In this article, we’ll feature four contentious pipeline build-outs in the Eastern United States, show ways in which those pipelines impact natural and human communities, and provide examples of how environmental advocates have challenged these projects, with varying degrees of success.
This digital atlas exploring natural gas development in the Towanda Creek watershed is the fourth in a series of FracTracker Alliance watershed impact analyses in the Susquehanna River Basin.
The interplay between the rights of the owner of the surface estate and the rights of the mineral estate have recently become the subject of both legislation and litigation as the use of subsurface pore space by various energy industries has developed at an increasingly rapid pace in North Dakota.
Water at Risk
A Digital Atlas Exploring the Impacts of Natural Gas Development in
the Lycoming Creek Watershed of Pennsylvania
Coursing through lush valleys of the Allegheny Plateau, Lycoming Creek flows over 37 miles to its confluence with the West Branch Susquehanna River in Williamsport, Pennsylvania. The 272-square-mile watershed includes idyllic tributaries like Pleasant Stream and Trout Run, names reflecting the intrinsic beauty and bounty of the area. Rock Run in Loyalsock State Forest by some accounts is, “one of the most beautiful streams in all of Pennsylvania.”
The mightier Pine Creek to the west perhaps carries greater notoriety, as does the enchanting Loyalsock to the east. But make no judgement about Lycoming Creek’s smaller stature. Forest covers 81% of the basin and only one percent is developed, with the rest of the land used for agriculture. Through the heart of this rugged terrain, a picturesque waterway beckons anglers and other revelers of the wilds.
The Lenape people called the watershed home before European occupation. They knew the creek as Legani-hanne, meaning “sandy or gravelly stream.” The native residents and those who displaced them used it as a means of transportation, whether traveling by canoe or walking the Sheshequin Path that runs north and east along the shores.
Lumber fueled the regional economy of the 19th century, and Lycoming’s forests fell. By rail and by water, saw logs were sent to Williamsport for milling. Wood-powered wealth gave rise to the city’s “Millionaire’s Row,” but prosperity apexed in the early 20th century. Today, the Williamsport area is home to nearly 30,000 people, down from a peak of around 45,000 in 1950. Comparatively, about 20,000 persons live within the Lycoming Creek watershed.
These days, Williamsport buzzes with breweries, bookstores, and the vitality of an urban hub. The Little League World Series still comes to town every summer, ushering memories of simpler, quieter times.
Nearby, the serene creek surges with life, including the Eastern hellbender—North America’s largest amphibian. But the same water can turn tempestuous and destructive. Notable floods in 1972, 1996, 2011, and 2016 caused loss of life and property damage. As climate change intensifies, heavy downpours and rapid snowmelt exacerbate flood risks.
Unconventional drilling brought new threats to the area: congested truck traffic, exorbitant consumptive water use, myriad air pollution sources, extensive land clearing, and ecological disturbance; and, the dangers of spills, leaks, and water contamination.
This report explores these impacts, underscoring the heavy footprint of extraction—and related activities—on public and private lands throughout the Lycoming Creek watershed.
The Lycoming Creek watershed provides ample opportunities for nature-based recreation. While there are no state parks in the watershed, a 507-acre (0.8 square miles) portion of the Tioga State Forest occupies the northern boundary of the watershed in Tioga County. Further south lies 45,022 acres (71.1 square miles) of the Loyalsock State Forest. This includes 332 acres (0.52 square miles) of the Devil’s Elbow Natural Area, a site known for its many wetlands—home to carnivorous sundew and pitcher plants—waters that feed the stunning Rock Run. The McIntyre Wild Area covers a 7,226 acre (11.3 square mile) expanse of the Loyalsock State Forest, situated entirely in the Lycoming Creek watershed. It includes spectacular waterfalls on streams that feed the aforementioned Rock Run, a tributary known for its vibrant trout population.
The Lycoming Creek watershed provides ample opportunities for nature-based recreation. While there are no state parks in the watershed, a 507-acre (0.8 square miles) portion of the Tioga State Forest occupies the northern boundary of the watershed in Tioga County. Further south lies 45,022 acres (71.1 square miles) of the Loyalsock State Forest. This includes 332 acres (0.52 square miles) of the Devil’s Elbow Natural Area, a site known for its many wetlands—home to carnivorous sundew and pitcher plants—waters that feed the stunning Rock Run.
The McIntyre Wild Area covers a 7,226 acre (11.3 square mile) expanse of the Loyalsock State Forest, situated entirely in the Lycoming Creek watershed. It includes spectacular waterfalls on streams that feed the aforementioned Rock Run, a tributary known for its vibrant trout population.
To the west of Lycoming Creek and State Route 14 is Bodine Mountain, another sweeping feature of the Loyalsock State Forest. Bodine Mountain is a north-to-south ridge rising over 1,300 feet above the Lycoming Creek valley.
In addition to state forests, the watershed contains 238 acres of State Game Land 335 at the northern boundary, and 2,430 acres (3.8 square miles) of State Game Land 133, situated southeast of Bodine Mountain. These conserved lands are designated to protect wildlife—a goal that seems at odds with current oil and gas leasing practices.
Fishing and enjoying mountain streams
Pennsylvania has two separate designations for streams with excellent water quality: exceptional value (EV) and high quality (HQ). The Department of Environmental Protection (DEP) explains that the quality of HQ streams can be lowered, “if a discharge is the result of necessary social or economic development, the water quality criteria are met, and all existing uses of the stream are protected.” The water quality of EV streams cannot be lowered.
Sadly, there are no streams in the beautiful Lycoming Creek watershed with an EV designation, however deserving. On the other hand, 412 miles of streams in its drainage are designated as HQ, representing 76% of the watershed’s 542 total stream miles, according to the state’s official designated use inventory. Statewide, 3,838 out of 86,473 miles (4.4%) of inventoried streams are categorized as EV, while 58,748 miles (67.9%) are HQ, making the Lycoming Creek watershed below average for the former, and above average for the latter.
Prior to industrialization, native brook trout populations were widespread in small, forested streams across Pennsylvania. While many streams are now stocked with several species of trout, the combination of pollution and deforestation has decimated the areas where trout—especially native brook trout—thrive in sustainable wild populations. Suitable streams are designated as Class A trout streams, and they are rare, accounting for just 3,037 miles, or 3.5% of streams across the Commonwealth. The Lycoming Creek watershed contains slightly fewer Class A streams than is typical, with 17.5 miles, representing just 3.2% of all streams in the drainage. Nevertheless, it remains an important respite for trout species and the anglers who seek them.
