

Media sources have reported on some of the details of Shell’s Pipeline easement agreements. In some instances, contracts stated a transactional price of $10 per linear foot as a “placeholder” to get the process started. In other cases, Shell has paid landowners as much as $75 per linear foot of pipeline. These agreements also state that Shell reserved the right to “lay, construct, test, maintain, inspect, operate, repair, renew, relocate, replace, substitute, change the size of, upgrade, alter, mark, protect and remove or abandon in place” any pipelines on the property. Below is an example of how our interactive map represents these parcels and their status. For instance, executed easements are in green and pending or stalled agreements in yellow.

Parcels along the Falcon route and their easement status

Valves & Metering Stations

Pipelines require a number of facilities to properly manage the flow and pressure of gas from one end of the line to another. For instance, metering stations are installed to measure how much gas is in the pipeline system at given points. Falcon has five “pads” where metering stations will be located. Three of these are co-located at the origin points of the pipeline (the MarkWest separator facilities) and a fourth at the ethane cracker end-point. However, the fifth meter stations will be located where the two legs of the pipeline meet in northeast Raccoon Township, Beaver County, PA. This site is called the “Junction” meter pad.

Shut-off valves will also placed along the route—18 in all for Falcon—in order to section off lengths of the pipeline that can be turned off as needed. These valves will be located at fairly regular intervals of 8-10 miles in most places, but are also found just before and after sensitive locations, such as the Oho River crossing and areas and where the lines juncture.

The Risks of Proximity

Metering stations and shut-off valves bring particular risks. For instance, when valves are closed at a section of pipeline for maintenance, or in the event of an emergency, excess gasses must vented to relieve pressure. This is one reason why communities have become concerned about the location of these facilities, such as with a Mariner East 2 pipeline valve in West Goshen Township, PA. Similarly, the Falcon pipelines’ valve in New Somerset, OH, is especially close to residential areas, seen below.

A proposed Falcon shut-off valve site in New Somerset, Ohio

Workspaces & Access Roads

Finally, pipeline operators must identify in their permit applications the “workspace” needed for construction. Shell’s temporary ROW for workspace is approximately 100ft in most stretches along the Falcon’s route, similar to what is shown in the image below. Site-specific conditions, such as road, railroad crossings, and buildings make the workspace narrower in some instances, but much larger workspaces will be needed around sites like metering stations and shut-off valves.

A typical pipeline workspace; this one from the Mariner East 2

The locations of access roads must also be identified in permit applications. Access roads come in two categories and typically require a 25ft ROW. Temporary access roads are used during the construction process and often utilize existing private driveways, farm roads, or are built after clearing land acquired in the easement process. Permanent roads allow long-term access to facilities, such as valves and pumping stations, as well as for bringing in equipment to maintain the pipeline’s ROW. Shell’s plan proposes 111 temporary access roads (28 miles) and 21 permanent access roads (2.3 miles).

Shell’s permit applications state that the total disturbed workspace needed for construction and access roads is approximately 1,273 acres. About half of this will remain cleared for the permanent right-of-way and permanent access roads.

A Closer Look

When a pipeline project is subject to regulatory review, alternative routes are typically offered up by the operator for consideration in weighing different costs and benefits. Major reroutes typically deviate from the proposed route for significant distances in order to avoid significant impediments such as large cities or protected lands. Minor alternatives are shorter in length and used to avoid specific areas of concern, such as a protected wetland. An alternative route might also be selected in order to utilize an existing ROW from other pipelines.

Ohio River Crossing

As noted, there are a number of places along the Falcon route where we see examples of major route changes. Many of these reroutes appear to be due to landowners along the preferred path not signing easements for one reason or another. One of the more significant change occurred at the location where the Falcon crosses the Ohio River in Hancock County, West Virginia, seen below. For many months, Shell’s maps showed a planned crossing south of the current proposed route, but later took a dramatic diversion to the north, apparently due to an easement not having been executed for a single property. What is notable about the new route is that it utilizes property owned by the popular Mountaineer Casino, Racetrack, and Resort.

The current and former Falcon route crossing the Ohio River

Fort Cherry Golf Course Reroute

In another instance, we see a reroute near the Fort Cherry Golf Course in McDonald, Washington County, PA. An earlier route took the Falcon straight through the course, whereas the current proposed route goes further east, disrupting a smaller number of fairways. Notice in the image below that a temporary access road for the pipeline’s construction will also still utilize Fort Cherry Golf Course’s driveway.

The current and former Falcon routes crossing the Ft. Cherry Golf Course

Montour Trail Intersections

Finally, we bring attention to what appears to be some of the few remaining properties with easements not yet settled in order to begin construction. As noted in the excerpt from Shell’s permit application at the top of this page, a number of parcels owned by the Montour Trail Council have a status of: “in negotiation and depended on submitted crossing permit applications,” presumably meaning they would agree to the easement if PA DEP approved Shell’s permits.

Falcon intersections with the Montour Trail

The Montour Trail is a 46-mile long multi-use non-motorized recreational rail-trail located in Washington and Allegheny County, PA, used by more than 400,000 people annually. It also makes up part of the Great Allegheny Passage (GAP), a trail system that stretches over 335 miles from Pittsburgh to Washington, DC. The trail is managed by the nonprofit Montour Trail Council with support from state agencies such as the Pennsylvania Department of Conservation and Natural Resources (DCNR).

We were surprised to find that the Montour Trail will be crossed by the Falcon in 9 locations: 5 by the pipeline itself, 3 by temporary access roads, and 1 by a permanent access road, as illustrated in the image above. Two of the pipeline intersections will be executed using HDD boring. The trail and its intersection with the Falcon can be seen by activating these layers on FracTracker’s interactive map, as illustrated in the image above.

 

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Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Water Crossings & Hazards

Part of the Falcon Public EIA Project

In this section of the Falcon Public EIA Project, we explore the hydrological and geological conditions of the pipeline’s construction areas. We first identify the many streams, wetlands, and ponds the Falcon must cross, as well as describe techniques Shell will likely use in these water crossings. The second segment of this section highlights how the areas in the Falcon’s path are known for their complex geological features, such as porous karst limestone and shallow water tables that can complicate construction.

Quick Falcon Facts

  • Intersects 319 streams; 361 additional streams located only 500ft from construction areas
  • Intersects 174 wetlands; 470 additional wetlands located only 500ft from construction areas
  • Majority of crossings will be open cuts and dry-ditch trenching
  • A total of 19 horizontal directional drilling (HDD) sites; 40 conventional boring sites
  • 25 miles of pipeline overlap karst limestone formations, including 9 HDD sites
  • 240 groundwater wells within 1/4 mile of the pipeline; 24 within 1,000ft of an HDD site

Map of Falcon water crossings and hazards

The following map will serve as our guide in breaking down the Falcon’s risks to water bodies. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional features of the map are not shown by default, but can be turned on in the “layers” tab. These include information on geological features, water tables, soil erosion characteristics, as well as drinking reservoir boundaries. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

Defining Water Bodies

The parts of Pennsylvania, West Virginia, and Ohio where the Falcon pipeline will be built lie within the Ohio River Basin. This landscape contains thousands of streams, wetlands, and lakes, making it one of the most water rich regions in the United States. Pipeline operators are required to identify waters likely to be impacted by their project. This two-step process involves first mapping out waters provided by the U.S. Geological Survey’s national hydrological dataset. Detailed field surveys are then conducted in order to locate additional waters that may not yet be accounted for. Many of the streams and wetlands we see in our backyards are not represented in the national dataset because conditions can change on the ground over time. Yet, plans for crossing these must also be present in pipeline operator’s permit applications.