Split estates and the Clarence Moore lands
Hundreds of thousands of acres of Pennsylvania state forest are under lease agreements for fracked gas extraction, diminishing outdoor experiences and posing ongoing environmental threats. In those situations, the state Department of Conservation and Natural Resources (DCNR) clearly controls the surface and the gas that lies beneath. However, in some areas of the state forest, private interests claim mineral ownership, even in gaseous form—a situation called “split estate.” Loyalsock State Forest contains about 25,000 split estate acres, known as the Clarence Moore Lands.
In the Lycoming Creek watershed, most of the Clarence Moore lands lie east of US Highway 15, occupying areas that drain into Rock Run and Pleasant Stream, including some of the area’s few remaining Class A wild trout waters. Another section of the Clarence Moore lands extends west of Highway 15, on Bodine Mountain’s eastern flank. In their current state, the lands provide invaluable ecological services and—coupled with the Loyalsock Creek to the east—comprise critical source waters for two major watersheds.
Gas drilling requires a significant amount of infrastructure, including multiacre well pads, miles of gathering pipelines, retention ponds, waste processing facilities, and compressor and metering stations. Allowing surface disturbance in the Clarence Moore lands could have lasting, devastating consequences.
Nearly a decade ago, the Anadarko Petroleum Corporation approached DCNR with extensive plans for dozens of fracked gas wells and all the disruptive destruction that accompanies them in a large swatch of the Loyalsock State Forest and the Clarence Moore lands. Over the years, the Clarence Moore players have changed significantly. Southwestern Energy scored a stake, while Anadarko sold their interest to Alta Resources, a privately-held company scheduled for purchase by EQT, the nation’s largest fracked gas company. While the operators play their game of musical chairs, the situation remains a serious threat to some of the few remaining portions of the region that haven’t been spoiled with industrial gas drilling.
Ironically, modern horizontal drilling enables access to Clarence Moore’s reserves from miles away—from well pads on private land. There is no need—nor social license—to expunge the forest for future generations for short-lived, selfish gain. Organizations near and far, led by the Responsible Drilling Alliance and Save PA Forests Coalition, have rallied tirelessly to save this land from development, a truly special place deserving permanent protection.
Figure 2. The Clarence Moore Lands are a complicated split estate situation in the Loyalsock State Forest, including parts of the Lycoming, Loyalsock, and Schrader Creek watersheds.
Unique wetland biomes
Countless wetlands feed Lycoming Creek’s headwaters, providing a unique opportunity to observe aquatic flora and fauna beneath the forested canopy of Penn’s Woods. The US Fish and Wildlife Service (USFWS) explains their importance, as well as their precarious state:
“Wetlands provide a multitude of ecological, economic and social benefits. They provide habitat for fish, wildlife and plants—many of which have a commercial or recreational value—recharge groundwater, reduce flooding, provide clean drinking water, offer food and fiber, and support cultural and recreational activities. Unfortunately, over half of America’s wetlands have been lost since 1780, and wetland losses continue today. This highlights the urgent need for geospatial information on wetland extent, type, and change.”
The geospatial data referred to above is the National Wetland Inventory (NWI), which seeks to document all the wetlands in the United States, based primarily in aerial imagery. According to NWI data, there are 3,136 acres (4.9 square miles) of wetlands in the Lycoming Creek watershed. However, further field research is necessary to properly identify wetland boundaries, particularly in the case of ephemeral wetlands, for example, where the presence of aquatic plants help determine boundaries. All of this suggests that while there is every reason to believe the USFWS’ claim that over half of the nation’s wetlands have been lost since around the time of the Revolutionary War, it is believed the NWI discounts the total acreage.
A University of Vermont team developed another model for calculating wetlands, based primarily on, “2006-2008 leaf-off LiDAR data, 2005-2008 leaf-off orthoimagery, 2013 high-resolution land-cover data, and moderate-resolution predictive wetlands maps, incorporating topography, hydrological flow potential, and climate data.” This model calculates 6,943 wetlands acres (10.8 square miles) in the Lycoming Creek drainage, more than double the NWI’s estimated acreage.
Five trails traverse the Lycoming Creek watershed, crossing 152 miles total. This includes nearly 44 miles of the Loyalsock State Forest Cross-Country Ski Trail system south and east of the McIntyre Wild Area, suitable for hiking, biking, equestrian pursuits, and of course, cross-country skiing. The watershed also contains 33 miles of Bicycle PA Route J, which runs along Lycoming Creek from the confluence with the West Branch Susquehanna River on the southern end, all the way to the wetland border that feeds Lycoming Creek and neighboring Towanda Creek to the northeast. The watershed’s most popular trail may be the famous Old Loggers Path, a coveted backpacking route that meanders nearly 23 miles. The Hawkeye Cross-Country Ski Trail—frequented by hikers, bikers, and skiers—loops over seven miles in the northeastern corner of the watershed. Yet another watershed trail is the Lycoming Creek Bikeway, a mostly straight five-mile stretch from Hepburnville to the West Branch Susquehanna River.
Figure 3. Rock Run in Loyalsock State Forest’s McIntyre Wild Area. Photo by Ann Pinca.
Figure 4. A flyfisher casts in Lycoming Creek right beside Sheshequin Campground in Trout Run. Photo by Rebecca Johnson.
Figure 5. This wetland lies just beyond the northeastern boundary of the Lycoming Creek watershed and is similar to those feeding the headwaters of Rock Run near Devil’s Elbow Natural Area in Loyalsock State Forest. Photo by Shannon Smith.
The commercial oil and gas industry got its start in Pennsylvania in 1859 with the famous Drake Well, followed by a frenzy of drilling in the central and western portions of the state. The DEP has records of over 185,000 conventional oil and gas wells throughout the Commonwealth, and—because the industry preceded permitting requirements by almost a century—yearly estimates range between 480,000 and 760,000 conventional wells have punctured Pennsylvania’s surface. The Lycoming Creek watershed was further east than most of the conventional oil and gas pools, so it has seen very little conventional drilling. Of the 185,000 known well locations, only 25 (0.01%) are within the watershed. Of those, 11 (44%) have a status of “proposed but never materialized,” or “operator reported not drilled.” Eight wells (32%) are plugged, four (16%) have active status, one (four percent) is considered being in a regulatory inactive period, and one (four percent) is on the DEP’s orphan list—awaiting funding to be plugged properly.
The commercial oil and gas industry got its start in Pennsylvania in 1859 with the famous Drake Well, followed by a frenzy of drilling in the central and western portions of the state. The DEP has records of over 185,000 conventional oil and gas wells throughout the Commonwealth, and—because the industry preceded permitting requirements by almost a century—yearly estimates range between 480,000 and 760,000 conventional wells have punctured Pennsylvania’s surface.
The Lycoming Creek watershed was further east than most of the conventional oil and gas pools, so it has seen very little conventional drilling. Of the 185,000 known well locations, only 25 (0.01%) are within the watershed. Of those, 11 (44%) have a status of “proposed but never materialized,” or “operator reported not drilled.” Eight wells (32%) are plugged, four (16%) have active status, one (four percent) is considered being in a regulatory inactive period, and one (four percent) is on the DEP’s orphan list—awaiting funding to be plugged properly.
While drillers had long known about the Marcellus Shale, it wasn’t until 2004 that drilling in the formation became a profitable enterprise, through the combination of industrial-scale hydraulic fracturing and horizontal drilling. Soon thereafter, the Lycoming Creek watershed was no longer on the periphery of oil and gas exploration, but part of a densely drilled cluster of new unconventional wells in northeastern Pennsylvania.
The first unconventional well in the Lycoming Creek watershed was permitted by Range Resources at the Bobst Mountain Hunting Club on May 31, 2007, and drilling started less than two months later.
In the years that followed, 592 unconventional wells have been proposed for the watershed, 586 (99%) of which received permits, with 384 (65%) drilled as of June 28, 2021. Some wells had a short life, with 41 (10.6%) already plugged—a figure slightly higher than the statewide average of 8.7%. Fifteen operators have been active in the watershed.
As with the rest of Pennsylvania, the total number of drilled wells peaked in 2012, with 100 wells drilled that year. In the past seven years, the highest annual total was only one-fourth of that, with 25 wells drilled in 2019. However, these trends do not foretell an end to drilling in the region. The reduced number of wells drilled is offset by drilling each well more intensively, using five times as much water per well for hydraulic fracturing.
Gas production has flooded markets, reducing gas prices and profit margins. At the very start of the Marcellus boom in October 2005, gas prices were $13.42 per million British Thermal Units (BTUs), but have fluctuated between $1.75 and $4.00 per million BTUs in recent years. Many of the 202 wells permitted but not drilled in the watershed are located on existing well pads and can easily be drilled and brought into production as market forces dictate. For these reasons, the area is unlikely to see an end to drilling, pipeline construction, truck convoys—and all the other ancillary activities—any time soon.
Figure 6. Active fracking operation in May 2021 on ARD Operating’s COP Tract 551 A well pad, originally planned by Anadarko E&P in 2014. Photo by Ted Auch.
Figure 7. This video was taken at the same site as Figure 6, capturing ARD Operating’s well pad and the incessant noise it makes during hydraulic fracturing activities. Video footage captured by Brook Lenker.
Figure 8. Permitting, drilling, and plugging summary of unconventional wells in the Lycoming Creek watershed by year. Data through June 28, 2021.
Figure 9. Proposed unconventional wells by current operators in the Lycoming Creek watershed. Data through June 28, 2021. Note that wells that were proposed but not drilled are still associated with the original operator, which are not always still active in the watershed.
Figure 10. FracTracker’s partners at LightHawk provided aerial assistance to fly our photographer over the Lycoming Creek watershed. This video offers a glimpse at the oil and gas industry’s expansion in the watershed, juxtaposed with houses, farms, forests, wetlands, and numerous waterways. FracTracker’s Ted Auch captured still images while LightHawk pilot David Hartnichek gathered video footage, captured May 2021.
TimeSlider of Bodine Mountain
On the right, we see imagery from June 2021, with a substantial number of well pads, impoundments, compressors, pipelines, and access roads. Imagery on the left is from June 2014, with significantly less infrastructure. Users can zoom, pan, and choose different dates to explore the impacts of the industry over time.
In the Lycoming Creek watershed, unconventional wells and the well pads they operate on have been issued 634 violations between 2008 and June 28, 2021. This works out to 1.65 violations per drilled well, considerably above the statewide average of 1.3 violations per well.
Most of the violations (545, or 86%) are considered to negatively impact environmental health and safety, with the remaining 89 (14%) assessed for administrative infractions. However, the distinction between the two categories is murky at best. For example, the most common administrative violation is, “pits and tanks not constructed with sufficient capacity to contain pollutional substances,” an infraction documented 18 times in the watershed—presenting obvious hazards to health, safety, and the environment.
Altogether, there are 66 different violation codes cited within the watershed. The ten most frequent are seen in Figure 11.
For these 634 violations, the DEP has collected fines totaling $2,460,700 from four operators. Range Resources leads the way with $1,461,000 in fines, followed by Seneca Resources with $600,000, East Resources with $380,700, and Chief Oil & Gas with $19,000. For comparison, the average cost of drilling a single well in the Marcellus Shale is $8.3 million, according to 2017 financial data from a major operator in the region. At this rate, while assuming no inflation, the watershed will have to suffer 2,138 violations before the DEP’s penalties equal the cost of drilling and fracking one well.
Clearly, operators are not cowed by receiving violations, nor do they look at the occasional fine as anything more than the cost of doing business. It seems that in practice, the DEP’s regulatory role is chronicling the industry’s misdeeds, instead of protecting the environment and the people who live among the hundreds of wells in the area.
Figure 11. The ten most frequent violations for unconventional wells and well pads in the Lycoming Creek watershed through June 28, 2021.