Streams

Streams (and rivers) have three general classifications. “Perennial” streams flow year-round, are typically supplied by smaller up-stream headwaters, and are supplemented by groundwater. In a sense, the Ohio River would be the ultimate perennial stream of the region as all smaller and larger streams eventually end up there. “Intermittent” streams flow for only a portion of the year and are dry at times, such as during the summer when water tables are low. Finally, “ephemeral” streams flow only during precipitation events.

These classifications are important because they can determine the extent of aquatic habitat that streams can support. Working in streams that have no dry period can put aquatic lifeforms at elevated risk. For this and other reasons, many states further designate streams based on their aquatic life “use” and water quality. In Pennsylvania, for instance, the PA DEP uses the designations: Warm Water Fishes (WWF), Trout Stocked (TSF), Cold Water Fisheries (CWF) and Migratory Fishes (MF). Streams with exceptional water quality may receive an additional designation of High Quality Waters (HQ) and Exceptional Value Waters (EV).

Wetlands

Similar to streams, wetlands also have unique designations. These are based on the U.S. Fish and Wildlife Services’ national wetlands inventory. Wetlands are generally defined as “lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water.” As such, wetlands are categorized by their location (such as a tidal estuary or an inland wetland that lacks flowing water), its substrate (bedrock, sand, etc.), and plant life that might be present. While there are hundreds of such categories, only four pertain to the wetlands present in the regions where the Falcon pipeline will be built. Their designations roughly translate to the following:

  • Palustrine Emergent (PEM): Marshes and wet meadows hosting perennial small trees, shrubs, mosses, or lichens
  • Palustrine Shrub (PSS): Similar to PEMs, but characterized by also having well-established shrubs
  • Palustrine Forested (PFO): Similar to PEMs and PSSs, but having trees larger than 6 meters high
  • Palustrine Unconsolidated Bottom (PUB) and Palustrine Opem Water (POW) (aka ponds)

Pipeline operators are required to report the crossing length of each wetland they will encounter, as well as the area of permanent and temporary disturbance that would occur in each of these wetlands. When building the pipeline, operators are required to ensure that all measures are taken to protect wetlands by minimizing impacts to plant life, as well as by taking “upland protective measures” to prevent sedimentation runoff during precipitation events. When undergoing FERC EIA scrutiny, operators are also required to limit the width of wetland construction areas to 75 feet or less.

Crossing Methods

Open-Cut Trenching

Pipeline operators use a variety of methods when crossing streams, wetlands, and ponds. Shorter length crossings often employ a rudimentary trench. After the cuts, construction crews attempts to repair damage done in the process of laying the pipeline. For longer crossings, operators can use boring techniques to go underneath water features.

Open-cut trenching

There are two general types of trenches. The first, “open-cut” crossings, are typically used for smaller waterbodies, such as in intermittent streams where flow may not be present during time of construction, or when construction can be completed in a short period of time (typically 24-48 hours). In this process, a trench is laid through the water body without other provisions in place.

The second type, “dry-ditch” crossing, are required by FERC for waterbodies up to 30 feet wide “that are state-designated as either coldwater or significant coolwater or warmwater fisheries, or federally-designated as critical habitat.” In these spaces, pumps are used to transfer stream flow around the area where trenching occurs. In places where sensitive species are present, dry-ditches must include a flume to allow these species to pass through the work area.

Conventional Boring

Conventional boring consists of creating a tunnel for the pipeline to be installed below roads, waterbodies, and other sensitive resources. Bore pits are excavated on either sides of the site. A boring machine is then used to tunnel under the resource and the pipeline is pushed through the bore hole.

Horizontal Directional Drilling

In more difficult or lengthy crossings, operators may choose to bore under a water feature, road, or neighborhood. Horizontal directional drilling (HDD) involves constructing large staging areas on either side of the crossing. A large drill bit is piloted through the ground along with thousands of gallons of water and bentonite clay for lubricant (commonly referred to as drilling muds). HDDs are designed to protect sensitive areas, but operators prefer not to use them as HDDs can be expensive and require in-depth planning in order for things to go well.

Bentonite sediment pollutes a stream at a Mariner East HDD spill site
(source: Washington, PA, Observer-Reporter)


An example of what happens when things are rushed can be seen in Sunoco’s Mariner East 2 pipeline. The PA DEP has cited Sunoco for over 130 inadvertent returns (accidental releases of drilling muds) since construction began. These spills led to damaged water wells and heavy sedimentation in protected streams, as exemplified in the image above. Making matters worse, Sunoco later violated terms of a settlement that required them to re-survey before recommencing construction. See FracTracker’s article on these spills.

Footprint of the Falcon

The overwhelming majority of Falcon’s water body crossings will be executed with either open-cut or dry-ditch methods. There are 40 locations where conventional boring will be used, but only a 3 are used for crossing water resources. Shell intends to use 19 HDDs and, of these, only 13 are used for crossing water bodies of some kind (the longest of which crosses the Ohio River). All other conventional and HDD boring locations will be used to cross under roads and built structures. This is not entirely unusual for pipelines. However, we noted a number of locations where one would expect to see HDDs but did not, such as in the headwaters of the Ambridge and Tappen Reservoirs, as was seen in the images above.

Stream Impacts

Shell identified and/or surveyed a total of 993 stream sections in planning for the Falcon’s construction. As shown on FracTracker’s map, the pipeline’s workspace and access roads will directly intersect 319 of these streams with the following classifications: perennial (96), ephemeral (79), and intermittent (114). An additional 361 streams are located only 500ft from construction areas.

A number of these streams have special designations assigned by state agencies. For instance, in Pennsylvania, we found 10 stream segments listed as Trout Stocked (TS), which are shown on our interactive map.

Crossing HQ headwater streams of the Ambridge Reservoir

Perhaps more concerning, the Falcon will cross tributaries to the Service Creek watershed 13 times. These feed into three High Quality Cold Water Fishes (HQ/CWF) headwater streams of the Ambridge Reservoir in Beaver County, PA, shown in the image above. They also support the endangered Southern Redbelly Dace (discussed in greater depth here). On the eastern edge of the watershed, the Falcon will cross the raw water line leading out of the reservoir.

The reservoir supplies 6.5 million gallons of water a day to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). This includes drinking water services to 30,000 people.

We found a similar concern in Ohio where the Falcon will cross protected headwaters in the Tappan Reservoir watershed at six different locations. The Tappan is the primary drinking water source for residents in Scio. Below is a page from Shell’s permit applications to the PA DEP outlining the crossing of one of the Ambridge Reservoir’s CWF/HQ headwater streams.

Wetland Impacts

Shell identified a total of 682 wetland features relevant to Falcon’s construction, as well as 6 ponds. Of these, the pipeline’s workspace and access roads will directly intersect 174 wetlands with the following classifications: PEM (141), PSS (13), PFO (7), PUB (10), POW (3). An additional 470 of these wetlands, plus the 6 ponds, are located only 500ft from construction areas.

Example 1: Lower Raccoon Creek

A few wetland locations stand out as problematic in Shell’s construction plans. For instance, wetlands that drain into Raccoon Creek in Beaver County will be particularly vulnerable in two locations. The first is in Potter Township, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland of approximately 14 acres in size, seen below. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides, shown in the first map below in dotted red.

Landslide areas along Raccoon Creek wetlands and streams

This area is also characterized by the USGS as having a “high hazard” area for soil erosion, as seen in this second image. Shell’s engineers referenced this soil data in selecting their route. The erosion hazard status within 1/4 mile of the Falcon is a layer on our map and can be activated in the full-screen version.