Fracking’s aquatic impacts
The DEP maintains a statewide list of water resource sites. In the Lycoming Creek watershed, 76 out of 128 (59%) listed water resource facilities are associated with oil and gas activity, including 13 surface water withdrawal sites and 63 interconnections—large impoundments where water is collected and stored for future use. As excessive as these figures are, the state’s water resources data is incomplete. By examining aerial imagery, FracTracker found six impoundments adjacent to oil and gas operations that were not listed in the inventory. The DEP was aware of these facilities and provided data upon request. Multiacre lined impoundments can be identified from such imagery, but the inventory might be missing smaller withdrawal sites occluded from view by the tree canopy.
Overall, 259 wells reported using between 891,900 and 33,193,599 gallons of water as a base for their fracking chemical cocktail.
These numbers only represent the water consumed for hydraulic fracturing and don’t include any water used for pipeline hydrostatic testing, dust suppression on dirt and gravel roads, or any other purpose. For example, the voluminous 33,193,599 gallons used to frack Alta Resources’ Mac North B-3H well pad represents only a fraction of its permitted capacity for fracking operations.
Figure 12. A lined impoundment that does not appear on DEP’s Water Resources inventory. Photo by Karen Edelstein.
The unconventional oil and gas industry dominates water extraction, distribution, and use throughout the watershed. The amount of water used per fracked well has increased dramatically over the years, according to data from the industry’s frack fluid registry, FracFocus.
However, the registry is riddled with some obvious data inaccuracies—perhaps stemming from the fact that the registry is self-reported by the various operators.
For example, there are 272 well reports with latitude and longitude coordinates placing them inside the Lycoming Creek watershed, excluding wells where operators left the water usage field blank. There are some problematic data points with those remaining.
Five wells reported a negative number of gallons used to stimulate wells, including four from Seneca Resources’ Gamble K well pad—with quantities ranging from -214.7 million to -1.18 billion gallons of water—and one well from EXCO Resources’ Emig Unit well pad that registered -859.0 million gallons. At the other end of the spectrum, eight wells reported water consumption over 100 million gallons, including four from Rockdale Marcellus’ Cochran well pad, two from Seneca Resources’ Gamble K well pad, and two from EXCO Resources’ Emig Unit well pad.
As water consumption data of these 13 wells is obviously erroneous, they were excluded from the following analysis.
These withdrawal allowances are truly staggering.
Based on observations of consumptive use permit signs across the watershed, these water withdrawal limits are typical. Taking the 7.62 billion gallons per well pad average from Figure 15, this equates to about 716 billion gallons of permitted water consumption for the 94 well pads in the watershed that have at least one well with an active, regulatory inactive, or plugged well status. Given the average household consumes about 300 gallons of water per day—and that Pennsylvania has just over 5 million households—this volume is nearly equal to the entire residential consumption of the state for 628 days. If this is applied to each of the 125 proposed well pads, that figure rises to about 953 billion gallons, or a little less than the full capacity of Florida’s vast Lake Okeechobee.
Contamination from spills and leaks can affect more than just surface water. In 2014, 75 water wells in Lycoming County—which includes most of the Lycoming Creek watershed—were tested for various contaminants by the United States Geologic Survey (USGS). Six wells with the highest methane concentrations were further analyzed for their ratio of chloride to bromide, with half of that smaller subset showing water chemistry indicative of mixing with oilfield brine. Although the study posited that it could be mixing deep in the aquifer, it did not mention the frenzied drilling in the region at the time of sampling.
Stemming from thousands of complaints across the Marcellus Shale region, there are 378 private water supplies where DEP determined the loss of water quality or quantity was because of oil and gas activities. The public isn’t provided with the exact location of these fouled wells due to privacy concerns of impacted residents, but it is known that 18 incidents occurred in municipalities wholly or partially within the Lycoming Creek watershed.
According to Pennsylvania’s Act 13—an instrumental law governing various aspects of unconventional drilling in the state—oil and gas operators are presumed responsible for water wells negatively affected within 12 months and 2,500 feet of operations. Of course, the actual spread of a pollution plume depends on the characteristics of the aquifer itself, rather than definitions from Act 13, so it is possible that wells further than 2,500 feet from an incident could be negatively impacted—potentially years after the leak or spill occurred.
Of the 18 determination letters issued by DEP, one occurred in Fox Township in Sullivan County, six in Liberty Township in Tioga County, and two in Union Township. In Lycoming County, Eldred Township received three, Hepburn Township got one, Jackson Township received two, and McNett Township got two.
As previously mentioned, DEP also tracks violations of various state oil and gas regulations. The vast majority of incidents in the Lycoming Creek watershed resulted in an impact to surface or groundwater. Of the 634 total citations associated with unconventional wells and well pads: 41 (six percent) related to erosion and sedimentation concerns, which could harm aquatic life; 379 (60%) citations were for spills, leaks, or pollution discharges that degraded surface or groundwater; and 41 (six percent) were for other water issues. The remaining 173 (27%) violations were for various other shortcomings—most issued for improper handling of waste materials. Depending on what happened in the field to merit these violations, many of these incidents may also have had an impact on Pennsylvania’s waters.
Water is a defining characteristic for any watershed. From the expansive wetlands uphill to the brisk trout streams around Rock Run and the McIntyre Wild Area, down to the steep ravines of the Lycoming Creek, water makes this area special. In the rush to accommodate the thirsty and pollutive oil and gas industry, the state has allowed vast portions of the region to be spoiled.
Figure 13. Water consumption per well in the Lycoming Creek watershed has increased nearly five-fold in less than a decade, from 3,679,467 gallons in 2011 to 17,512,356 gallons in 2020, according to FracFocus data downloaded April 28, 2021.
Figure 14. Water consumption postings for six ARD (Alta Resources Development) well pads. Of the five visible signs, water consumption was permitted at 3 to 4 million gallons per pad, per day, for over five years. Photo by Erica Jackson.
Figure 15. The five visible signs in Figure 14 show that well pads are permitted to withdraw over 38.1 billion gallons of water, or an average of 7.62 billion gallons per well pad.
When fossil fuel companies portray fracked gas as “clean,” they better hope the public doesn’t notice the enormous stream of liquid and solid waste. In the Lycoming Creek watershed, operators reported 9,064,377 barrels (380.7 million gallons) of liquid waste and 416,248 tons of solid waste were generated in the drainage between January 2011 and April 2021. As a point of comparison, this volume of liquid waste—from 362 wells in the watershed—is equal to about 577 Olympic-sized swimming pools, or an acre of land covered in toxic waste 1,168 feet deep. In terms of solid waste, disposal of drill cuttings and other substances equals the garbage left behind after 8,672 Kenny Chesney concerts—like having about 2.3 concerts every day. This estimation is based on 330 wells reporting solid waste generation in the watershed.
When fossil fuel companies portray fracked gas as “clean,” they better hope the public doesn’t notice the enormous stream of liquid and solid waste. In the Lycoming Creek watershed, operators reported 9,064,377 barrels (380.7 million gallons) of liquid waste and 416,248 tons of solid waste were generated in the drainage between January 2011 and April 2021.
As a point of comparison, this volume of liquid waste—from 362 wells in the watershed—is equal to about 577 Olympic-sized swimming pools, or an acre of land covered in toxic waste 1,168 feet deep. In terms of solid waste, disposal of drill cuttings and other substances equals the garbage left behind after 8,672 Kenny Chesney concerts—like having about 2.3 concerts every day. This estimation is based on 330 wells reporting solid waste generation in the watershed.
Problems with oil & gas waste
To compare chemical-laden flowback fluid and radioactive brines to pool water based on volume alone does little to communicate the dangers of liquid waste—just as comparing drill cuttings and filter socks to beer cans and food wrappers is insufficient.
Oil and gas waste is much more harmful to human health and the environment than normal household refuse.
Flowback fluid includes a portion of the liquid injected into a wellbore during hydraulic fracturing. As presented in the Water section, the volume of water injected into each well averaged over 17.5 million gallons in 2020. The industry’s chemical registry site FracFocus estimates that between one-half percent and two percent of the injected volumes are composed of various chemical additives. To get an accurate estimate of the volumes of these chemicals, it is necessary to add the water volume and the non-water volume together, then calculate the above range. Unfortunately, only 18 out of the 259 wells in the watershed that provide believable water volumes also provide non-water volumes.
Approximately 25% of these chemical additives could cause cancer, according to recent studies—while others may inflict skin or respiratory damage.
What is now the Marcellus Shale formation was an ancient, shallow seabed around 384 million years ago in the Middle Devonian epoch. As this sea dried out, organic content concentrated, which would eventually be the source of hydrocarbon gasses. Other components saturated with this organic matter—including barium, benzene, chloride, radium, thallium, and more. These contaminants resurface with the oil and gas, either dissolved or suspended in fluid waste called brine. Brine will continue to rise to the surface in significant quantities during a well’s operating lifespan.
Drill cuttings comprise most of the solid waste from oil and gas sites in Pennsylvania. As with brine, these cuttings contain concentrations of the same toxic and radioactive chemicals. Whether used onsite or sent to landfills, these cuttings are problematic when precipitation causes contaminants to leach, posing risks to aquifers and surface waters. Traditionally, landfill leachate is taken to water treatment facilities. However, these facilities are ill-equipped to handle oil and gas waste and cannot effectively remove the contaminant load.
What happens to the waste?
In 2019, FracTracker analyzed and mapped the destination of Pennsylvania’s oil and gas waste from 2011 through 2018 in a project with Earthworks. Most waste stays in Pennsylvania and neighboring states, but this still requires thousands of heavy tankers travelling tens or even hundreds of miles to reach their destinations. The industry ships some waste as far as Texas, Utah, and Idaho, despite enormous transportation costs. The project underscored Pennsylvania’s incapacity to deal with this noxious and problematic waste stream.
This waste is handled in various ways, with about 54% reused at other fracking sites, 30% sent to residual waste processing facilities, and ten percent disposed in injection wells. Most of the remaining six percent is sent to surface impoundments—but it is not clear what happens to the waste from there.
For solid waste, 56% goes to landfills, 34% is reused at well pads, and eight percent goes to residual waste processing facilities—with the rest handled by other methods.
There is record of 124 waste facilities in the Lycoming Creek watershed, including 121 well pads, one landfill, one residual waste processing facility, and one temporary storage site, pending future reuse or disposal.
The Clean Earth facility—a landfill and drilling mud processing facility—has taken 157,457 tons of solid oil and gas waste and 315 barrels of liquid waste from 2013 to 2016. Between 2012 and 2013, the facility operated as Clean Streams, LLC, and accepted 10,610 additional tons of solid waste and 513,894 barrels of liquid waste. At the watershed’s northern border in Tioga County is Rockdale Marcellus’ Harer Beneficial Reuse facility. Beech Resources proposed an additional facility in currently forested land across US Highway 15 from the Clean Earth facilities.
Figure 16. Estimated chemical components of fracking fluid for the 18 wells in the Lycoming Creek watershed that provide non-water volumes. The minimum estimate is 965,434 gallons, based on 0.5% chemical concentrations, while the maximum estimate is 3,861,737 gallons, based on two percent concentrations.
Figure 17. Disposition method of liquid waste from unconventional wells in Pennsylvania in 2020, based on DEP waste reports. The total liquid waste volume was 61,832,431 barrels, or about 2.6 billion gallons.
Figure 18. Disposition of solid waste from unconventional wells in Pennsylvania in 2020. Total statewide mass was 1,397,678 tons.
Mountains of waste
As drilling continues in the Lycoming Creek watershed and nearby, enormous waste streams will continue to be a conundrum. Even reused material might contaminate the land, streams, and groundwater, and harm human health. As wells are fracked with ever-increasing volumes of fluid, they will return ever-increasing volumes of waste, requiring more and more resources to process.