Shell’s permit applications to the PA DEP requires plans be submitted for erosion and sedimentation control of all areas along the Falcon route. Below are the pages that pertain to these high hazard areas.

Example 2: Independence Marsh

The other wetland area of concern along Raccoon Creek is found in Independence Township. Here, the Falcon will go under the Creek using horizontal drilling (highlighted in bright green), a process discussed in the next section. Nevertheless, the workspace needed to execute the crossing is within the designated wetland itself. An additional 15 acres of wetland lie only 300ft east of the crossing but are not accounted for in Shell’s data.

This unidentified wetland is called Independence Marsh, considered the crown jewel of the Independence Conservancy’s watershed stewardship program. Furthermore, the marsh and the property where the HDD will be executed are owned by the Beaver County Conservation District, meaning that the CCD signed an easement with Shell to cross publicly-owned land.

Independence Marsh, unidentified in Shell’s survey data

 

Groundwater Hazards

The Falcon’s HDD locations offer a few disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys prior to drilling that failed to identify karst limestone formations and shallow groundwater tables, which then led to drilling muds entering nearby streams and groundwater wells.

Karst Limestone

Karst landscapes are known for containing sinkholes, caves, springs, and surface water streams that weave in and out of underground tunnels. Limestone formations are where we are most likely to see karst landscapes along the Falcon’s route.

In fact, more than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. However, only three of these HDDs sites are identified in Shell’s data as candidates for potential geophysical survey areas. The fact that the geology of the other 10 HDD sites will not be investigated is a concern.

One site where a geophysical survey is planned can be seen in the image below where the Falcon crosses under PA Highway 576. Note that this image shows a “geological formations” layer (with limestone in green). This layer shows the formation types within 1/4 mile of the Falcon and can activated in the full-screen version of our interactive map.

A potential HDD geophysical survey area in karst limestone

Water Tables

We also assessed the Falcon’s HDDs relative to the groundwater depths and nearby private groundwater wells. The USGS maintains information on minimum water table depths at different times of the year. In the image below we see the optional “water table depth” layer activated on the FracTracker map. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.

Shallow groundwater and private wells near a planned HDD site

Groundwater Wells

Also seen in the above image is the “groundwater wells” layer from the FracTracker map. We found 240 private water wells within 1/4 mile of the Falcon. This data is maintained by the PA Department of Natural Resources as well as by the Ohio Department of Natural Resources. Comparable GIS data for West Virginia were not readily available thus not shown on our map.

While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to HDD sites deserve particular attention. In fact, Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site. We’ve isolated the groundwater wells and HDD sites in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.

View Map Fullscreen | How FracTracker Maps Work

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Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Class Locations, Buildings & Recreational Areas

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project we begin to explore the different ways that pipelines are assessed for potential risk to populated areas. We outline a methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called Class Locations. This methods identifies occupied structures in proximity to a pipeline.

Quick Falcon Facts

  • 67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3.
  • More than 557 single family residences and 20 businesses within 660ft of the pipeline.
  • Three recreational parks and a planned luxury housing development also at risk.

Map of Falcon Class Locations

The following map will serve as our guide in breaking down the Falcon’s Class Locations. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.



View Map Fullscreen | How FracTracker Maps Work

Pipeline Class Locations

Pipeline “Class locations” determine certain aspects of how a pipeline is constructed. Essentially, a pipeline’s route is segmented into lengths that are each given different classifications as outlined in PHMSA guidelinesIn general terms, a segment’s Class is established by first calculating a buffer that extends 220 yards (660ft) on either side of the pipeline’s center in 1-mile continuous lengths. This buffer area is then analyzed for how many building structures are present. Classes are then assigned to each 1-mile segment using the follow criteria:

  • Class 1: a segment with 10 or fewer buildings intended for human occupancy
  • Class 2: a segment with more than 10, but less than 46 buildings intended for human occupancy
  • Class 3: a segment with 46 or more buildings intended for human occupancy, or where the pipeline lies within 100 yards of any building, or small well-defined outside area occupied by 20 or more people on at least 5 days a week for 10 weeks in any 12-month period (i.e. schools, businesses, recreation areas, churches)
  • Class 4: a segment where buildings with four or more stories aboveground are prevalent

The finer details of these calculations and their adjustments are complex, however. For instance, Class locations can be shortened to less than 1-mile lengths if building densities change dramatically in an certain area. The example image below shows one of the ways available to operators for doing this, called the “continuous sliding” method:

Calculating Class Locations
(source: PHMSA)

Class location designations may also be adjusted over time as densities change. For instance, if new homes were built in proximity to a previously constructed pipeline, the operator may be required to reduce their operating pressure, strengthen the pipeline, or conduct pressure tests to ensure the segment would technically meet the requirements of a higher Class. Alternatively, operators can apply for a special permit to avoid such changes.

What Class Locations Dictate

Pipeline segments with higher Classes must meet more rigorous safety standards, which are enforced either by PHMSA or by their state equivalent, such as the Pennsylvania Utility Commission. These include:

  • Soil depth: Class 1 locations must be installed with a minimum soil depth of 30 inches (18 inches in consolidated rock). Class 2, 3, and 4 locations require a minimum soil depth of 36 inches (24 inches in consolidated rock)
  • Shut-off valves: Class locations determine the maximum distance from shut-off valves to populated areas, as follows: Class 1 (10 miles), Class 2 (7.5 miles), Class 3 (4 miles), and Class 4 (2.5 miles).
  • Operating pressure: Classes also regulate the maximum allowable operating pressure (MAOP) of pipeline segments
  • Structural integrity: Classes determine where thicker walled materials must be used to withstand higher pressures, as well as different structural testing methods used in safety inspections

By replicating the 600 foot buffer from the Falcon’s centerline (used as the standard distance for determining Class Locations) we found that 67% of the Falcon route will qualify as Class 1, 27% as Class 2, and 3% as Class 3. These are represented on our interactive maps as green, yellow, and orange segments, respectively. An additional segment is marked as having an “unknown” Class on our maps (shaded in gray). This is the stretch crossing the Ohio River, where Shell’s Class location analysis has not been updated to reflect the route change that occurred in the summer of 2017.

Residential Structures

In total, there are 557 single family residences, 20 businesses, and a church within the 660ft buffer. Shell’s data also identify non-occupied structures along the route, such as sheds, garages, and other outbuildings. There are 535 such structures, but we did not have the time to replicate the locations of these sites. It is also important to note that the points on our interactive map represent only those identified by Shell, which we believe is an incomplete assessment of occupied structures based on our quick review of satellite maps.

Three residential structures lie directly within the 50-foot right-of-way. One of these homes, located in a Class 2 segment in Independence Township, is shown below. The Falcon will come as close as 20 feet to the edge of the structure and surround the home on three sides.

An occupied residence in the right-of-way

Neighborhoods in the following five communities account for the entirety of Falcon’s Class 3 locations. These would be considered the most “at risk” areas along the route in terms of proximity to the number of occupied structures. For instance, below is a satellite view of the Class 3 section of Raccoon Township.

  • Rumley Township, Harrison OH
  • Knox Township, Jefferson County OH
  • Raccoon Township, Beaver County PA
  • Independence Township, Beaver County PA
  • Mount Pleasant Township, Washington County PA

Raccoon Township residences & Municipal Park in a Class 3

Recreational Areas

In the above image we also see the location of Raccoon Township Municipal Park (in purple), home to a number of ballfields. Two similar recreation areas are located in the 660ft Class Location buffer: Mill Creek Ballpark, in Beaver County PA, and Clinton Community Park, in Allegheny County PA.

However, the Raccoon Township park is notable in that the Falcon cuts directly through its property boundary. Shell intends to bore under the park using HDD techniques, as stated in their permit applications, “to avoid disturbance to Beaver County baseball field/recreational park,” also stating that, “this HDD may be removed if the recreational group will allow laying the pipeline along the entrance roadway.”

New Housing Developments

One discovery worth attention is that the Falcon runs straight through an under-construction luxury housing development. Located in Allegheny County, PA, its developer, Maronda Homes, bills this growing community as having “picturesque landscapes, waterfront views and a peaceful collection of homes.” Shell mentions this development in their permit applications, stating:

Maronda Homes is in the planning and design stage of a very large housing development and SPLC [Shell Pipeline LC] worked closely with the developer and the Project was rerouted to avoid most of the housing sites.

It stands to reason that this neighborhood will eventually rank as one of the densest Class 3 areas along the Falcon route. Whether or not the pipeline is updated with higher safety standards as a result remains to be seen. The image below illustrates where the Falcon will go relative to lots marked for new homes. This property lots diagram was obtained from Shell’s GIS data layer and can be viewed on the FracTracker interactive map as well.

The Falcon intersects a luxury home development

1/31/18 Note: the Pittsburg Post-Gazette obtained newer lot line records for a portion of the Maronda Farms during their investigation into this story. These new records appear to have some alterations to the development, as seen below.

Maronda Farms, updated lot lines

Issues with Setbacks

There are no setback restrictions for building new homes in proximity to a pipeline. Parcels will eventually be sectioned off and sold to home buyers, begging the question of whether or not people in this community will realize a hazardous liquid pipeline runs past their driveways and backyards. This is a dilemma that residents in a similar development in Firestone, Colorado, are now grappling with following a recent pipeline explosion that killed two people, seen below, due to inadequate building setbacks.

A pipeline explodes in a Colorado home development
(source: InsideEnergy, CO)

Interestingly, we researched these same Maronda Farms parcels in FracTracker’s Allegheny County Lease Mapping Project only to discover that Maronda Homes also auctioned off their mineral rights for future oil and gas drilling. New homeowners would become victims of split-estate, where drilling companies can explore for oil and gas without having to seek permission from property owners, amplifying their level of risk.

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Related Articles

The Falcon: High Consequence Areas & Potential Impact Zones

Part of the Falcon Public EIA Project

In this segment of the Falcon Public EIA Project we continue to explore the different ways that pipelines are assessed for potential risk – in this case, relative to population centers, drinking water systems, and sensitive habitats. We outline methods dictated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) called “high consequence areas” (HCAs) and how they determine potential impact zones for highly volatile liquid (HVL) pipelines. These methods are then applied to the Falcon to understand its possible dangers.

Quick Falcon Facts

  • An estimated 940-foot potential impact radius (PIR)
  • 60 of 97 pipeline miles qualifying as High Consequence Areas (HCA)
  • More than 8,700 people living in the “vapor zone”
  • 5 schools, 6 daycare centers, and 16 emergency response centers in “vapor zone”
  • In proximity to 8 source-water (drinking water) protection areas
  • Affecting habitats populated by 11 endangered, protected, or threatened species

Map of Falcon High Consequence Areas

The following map will serve as our guide in breaking down the Falcon’s High Consequence Areas. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

High Consequence Areas

While Class Locations, discussed in a prior project article, dictate the construction and maintenance of a pipeline, high consequence areas (HCAs) designate when operators must implement integrity management programs (IMP) where pipeline failures could cause major impacts to populated areas, as well as drinking water systems and ecological resources — otherwise defined as unusually sensitive areas (USAs).

Populated Areas

Two considerations are used when determining pipeline proximity to population centers:

  1. High Population Areas – an urbanized area delineated by the Census Bureau as having 50,000 or more people and a population density of at least 1,000 people per square mile; and
  2. Other Populated Areas – a Census Bureau designated “place” that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or other designated residential or commercial area – including work camps.

USAs: Drinking Water

PHMSA’s definition of drinking water sources include things such as:

  • Community Water Systems (CWS) – serving at least 15 service connections and at least 25 year-round residents
  • Non-transient Non-community Water Systems (NTNCWS) – schools, businesses, and hospitals with their own water supplies
  • Source Water Protection Areas (SWPA) for a CWS or a NTNCWS
  • Wellhead Protection Areas (WHPA)
  • Sole-source karst aquifer recharge areas

These locations are typically supplied by regulatory agencies in individual states.

With the exception of sole-source aquifers, drinking water sources are only considered if they lack an alternative water source. However, PHMSA is strict on what alternative source means, stating that they must be immediately usable, of minimal financial impact, with equal water quality, and capable of supporting communities for at least one month for a surface water sources of water and at least six months for a groundwater sources.

One very important note in all of these “drinking water” USA designations is that they do not include privately owned groundwater wells used by residences or businesses.

USAs: Ecological Resource

Ecological resource areas are established based on any number of qualities with different variations. In general terms, they contain imperiled, threatened, or endangered aquatic or terrestrial species; are known to have a concentration of migratory waterbirds; or are a “multi-species assemblage” area (where three or more of the above species can be found).

Calculating HCAs

Like Class locations, HCAs are calculated based on proximity. The first step in this process is to determine the pipeline’s Potential Impact Radius (PIR) — the distance beyond which a person standing outdoors in the vicinity of a pipeline rupture and fire would have a 99% chance of survival; or in which death, injury, or significant property damage could occur. PIR is calculated based on the pipeline’s maximum allowable operating pressure (MAOP), diameter, and the type of gas. An example of this calculation is demonstrated in FracTracker’s recent article on the Mariner East 2 pipeline’s PIR.

Once the PIR is known, operators then determine HCAs in one of two ways, illustrated in the image below:

  • Method 1: A Class 3 or Class 4 location, or a Class 1 or Class 2 location where “the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy”; or a Class 1 or Class 2 location where “the potential impact circle contains an “identified site.”
  • Method 2: An area within PIR containing an “identified site” or 20 or more buildings intended for human occupancy.

Calculating HCAs
(source: PHMSA)

In these definitions, “identified sites” include such things as playgrounds, recreational facilities, stadiums, churches, office buildings, community centers, hospitals, prisons, schools, and assisted-living facilities. However, there is a notable difference in how HCAs are calculated for natural gas pipelines vs. hazardous liquid pipelines.

Beyond just looking at what lies within the PIR, pipelines that contain gasses such as ethane potentially impact a much broader area as vapors flow over land or within a river, stream, lake, or other means. A truly accurate HCA analysis for an ethane pipeline leak requires extensive atmospheric modeling for likely vapor dispersions, such as seen in the example image below (part of a recent ESRI GIS conference presentation).

Vapor dispersion modelling
(source: TRC Solutions)

 

What HCAs Dictate

HCAs determine if a pipeline segment is included in an operator’s integrity management program (IMP) overseen by PHMSA or its state equivalent. IMPs must include risk assessments that identify the most likely impact scenarios in each HCA, enhanced management and repair schedules, as well as mitigation procedures in the event of an accident. Some IMPs also include the addition of automatic shut-off valves and leak detection systems, as well as coordination plans with local first responders.

The Falcon Risk Zones

Shell’s permit applications to the PA DEP state the pipeline:

…is not located in or within 100 feet of a national, state, or local park, forest, or recreation area. It is not located in or within 100 feet of a national natural landmark, national wildlife refuge, or federal, state, local or private wildlife or plant sanctuaries, state game lands. It is also not located in or within 100 feet of a national wild or scenic river, the Commonwealth’s Scenic Rivers System, or any areas designated as a Federal Wilderness Area. Additionally, there are no public water supplies located within the Project vicinity.