To see more footage & photos from this project:
Field Day Description
On a sunny and brisk Thursday in May 2021, a group of 11 FracTracker staff members and volunteers gathered in the Lycoming watershed outside Williamsport to find and document unconventional oil and gas activities and infrastructure. This field day was in part informed by insights from members of the Responsible Drilling Alliance, a regional organization, and the knowledge and experiences of Peter Petokas, a biology and environmental science professor at Lycoming College who has explored and kept tabs on the area’s hellbender habitats for years. FracTracker’s Matt Kelso used DEP data to develop maps illustrating various infrastructure, including 384 drilled wells on 96 different pads, nine compressor and metering stations, and 67 water facilities related to oil and gas extraction—including 12 surface water withdrawal sites and 55 storage reservoirs. He then divided an area of about 272 square miles into five sections, and at least two participants explored each section. Using Matt’s maps, FracTracker’s mobile app, cameras, decibel and distance measuring apps, and other tools, the group visited and documented various infrastructure—while observing significant truck traffic and other evidence of the industry’s pervasiveness. As the groups navigated rural back roads and small state highways, many were struck by the juxtaposition of a bucolic landscape of rolling hills, green forests, and peaceful farmland with imposing, pollutive, and sometimes noisy and smelly fracking sites. Additional fieldwork was conducted with assistance from Earthworks’ staff and their FLIR technology, as well as aerial photography and videography captured by FracTracker’s Ted Auch—with flying assistance from partners at LightHawk. FracTracker then used the geolocated photos, video, and site-specific descriptions—coupled with variable datasets, research, and other literature—to compile this Story Atlas, an educational tool for concerned residents of the Lycoming Creek watershed, and an insightful resource for others living near fracking activity. The mobile app reports from this reconnaissance—and from locations across the U.S.—are visible on the FracTracker mobile app, available for download on your iOS or Android device, or by visiting the web app at https://app.fractracker.org/.
On a sunny and brisk Thursday in May 2021, a group of 11 FracTracker staff members and volunteers gathered in the Lycoming watershed outside Williamsport to find and document unconventional oil and gas activities and infrastructure.
This field day was in part informed by insights from members of the Responsible Drilling Alliance, a regional organization, and the knowledge and experiences of Peter Petokas, a biology and environmental science professor at Lycoming College who has explored and kept tabs on the area’s hellbender habitats for years.
FracTracker’s Matt Kelso used DEP data to develop maps illustrating various infrastructure, including 384 drilled wells on 96 different pads, nine compressor and metering stations, and 67 water facilities related to oil and gas extraction—including 12 surface water withdrawal sites and 55 storage reservoirs. He then divided an area of about 272 square miles into five sections, and at least two participants explored each section.
Using Matt’s maps, FracTracker’s mobile app, cameras, decibel and distance measuring apps, and other tools, the group visited and documented various infrastructure—while observing significant truck traffic and other evidence of the industry’s pervasiveness. As the groups navigated rural back roads and small state highways, many were struck by the juxtaposition of a bucolic landscape of rolling hills, green forests, and peaceful farmland with imposing, pollutive, and sometimes noisy and smelly fracking sites.
Additional fieldwork was conducted with assistance from Earthworks’ staff and their FLIR technology, as well as aerial photography and videography captured by FracTracker’s Ted Auch—with flying assistance from partners at LightHawk.
FracTracker then used the geolocated photos, video, and site-specific descriptions—coupled with variable datasets, research, and other literature—to compile this Story Atlas, an educational tool for concerned residents of the Lycoming Creek watershed, and an insightful resource for others living near fracking activity.
The mobile app reports from this reconnaissance—and from locations across the U.S.—are visible on the FracTracker mobile app, available for download on your iOS or Android device, or by visiting the web app at https://app.fractracker.org/.
Figure 19. The field day volunteers gathered before exploring the Lycoming Creek watershed. Photo by Shannon Smith, FracTracker Alliance.
Figure 20. This FLIR footage was recorded by Earthworks at NFG Midstream Trout Run LLC’s Hagerman gas processing and metering facility in Trout Run, Pennsylvania in June 2021. This recording captures visible air pollution from combustion and fugitive emissions at the facility.
Much has changed in the Lycoming watershed since unconventional oil and gas exploration ramped up over the last 15 years—in terms of ecological deterioration, as well as the deterioration of locals’ attitudes toward the industry.
At first welcomed by many as a chance for financial gain through mineral rights leasing, some community members—especially those whose families have lived in the area for generations—watched their land drastically degenerated and their sovereign land rights eclipsed by industrial encroachment they did not foresee.
Between 2011 and 2018, unconventional oil and gas drilling—notably, hydraulic fracturing—transformed sections of forest and farmland into comparatively gritty industrial zones.
“They were assured that, after the drilling phase was completed, they would hardly know the wells were there. They were also told that they had to decide quickly, and that everyone around them had already leased. A local anti-drilling advocacy group tried to warn them, but many locals distrusted environmentalists.”
As author and professor Colin Jerolmack references in his recent article for The New Republic, some landowners who willingly leased their mineral rights to oil and gas companies now view the industry’s activities with consternation. Incessant noise, traffic congestion, and foul odors have tarnished the once peaceful countryside. Even more disconcerting for property owners, the industry often operates however they please, with little consultation or consent—making some feel that they have lost their decision-making power and agency.
This disaffection potentially makes room for environmentalists to find common ground with those who embraced the industry, couched not in anti-fracking sentiments—and not necessarily in the essential need to mitigate the climate crisis—but in their shared love for the land.
Another big ecological concern in the punctured watershed centers on the fragile Eastern hellbender populations. Five conservation groups filed a lawsuit on July 1, 2021, challenging a 2019 decision to deny the amphibian protection under the Endangered Species Act.
“The hellbender is an ancient species that deserves better protections,” said Betsy Nicholas, Executive Director of Waterkeepers Chesapeake, one of the groups involved in the lawsuit. “The hellbender reminds us that we all live downstream. As the upstream tributaries are disturbed and polluted, the hellbender disappears. And the same pollution flows downstream to our populated areas, threatening the use and enjoyment of our rivers. We need to pay attention to what happens to the hellbender.”
Once widespread across 15 states, Eastern hellbenders have been eliminated from most of their historic range and continue to face many threats, including low water flow and poor water quality, increasing water pollution, deforestation, residential development, mining—and of course—oil and gas development.
Peter Petokas has been studying Eastern hellbender populations in the Lycoming watershed for 16 years. He is very concerned for the future of the species in the watershed, which holds one of the richest populations in Pennsylvania, concentrated in one of the few remaining streams with optimal water quality. Even so, a drought in 2020 left the area’s waterways with very low flows, which constrains the hellbender’s habitat and stresses the population. Because they lack protection under endangered species status, agencies may be remiss to implement enhanced regulations on discharges and withdrawals in the basin. Petokas remains hopeful that the pending lawsuit against the US Fish & Wildlife Service will restart an assessment for federal endangered/threatened species protection.
“If there’s ever a spill of anything, it’s the end, it would wipe out one of the best hellbender populations in Pennsylvania,” Petokas said.