This is a partial truth, as “site” and “vicinity” are vague terms here. A number of these notable areas are within the PIR and HCA zones. Let’s take a closer look.

The PIR (or “Blast Zone”)

Shell’s permit applications state a number of different pipeline dimensions will be used throughout the project. Most of the Falcon will be built with 12-inch steel pipe, with two exceptions: 1) The segment running from the Cadiz, OH, separator facility to its junction with line running from Scio, OH, will be a 10-inch diameter pipe; 2) 16-inch diameter pipe will be used from the junction of the Falcon’s two main legs located four miles south of Monaca, PA, to its end destination at the ethane cracker. We also know from comments made by Shell in public presentations that the Falcon’s maximum allowable operating pressure (MOAP) will be 1,440 psi. These numbers allow us to calculate the Falcon’s PIR which, for a 16″ ethane pipeline at 1,440psi, is about 940 feet. We’ve termed this the “blast zone” on our maps.

The HCA (or “Vapor Zone”)

Shell’s analysis uses an HCA impact radius of 1.25 miles. This much larger buffer reflects the fact that vapors from hazardous liquid pipelines can travel unpredictably at high concentrations for long distances before ignition. This expanded buffer might be called the “vapor zone,” a term we used on our map. Within the HCA “vapor zone” we find that 60 of the Falcon’s 97 miles qualify as high consequence areas, with 35 miles triggered due to their proximity to drinking water sources, 25 miles trigger for proximity to populated areas, and 3 miles for proximity to ecological areas.

Populated Areas

Shell’s HCA buffer intersects 14 US Census-designated populated areas, shown in the table below. Falcon’s right-of-way directly intersects two of these areas: Cadiz Village in Harrison County, Ohio, and Southview CDP (Census Designated Place) in Washington County, PA. These areas are listed below. Additionally, we included on the FracTracker map the locations of public facilities that were found inside the HCA buffer. These include 5 public schools, 6 daycare centers, 10 fire stations, and 6 EMS stations.

Area Population State HCA
Pittsburgh Urbanized Area High PA Indirect
Weirton-Steubenville Urbanized Area High WV/OH/PA Indirect
Scio Village Other OH Indirect
Cadiz Village* Other OH Direct
Amsterdam Village Other OH Indirect
Shippingport Borough Other PA Indirect
Industry Borough Other PA Indirect
Hookstown Borough Other PA Indirect
Midway Borough Other PA Indirect
Clinton CDP Other PA Indirect
Imperial CDP Other PA Indirect
Southview CDP* Other PA Direct
Hickory CDP Other PA Indirect
Westland CDP Other PA Indirect
* Indicates an area the Falcon’s right-of-way will directly intersect

While it is difficult to determine the actual number of people living in the PIR and HCA vapor zone, there are ways one can estimate populations. In order to calculate the number of people who may live within the HCA and PIR zones, we first identified U.S. Census blocks that intersect each respective buffer. Second, we calculated the percentage of that census block’s area that lies within each buffer. Finally, we used the ratio of the two to determine the percentage of the block’s population that lies within the buffer.

Based on 2010 Census data, we estimate that 2,499 people live within a reasonable projection of the Falcon’s PIR blast zone. When expanded to the HCA vapor zone, this total increases to 8,738 people. These numbers are relatively small compared to some pipelines due to the fact that a significant portion of the Falcon runs through fairly rural areas in most places.

PIR est. pop. HCA est. pop.
OHIO
Carroll County 11 47
Harrison County 274 915
Jefferson County 334 1,210
Total 619 2,172
WEST VIRGINIA
Hancock County 242 1,155
Total 242 1,155
PENNSYLVANIA
Allegheny County 186 969
Beaver County 990 3,023
Washington County 461 1,419
Total 1,637 5,410
Grand Total 2,499 8,738


Drinking Water Sources

Shell’s data identified a number of drinking water features considered in their HCA analysis. Metadata for this information show these sites were obtained from the Ohio Division of Drinking and Ground Waters, the West Virginia Source Water Assessment and Wellhead Protection Program, and the Pennsylvania DEP Wellhead Protection Program. The exact locations of public drinking water wells and intake points are generally protected by states for safety reasons. However, we duplicated the 5-mile buffer zones used on Shell’s map around these points, presumably denoting the boundaries of source water protection areas, wellhead protection areas, or intake points.

Drinking water buffers in Shell’s HCA analysis

As shown on FracTracker’s interactive map, five of these areas serve communities in the northern portions of Beaver County, shown in the image above, as well as the Cadiz and Weirton-Steubenville designated populated areas. Recall that HCA drinking water analysis only requires consideration of groundwater wells and not surface waters. This is an important distinction, as the Ambridge Reservoir is within the HCA zone but not part of Shell’s analysis — despite considerable risks outlined in our Falcon article on water body crossings.

Ecological Areas

Shell’s permits state that they consulted with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), and the Pennsylvania Department of Conservation and Natural Resources (DCNR) on their intended route in order to determine potential risks to protected species and ecologically sensitive areas.

DCNR responded that the pipeline had the potential to impact six sensitive plant species: Vase-vine Leather-Flower, Harbinger-of-spring, White Trout-Lily, Purple Rocket, Declined Trillium, and Snow Trillium. PFBC responded that the project may impact the Southern Redbelly Dace, a threatened temperate freshwater fish, within the Service Creek watershed. PGC responded that the pipeline had potential impact to habitats used by the Short-Eared Owl, Northern Harrier, and Silver-Haired Bat. Finally, the USFWS noted the presence of freshwater mussels in a number of water features crossed by the Falcon.

The presence of these species, as well as the proximity of protected lands illustrated on our map, factored into the Falcon’s HCA designations. A more detailed analysis of these issues is provided in the Falcon Public EIA Project article on Protected Habitats & Species of Concern.

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Related Articles

By Kirk Jalbert, FracTracker Alliance

The Falcon: Protected Habitats & Species of Concern

Part of the Falcon Public EIA Project

Major pipeline projects are scrutinized by state and federal agencies for their potential impacts to threatened, endangered, and protected species. As part of the planning process, operators are required to consult with agencies to identify habitats known to support these species and are often asked to conduct detailed field surveys of specific areas. In this segment of the Falcon Pipeline EIA Project, we investigate how Shell corresponded with different agencies in complying with federal and state protected species guidelines.

Quick Falcon Facts

  • More than half (54%) of construction areas are currently forested or farmland
  • Botanical species Purple Rocket and Climbing Fern located in proximity to workspaces
  • 67 Northern Harrier observations documented during site studies
  • One active Bald Eagle nest and two inactive nests in proximity to workspaces
  • Northern Long-eared Bat roost trees discovered as close as 318 feet from workspaces
  • Clusters of protected freshwater mussels, coldwater fish, and hellbenders in the path of the Falcon

Map of Protected Habitats & Species of Concern

The following map will serve as our guide to exploring the Falcon’s proximity to protected habitats and species of concern. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible at closer zoom levels. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

Shell’s permit applications detail extensive correspondences over a number of years — as early as August 2015 — with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), Pennsylvania Department of Conservation and Natural Resources (DCNR), Ohio Department of Natural Resources (ODNR), and the West Virginia Division of Natural Resources (WVDNR), among other agencies. These interactions tell a story of locating and cataloging threatened flowers, birds of prey, aquatic species, and bats.

Land Cover Assessment

A number of terrestrial habitat types are present along the Falcon pipeline’s route that will be disrupted during its construction. These are easily determined using data maintained by the USGS that tracks land cover and land use trends often used for understanding geospatial biodiversity. Shell used this data in their ecological impacts analysis and we have used it as well for comparison.

Habitat documentations from Shell’s permit applications

More than half (54%) of land in the Falcon’s construction area is currently forested land (deciduous and evergreen). Shell’s permits describe these areas as “contained cool, forested stream valleys and seeps and rich slopes” similar to the image above, which was submitted as part of Shell’s permit applications. An additional 35% is currently farmland (pasture/hay/crops). The remaining land cover is generally made up of water and wetlands, as well as residential and commercial development.

These numbers reflect the fact that the Falcon will travel through predominantly rural areas. Note that this analysis does not account for disruptions that will result from the pipeline’s 111 temporary and 21 permanent access roads. Land Cover for areas along the pipeline can be seen on the FracTracker map by activating the data in the “layers” tab.

Botanical Studies

In their correspondences with state agencies, Shell was notified that a number of important species would likely be found in these habitats. For instance, Pennsylvania Department of Conservation and Natural Resources (DCNR) noted the following botanical species on their watch list would be present:

  • Vase-vine Leather-flower (endangered): documented in floodplain and slopes of Raccoon Creek
  • Harbinger-of-spring (rare): documented in forested floodplain of Raccoon Creek
  • White Trout-lily (rare): documented in forested floodplain of Raccoon Creek
  • Purple Rocket (endangered): documented in forested floodplain of Raccoon Creek
  • Declined Trillium (threatened): documented along wooded tributaries and slopes of Raccoon Creek
  • Snow Trillium (rare): documented in tributary ravines along Raccoon Creek

DCNR requested a survey the Falcon’s route through all of Beaver County and the portion of Allegheny County north of the western fork of Raredon Run. AECOM, Shell’s contractor for this work, surveyed a 300-foot wide buffer along the pipeline route to allow for “minor alignment shifts” as construction plans are refined.

A final survey report was submitted to DCNR in March 2017. In it, AECOM noted having found multiple populations of Harbinger-of-spring (seen below), Purple Rocket, as well as Climbing Fern (Lygodium palmatum), also the PA Watch List. FracTracker’s map locates the general location of botanical discoveries nearest to the pipeline route.

Documented Harbinger-of-spring

DCNR’s response to the survey stated that route changes and plans to bore under Raccoon Creek using HDDs eliminated risks to Harbinger-of-spring and Purple Rocket. Meanwhile, Climbing Fern was determined to be in close proximity, but not directly in the pipeline’s construction area. Although, documents note that a number of ferns were transplanted “to further the species’ success within the Commonwealth.” As a result of these determinations, DCNR granted clearance for construction in August 2017.

Short-eared Owls & Northern Harriers

Shell was also notified by the Pennsylvania Game Commission (PGC) that portions of the Falcon’s workspace would be located near six areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species).

PGC requested a study of these areas to identify breeding and nesting locations, which AECOM executed from April-July 2016 within a 1,000-foot buffer of the pipeline’s workspace (limited to land cover areas consisting of meadows and pasture). One Short-eared Owl observation and 67 Northern Harrier observations were recorded during the study, but that some of these harriers appeared to be nesting just outside the study area. The study area is visible on the FracTracker map, as shown below.

AECOM’s Owl & Harrier study areas

In February 2017, Shell notified PGC that a number of reroutes had occurred that would shift the Falcon pipeline away from a subset of the observed Northern Harrier habitat. Although, there is no mention in the permit applications about identifying potential nest locations in the neighboring areas where AECOM’s biologists observed additional harriers. Nevertheless, PGC’s final determination in August 2017, approved the project, stipulating that, “based on the unusually high number of observations at these locations” work should not be done in these areas during harrier breeding season, April 15 through August 31.

Bald Eagles

The U.S. Fish & Wildlife Service (USFWS) notified Shell that a known Bald Eagle nest was located in Beaver County. Meanwhile, the Ohio Department of Natural Resources (ODNR) and West Virginia Division of Natural Resources (WVDNR) noted that two potential “alternate nests” were located where the Falcon crosses the Ohio River. National Bald Eagle Management Guidelines bar habitat disturbances that may interfere with the ability of eagles to breed, nest, roost, and forage.

AECOM surveyed these areas in March 2016 and March 2017. The first stage included an analysis of land cover data to determine other areas along the Falcon’s route that may be desirable eagle habitat. In addition to the sites noted above, AECOM determined that Fort Cherry Golf Course (discussed in gerater detail here) and Beaver Conservation District owned land (discussed in greater detail here) would serve as eagle habitat, although in later field surveys no additional nests were found.

The one active nest in close proximity to the Falcon, called the Montgomery Dam Nest, is located just west of the pipeline’s terminus at Shell’s ethane cracker facility. AECOM’s study determined that the foraging areas for a pair of eagles using the nest span the Ohio River and Raccoon Creek.

An additional nesting site was found near Tomlinson Run, along the Ohio River. During initial field observations it was noted that the nest was not in-use and is in an unmaintained condition. Nevertheless, its use by Bald Eagles as recently as 2015 means it is still considered an “alternate nest” and thus accorded protection from habitat modifications. A second alternate nest was found the west bank of the Ohio River. No previous history of the nest had been recorded by state agencies.

Bald Eagle Study Gaps?

Below are maps from Shell’s permit applications identifying the locations of the three nests. These can also be found on the FracTracker map.[/av_icon_box]

USFWS requested that Shell only implement setback buffers for the one active nest at Montgomery Dam. These include no tree clearing within 330 feet, no visible disturbances with 660 feet, and no excessive noise with 1,000 feet of an active nest. Furthermore, Shell must avoid all activities within 660ft of the nest from January 1st to July 31st that may disturb the eagles, including but not limited to “construction, excavation, use of heavy equipment, use of loud equipment or machinery, vegetation clearing, earth disturbance, planting, and landscaping.”

According to Shell’s permit applications, the reroute that occurred at the Ohio River crossing took the Falcon pipeline away from the two alternate nest sites of concern, and the crossing at the river will be done with HDD boring, thus no impacts will occur. Apparently USFWS agreed with this position. However, as we see in the above maps, the HDD staging area on the WV side of the river (where a great deal of noise will likely occur) is just barely outside the 1,000 foot buffer.

Important Bird Areas

USFWS determined that the Falcon pipeline was also in close proximity to many migratory bird species protected under the Migratory Bird Treaty Act and that “direct or indirect, unintentional take of migratory birds may result even if all reasonable measures to avoid avian mortality are utilized.” In particular, the USFWS brought attention to the Raccoon Creek Valley and State Park Important Bird Area (IBA), which is located just south and west of the Falcon pipeline’s two major branches, as seen below.

USFWS recommended a number of strategies, such as co-locating the Falcon pipeline along rights-of-way used by existing pipelines. We see this indeed became the case, as 11 of the Falcon’s 23 pipeline miles in Beaver County are found adjacent to or parallel to existing ROWs.

Additional restrictions were placed on the project in Ohio, where ODNR determined that the Falcon is within range of the Upland Sandpiper, a state endangered bird that nests in grasslands and pastures. Shell was instructed to avoid construction in these habitat types from April 15-July 31 if such areas were to be disturbed. As we can see on the FracTracker map’s analysis of land cover data, there are significant areas of grassland and pasture in Ohio along the pipeline route.

No Peregrine Falcon?

One absence we noted in AECOM’s birds of prey studies was any mention of Peregrine Falcons, listed as endangered and protected under the PA Game and Wildlife Code. Peregrine Falcons nest in cliffs and bridges along rivers in Allegheny and Beaver counties and are particularly prized by the PA DEP, as evidenced by a prominently displayed booth at their Harrisburg headquarters.