Besides concerns about low water levels, the watershed is losing tree cover along streams to invasive insects and erosion. Riparian species like ash, sycamore, and river birches provide shade and keep the water cool enough for hellbenders to thrive.
Figure 21. A pipeline path cuts through forest in McNett Township, Lycoming County. Photo by Shannon Smith.
What does the future hold?
Figure 22. Miner’s Run, a stream in the Lycoming Creek watershed. Photo by Tim Palmer.
Thank you to all the inspiring and persistent environmental stewards who have contributed to the creation of this digital atlas:
Project funding provided by:
Clarence Moore Controversy in the Loyalsock – FracTracker Alliance
Karen Melton, Sierra Club, Fracking and a Community Turned Upside-down, June 2021
Colin Jerolmack, This Could Be the Start of a Rural Anti-Fracking Coalition, May 2021
Center for Biological Diversity, etc. lawsuit, July 2021
Middle Susquehanna Riverkeeper, Lawsuit Filed to Overturn Denial of Endangered Species Protection to Eastern Hellbenders, July 2021
[ii] Colin Jermolmack, Up to Heaven and Down to Hell. P. 261
[iii] Colin Jermolmack, Up to Heaven and Down to Hell. P. 266
[iv] Colin Jermolmack, Up to Heaven and Down to Hell. P. 258
[v] Colin Jermolmack, Up to Heaven and Down to Hell. P. 270
[vi] Colin Jermolmack, Up to Heaven and Down to Hell. P. 272
By Emma Vieregge, FracTracker Summer 2020 Environmental and Health Fellow
Unconventional oil and natural gas development, or “fracking,” began in Pennsylvania in the early 2000s. Since then, over 12,000 unconventional wells have been drilled in the state, and over 15,000 violations have been documented at unconventional well sites. As fracking operations continue to expand, increasing numbers of residents have experienced significant health impacts and irreparable damage to their property. Southwest Pennsylvania in particular has been heavily impacted, with high concentrations of oil and gas infrastructure developed in Washington, Greene, and Fayette Counties.
Fracking operations have led to declining air quality, water and soil contamination, and drastic changes to the physical landscape including deforestation, habitat fragmentation, road construction, and damaged farmland. While the volume of scientific literature about the physical and mental health impacts of fracking is rising, few studies exist that specifically focus on residents’ perceptions of the changing physical landscape. The primary goal of this qualitative study was to identify residents’ attitudes about the changing physical landscape resulting from fracking operations. Furthermore, how have these landscape changes affected residents’ engagement with the outdoors and their overall health?
Mental health, green spaces, and a changing landscape
Many scientific studies have documented the relationship between fracking developments and mental health, and between mental health and access to green spaces and engagement with the outdoors. Peer-reviewed studies have looked at heavily fracked communities across the US, many of which focus on Pennsylvania residents. Methods typically involve one-on-one interviews, larger focus groups, surveys, or a combination of the three, to identify how living amongst oil and gas operations takes a toll on everyday life. These studies have found an increase in stress and anxiety, feelings of powerlessness against the oil and gas industry, social conflicts, sleep disturbances, and reduced life satisfaction. Additionally, residents have experienced disruptions in their sense of place and social identity. For a summary of published research about the mental health impacts from fracking, click here.
A healthy strategy many choose to cope with stress and anxiety is engagement in outdoor recreation. Having easily accessible “green spaces,” or land that is partly or completely covered with grass, trees, shrubs, or other vegetation such as parks and conservation areas have been shown to promote physical and mental health. Many scientific studies have identified significantly fewer symptoms of depression, anxiety, and stress in populations with higher levels of neighborhood green space.1 Additionally, green spaces can aid recovery from mental fatigue and community social cohesion.2 3 However, residents in Southwestern Pennsylvania may slowly see their access to green spaces and opportunities for outdoor recreation decline due to the expansion of fracking operations. Figure 1 below shows a visual representation of the interconnected relationship between fracking, access to green spaces, and negative mental health impacts.
In the last 10-15 years, fracking operations in Southwest Pennsylvania have exploded. The development of new pipelines, access roads, well pads, impoundments, and compressor stations is widespread and altering the physical landscape. Figure 2 below illustrates just one of many examples of landscape disruption caused from fracking operations.
Additionally, this time-slider map (Figure 3) illustrates a larger scale view of landscape changes in Greene County, Pennsylvania in a region just east of Waynesburg.
Figure 3. Time-slider map of a region in Greene County, PA where the left portion of the map is imagery from 2005, and the right portion of the map is from 2017. Active oil and gas wells are indicated by a blue pin, and compressor stations are in green.
A qualitative study was conducted to answer the following research questions:
- What are residents’ perception of the landscape changes brought about by fracking?
- Have these landscape changes caused any mental health impacts?
- Have changes to the physical landscape from oil and gas operations resulting in any changes in engagement with outdoor recreation?
To better understand these topics, residents living in Southwestern Pennsylvania were recruited to participate in one-on-one phone interviews, and an online survey was also distributed throughout the FracTracker Alliance network. Recruitment for the one-on-one phone interviews was accomplished through FracTracker’s social media, and email blasts through other partnering organizations such as Halt the Harm Network, People Over Petro, and the Clean Air Council. Similarly, the online survey was shared on FracTracker’s social media and also distributed through our monthly newsletter. Since this was not a randomized sample to select participants, these results should not be generalized to all residents living near oil and gas infrastructure. However, this study identifies how certain individuals have been impacted by the changing landscape brought about by fracking operations.
Eight residents completed phone interviews, all of whom resided in Washington County, PA. Residents were first asked how long they have lived in their current home, and if there was oil and gas infrastructure on or near their property. Oil and gas infrastructure was defined as well pads, compressor stations, pipelines, ponds or impoundments, or access roads. Next, residents were asked if they had any health concerns regarding fracking operations and gave personal accounts of how fracking operations have altered the physical landscape near their home and in their surrounding community. For those with agricultural land, additional questions were asked about fracking’s impact on residents’ ability to use their farmland. Lastly, residents were asked questions focused on engagement in outdoor recreation and if fracking had any impact on outdoor recreation opportunities. NVivo, a qualitative analysis software, was used identify emergent themes throughout the interviews,
In addition to the interviews, an online survey was also made available.The main purpose of the survey was to gauge where concerns about landscape changes from fracking operations fell in relation to other oil and gas impacts (i.e. air pollution, water contamination, excess noise and traffic, and soil contamination). Nine responses were recorded, and the results are discussed below. However, if you would like to add your thoughts, you can find the survey at https://www.surveymonkey.com/r/Z5DCWBD.