PA DEP Falcon Exhibit

One known nest is located under the East Rochester-Monaca Bridge just north of the Falcon pipeline’s terminus at Shell’s ethane cracker facility. While it is unlikely that activities such as tree clearing would affect falcon habitat, other aspects of the pipeline’s construction, such accidental drilling mud spills at HDD sites or ethane releases along Raccoon Creek, may indeed impact Falcon populations.

Federally Protected Bats

The USFWS notified Shell that the Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia and requested Shell conduct a bat “mist net” survey to identify breeding areas. Mist netting involves setting up nylon mesh nets at predetermined locations to capture and document bat populations.

AECOM’s bat survey was conducted from April-July 2016. While bats are known to live in caves and abandoned mines in winter, the study focused on summer habitats — mainly forests that support roost trees — given that tree clearing from building the pipeline would be the most likely impact. These forested areas constituted about 27 of the Falcon pipeline’s 97 miles in the two states. Mist net locations (MNLs) were established at 46 sites along the route, roughly 1/2 mile apart, as shown on the FracTracker map. A later reroute of the pipeline led to setting up 4 additional MNLs in June 2017.

A total of 274 bats from 6 different species were captured in the study, included 190 Big Brown Bats, 2 Silver-haired Bats, 62 Eastern Red Bats, 2 Hoary Bats, and 1 Little Brown Bat. 17 Northern Long-eared Bats were found at 13 of the MNL sites, but no Indiana Bats were captured. Radio transmitters were then attached to the Northern Long-eared Bats in order to follow them to roost trees. A total of 9 roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace.

A captured Northern Long-eared Bat

In January 2018, USFWS stated that, because the Falcon’s construction area is not within 150 feet of a known roost tree during breeding season or within a 1/4 mile of a known year-round hibernation site, that “incidental take that might result from tree removal is not prohibited.” However, USFWS also stated that “Due to the presence of several Northern Long-eared Bat roost trees within the vicinity of the project footprint (although outside of the 150-foot buffer), we recommend the following voluntary conservation measure: No tree removal between June 1 and July 31.”

Furthermore, the PGC noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). This was confirmed in AECOM’s mist net study. PGC did not require a further study for the species, but did request a more restrictive conservation of no tree clearing between April 1 and October 31.

Bat Study Gaps?

There are a number of possible gaps in AECOM’s study that need attention. First, the study notes the nearest roost tree is 318 feet from the Falcon’s workspace, but this does not fully represent the likely impact to bat populations. As is seen in the map below, taken from Shell’s permits, this tree is just one in a cluster of five trees all within 750 feet of the pipeline’s workspace.

A dense cluster of bat roosting trees

Furthermore, tree clearing in this area will be extensive considering its proximity to the Falcon’s juncture in Beaver County that also must accommodate a metering pad and access roads. This area is shown in the permit application map below and can be explored on the FracTracker map as well.

A second questionable aspect of the study is that, while the USFWS letter states the Falcon is not “within a 1/4 mile of a known year-round hibernation site,” this was not proven in the study as it did not identify nearby winter habitats. These omissions are noteworthy given the already significant stressors to bat populations in the region, as well as increasing pressure from oil and gas companies to relax standards for protecting endangered bat species.

A Note on Noise Control

As part of their ability to build the Falcon pipeline, USFWS mandated that Shell employ an “independent noise consultant” to measure ambient pre-construction noise levels at each HDD site and at designated Noise Sensitive Areas (NSA), which are generally determined by the presence of protected bird and bat species. Less is known about the details of this part of AECOM’s study plan for Shell. However, we have located noise monitoring sites on the FracTracker map for reference.

Freshwater Mussels

The USFWS and PGC identified very early in the Shell’s construction plans that the project would likely impact four endangered mussel species: the Northern Riffelshell, the Clubshell, the Rayed Bean, and the Snuffbox. AECOM conducted a survey in May 2016, at the request of Pennsylvania and Ohio agencies at 16 perennial streams along the route in those two states. These are shown on the FracTracker map. In PA, mussels were found to be present at both of the Falcon’s intersections with Raccoon Creek, as seen in a photo from Shell’s permit application below.

Documented freshwater mussels in Raccoon Creek

The results of the Ohio study are unknown at this time. However, we found it interesting that ODNR’s letter to Shell stated that unavoidable impacts could be resolved by allowing specialists to collect and relocate mussels to suitable and similar upstream habitats. Meanwhile, it appears that the USFWS and PFBC have also green lighted construction around the two known Raccoon Creek mussel habitats, as Shell’s applications argue these waters would not be impacted due to the fact that they would be crossing using HDD boring.

Coldwater Fish

The PA Fish & Boat Commission notified Shell that the Falcon may impact the Southern Redbelly Dace. This threatened species is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PAFB explicitly notes in their correspondences that “we are concerned about potential impacts to the fish, eggs and the hatching fry from any in-stream work.” Of note is that these sites of concern are located in HQ/CWF streams of the Service Creek watershed (discussed in greater detail here), as shown on the map below.

Headwater streams in the Service Creek watershed

Early correspondences with PFBC show the agency requesting that directional boring be used for these stream crossings or, if work necessitated direct impacts (such as open-cut crossings), that these activity be avoided during the spawning season. Shell responded to the request in stating that, with the exception of the Service Creek itself which will be crossed by HDD, the terrain surrounding its headwater streams was not suitable for boring, and would thus require open-cuts.

PFBC’s final determination on these matters is that they generally agreed, with the exception of the HDD site and one headwater stream (S-PA-151104-MRK-001), all other crossings must adhere to seasonal restrictions with no in-stream activity being conducted between May 1-July 31.

In Ohio, we see similar circumstances related to the River Darter, the Paddlefish, and the Channel Darter, all threatened species in the state. The ODNR recommended no in-stream work in the Ohio River from March 15-June 30 and no in-stream work in any of the state’s perennial streams from April 15-June 30.

Eastern Hellbenders

The Falcon is also within range of Eastern Hellbender habitat in Ohio, a state endangered species and a federal species of concern. In particular, ODNR noted that Yellow Creek, in Jefferson County, is known to host the species. Because of this, ODNR requested that if any in-stream work was to occur in Yellow Creek, a habitat suitability survey must be conducted to determine if Hellbenders were present. Yellow Creek’s tributaries are indeed crossed by the Falcon. Whether or not a study was conducted as a result of this is unknown due to our not having reviewed Shell’s Ohio permit applications. The below image, captured from our page on water crossings, shows these locations.

Falcon crossing Yellow Creek tributaries

Allowable Work Dates

To summarize, there are numerous implications for how Shell’s construction of the Falcon pipeline must accommodate endangered, threatened, and rare species in different states. In particular, Shell must avoid land and aquatic disturbances during different breeding and spawning seasons. Below is a breakdown of these black-out periods. Note that these only apply to locations where sensitive species were found in AECOM’s studies.

Land Disturbances

  • Northern Harriers, Short-eared Owls (PGC): No clearing between April 15 and August 31
  • Bald Eagles (USFWS): No work between January 1 and July 31
  • Upland Sandpiper (ODNR): No clearing between April 15 and July 31
  • Bats (USFWS): No clearing between April 1 and October 31

Aquatic Disturbances

  • Southern Redbelly Dace (PFBC): No in-stream work between May 1 and July 31
  • River Darter, Paddlefish, Channel Darter (ODNR): No Ohio River work between March 15 and June 30; no perennial stream work between April 15 and June 30

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Falcon Pipeline: Cumulative Development & Compounded Risks

Part of the Falcon Public EIA Project

In this final section of the Falcon Public EIA Project, we explore the Falcon pipeline’s entanglements with a region already impacted by a long history of energy development. Featured in this article are where the Falcon pipeline intersects underground mining facilities, strip mines, other hazardous pipelines, active oil and gas wells, as well as a very large compressor station. We utilize this information to locate spaces where cumulative development also has the potential for compounded risk.

Quick Falcon Facts

  • 20 miles of the Falcon run through under-mined areas; 5.6 miles through active mines
  • 18 miles of the Falcon run through surface-mined areas; also coal slurry waste site
  • Shares a right-of-way with Mariner West pipeline for 4 miles in Beaver County
  • 11 well pads, as well as a compressor station, are within the potential impact radius

Map of Falcon relative to mined areas and other energy-related development

The following map will serve as our guide in breaking down where the Falcon intersects areas that have experienced other forms of energy development. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible as you zoom in. A number of additional features of the map are not shown by default, but can be turned on in the “layers” tab. These include information on geological features, water tables, soil erosion characteristics, as well as drinking reservoir boundaries. Click the “details” tab in full-screen mode to read how the different layers were created.


View Map Fullscreen | How FracTracker Maps Work

 

Mined Lands

The Falcon pipeline intersects a surprising number of active and inactive/abandoned mine lands. While the location of active mines is fairly easy to obtain from mine operators, finding data on abandoned mines is notoriously difficult. State agencies, such as the Pennsylvania Department of Environmental Protection (DEP), have digitized many legacy maps, but these resources are known to be incomplete and inaccurate in many locations.

AECOM’s engineers used data layers on active and abandoned mine lands maintained by state agencies in OH, WV, and PA. FracTracker obtained this data, as well, as shown on the interactive map. Shell states in their permits that AECOM’s engineers also went through a process of obtaining and digitizing paper maps in areas with questionable mine maps.

Shell states that their analysis shows that 16.8 miles of the Falcon pipeline travel through under-mined areas. Our analysis using the same dataset suggests the figure is closer to 20 miles. Of these 20 miles of pipeline:

  • 5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine). 
  • More than 18 miles run through areas that have been historically surface-mined (some overlapping under-mined areas).
  • Of those 18 miles, 1.5 miles run through an active surface mine located in Cadiz Township, OH, managed by Oxford Mining Company.

Beaver Valley Mine

The Beaver Valley Mine in Greene Township, PA, appeared to be of particular importance in Shell’s analysis. Of the three active mines, Shell maintained an active data layer with the mine’s underground cell map for reference in selecting routes, seen in the image below. Note how the current route changed since the map was originally digitized, indicating that a shift was made to accommodate areas around the mine. The FracTracker interactive map shows the mine based on PA DEP data, which is not as precise as the mine map AECOM obtained from Rosebud Mining.

Digitized map of Beaver Valley Mine

Rosebud Mining idled its Beaver Valley Mine in 2016 due to declining demand for coal. However, Rosebud appears to be expanding its workforce at other mines in the area due to changing economic and political circumstances. We don’t know exactly why this particular mine was highlighted in Shell’s analysis, or why the route shifted, as it is not directly addressed in Shell’s permit applications. Possibilities include needing to plan around areas that are known to be unfit for the pipeline, but also perhaps areas that may be mined in the future if the Beaver Valley Mine were to restart operations.

Coal Slurry Site, Imperial PA

As discussed in other segments of the Falcon Public EIA Project, Shell intends to execute 19 horizontal directional drilling (HDD) operations at different sites along the pipeline. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations. A 2003 DEP report commented on this region, stating:

All of the coal has been underground mined. Most of the coal ribs and stumps (remnants from the abandoned underground mine) have been surface mined… The extensive deep mining, which took place from the 1920’s through the 1950’s, has had a severe effect on groundwater and surface water in this watershed.

Shell’s applications note that AECOM did geotechnical survey work in this and other surface-mined areas co-located with proposed HDD operations, concluding that the ”majority of rock encountered was shale, sandstone, limestone, and claystone.” However, at one proposed HDD (called “HOU-06”) the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large Palustrine Emergent (PEM) wetland along Potato Garden Run, seen below.

A Falcon HDD crossing under a wetland and coal slurry site

Foreign Pipelines

In addition to its entanglements with legacy coal mining, the Falcon will be built in a region heavily traveled by oil and gas pipelines. More than 260 “foreign pipelines” carrying oil, natural gas, and natural gas liquids, were identified by AECOM engineers when selecting the Falcon’s right-of-way (note that not all of these are directly crossed by the Falcon).

Owners of these pipelines run the gamut, including companies such as Williams, MarkWest, Columbia, Kinder Morgan, Energy Transfer Partners, Momentum, Peoples Gas, Chesapeake, and Range Resources. Their purposes are also varied. Some are gathering lines that move oil and gas from well pads, others are midstream lines connecting things like compressor stations to processing plants, others still are distribution lines that eventually bring gas to homes and businesses. FracTracker took note of these numbers and their significance, but did not have the capacity to document all of them for our interactive map.

Shared Rights-of-Way

However, we did include one pipeline, the Mariner West, because of its importance in the Falcon’s construction plans. Mariner West was built in 2011-2013 as part of an expanding network of pipelines initially owned by Sunoco Pipeline but now operated by Energy Transfer Partners. The 10-inch pipeline transports 50,000 barrels of ethane per day from the Separator plant in Houston, PA, to processing facilities in Canada. Another spur in this network is the controversial Mariner East 2

Mariner West is pertinent to the Falcon because the two pipelines will share the same right-of-way through a 4-mile stretch of Beaver County, PA, as shown below.

The Falcon and Mariner West sharing a right-of-way

Reuse of existing rights-of-way is generally considered advantageous by pipeline operators and regulatory agencies. The logistics of sharing pipelines can be complicated, however. As noted in Shell’s permit applications:   

Construction coordination will be essential on the project due to the numerous parties involved and the close proximity to other utilities. Accurate line location was completed; however, verification will also be key, along with obtaining proper crossing design techniques from the foreign utilities. A meeting with all of pipeline companies will be held to make sure that all of the restrictions are understood prior to starting construction, and that they are documented on the construction alignment sheets/bid documents for the contractor(s). This will save a potential delay in the project. It will also make working around the existing pipelines safe.

Shell’s attention to coordinating with other utility companies is no doubt important, as is their recognition of working near existing pipelines as a safety issue. There are elevated risks with co-located pipelines when they come into operation. This was seen in a major pipeline accident in Salem Township, PA, in 2016. One natural gas line exploded, destroying nearby homes, and damaged three adjacent pipelines that took more than a year to come back onlineThese findings raise the question of whether or not Class Location and High Consequence Area assessments for the Falcon should factor for the exponential risks of sharing a right-of-way with Mariner West.

Oil & Gas Extraction

The remaining features included on our map relate to oil and gas extraction activities. The Falcon will carry ethane from the three cryogenic separator plants at the pipeline’s source points. But the wet, fracked gas that supplies those plants also comes from someplace, and these are the many thousands of unconventional gas wells spread across the Marcellus and Utica shale.

We found 11 unconventional oil and gas pads, hosting a combined 48 well heads, within the Falcon’s 940-foot PIR. We also found a large compressor station operated by Range Resources, located in Robinson Township, PA. This is shown below, along with a nearby gas pad.

A well pad and compressor station in Falcon’s PIR

We noted these well pads and the compressor station because Class Location and HCA risk analysis may account for proximity to occupied businesses and homes, but does not always consider a pipeline’s proximity to other high-risk industrial sites. Nevertheless, serious incidents have occurred at well pads and processing facilities that could implicate nearby hazardous liquid pipelines. By the same measure, an accident with the Falcon could implicate one of these facilities, given they are all within the Falcon’s blast zone.

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