Main findings and emergent themes
Various emergent themes surrounding the oil and gas industry’s impact on public health and the environment were identified throughout the resident interviews. Residents shared their personal experiences and how they have been directly impacted by fracking operations, especially with reference to the changing physical landscape surrounding their homes and throughout their communities. Participants’ time of residence in Washington County ranged from 3 years to their entire life, and all participants had oil and gas infrastructure (well pad, pipelines, impoundment, access roads, or compressor station) on or next to their property.
Changes to the physical landscape and residents’ attitudes toward the altered environment
The first overarching theme was changes to the physical landscape and residents’ attitudes toward the altered environment. All interview participants expressed concerns about the changes to the physical landscape on or surrounding their property, especially regarding access roads and well pads. Although one participant mentioned that widening the township road in order to make room for fracking trucks benefited the local community, the majority of participants expressed frustration about the construction of access roads, excessive truck traffic, noise, and dust from the unpaved access roads. One individual stated, “My main concern is the dust from the road. I’m constantly breathing that in, and it’s all over my shed, on the cars, the inside of the house, the outside of the house.” Multiple participants discussed the oil and gas operations disrupting what was once peaceful farmland with beautiful scenery (see an example in Figure 4 below). Another individual stated, “And of course, the noise is just unbearable. They don’t stop…the clanging on the pipe, the blow off with the wells, pumps running, generators, trucks coming down the hill with their engine brakes on, blowing their horn every time they want another truck to move.”
Impacts to outdoor recreation activities
Impacts to outdoor recreation activities such as hunting, fishing, and hiking were another recurring theme throughout the interviews. Again, a majority of participants believed their opportunities to partake in outdoor recreation have been limited since fracking operations began in their area.
Among the top concerns was deteriorating air quality and increasing numbers of ozone action days, or days when the air quality index (AQI) for ozone reaches an unhealthy level for sensitive populations. Various participants expressed concerns about letting their children outside due to harmful air emissions and odors originating from well pads or compressor stations. Excessive truck traffic was also a safety concern that was mentioned, especially for those individuals with access roads on or neighboring their property.
Additionally, one individual noted landscape changes in areas commonly used for hiking stating, “You might be hiking along a trail and then realize that you’re no longer on the trail. You’re actually on a pipeline cut. Or you’ll get confused while you’re hiking because you’ll intersect with a road that was developed for a well pad, and it’s not on your map.” Along with hiking, participants also noted a change in hunting and fishing opportunities since fracking moved into the region. Concerns were expressed regarding harvesting any fish or wild game due to possible contamination from fracking chemicals, especially near watersheds with known chemical spills.
Going for a hike and immersing oneself in nature is a healthy way to unwind and relieve stress. However, a rising number of well pads and compressor stations are put in place near parks, hiking trails, and state game lands throughout Southwest Pennsylvania (Figure 5). Participants expressed concerns about feeling unable to escape oil and gas infrastructure, even when visiting these recreational areas. As one individual mentioned, “It really does change your experience of the outdoors. And, you know, it’s an area that’s supposed to be a protected natural area. Then you know you can’t really get away. Even there in public lands far away from buildings and roads. And you can’t really get away from it.”
Figure 5. A map of active oil and gas well pads and compressor stations in Washington County, Pennsylvania. Map layers also indicate wells pads and compressor stations within 1 mile of a park, hiking trail, ball park, or state game land.
Mental health impacts
But what are the mental health impacts that result from the changing physical landscape brought about by fracking? Aside from the physical health effects caused by fracking activity — such as respiratory illnesses from air pollution or skin irritation from contaminated well water — these landscape changes have taken a toll on participants’ mental health as well.
Sentimental value and emotional distress
Many participants described the sentimental value of their property, and the beautiful scenery surrounding their generational family farms. But after fracking began on neighboring property, witnessing their tranquil family farm suddenly become surrounded by dusty access roads, excessive truck traffic, noise, and deteriorating air quality took a serious emotional and mental toll. When asked about the impact of the changing landscape, one participant stated, “It’s the emotional part of watching her childhood farm being destroyed while she is trying to do everything she can to rebuild it to the way it used to be.”
An additional emergent theme surrounding fracking landscape changes was surrounding agricultural impacts. Participants with agricultural land were asked additional questions about fracking’s impacts on their ability to use their farmland. One individual noted that one of their fields was now unusable due to large rocks and filter fabrics left from construction of a well pad, and redirected runoff uphill of their fields. The loss of productive farmland has further contributed to the mental and emotional stress. One participant added, “Our house is ruined, our health is ruined, and our farms are ruined.” In addition to agricultural impacts on large farms, multiple participants also mentioned concerns about their smaller-scale gardens, citing uncertainty about the impacts of air pollution and soil contamination on their produce.
Feelings of powerlessness and social tension
Some participants mentioned feelings of powerlessness against the oil and gas industry. Many families were not consulted prior to fracking operations beginning adjacent to their property. In some cases, this has resulted in significant declines in property values, leaving residents with no financial means to escape oil and gas activity. It is important to note that many residents are given temporary financial incentives to allow fracking on their land. However, to some, the monetary compensation failed to make up for the toll fracking took on their physical and mental health. Lastly, some participants also mentioned feeling stress and anxiety from the social tension resulting from fracking. Debates about the restrictions and regulations on fracking have divided many communities, leading to conflicts and social tensions between once-amiable neighbors.
In addition to the interviews, an online survey was distributed to gain more insight as to where concerns about the changing physical landscape fell in relation to other effects associated with oil and gas development (such as poor air quality, water or soil contamination, truck traffic, and noise).
Nine individuals responded to the survey, all of whom indicated having oil and gas infrastructure within five miles of their home. All respondents also indicated that they participated in a wide variety of outdoor recreation activities such as hiking, wildlife viewing/photography, camping, hunting, and fishing.
Interestedly, only five respondents stated they felt fracking had a negative impact on their health, three responded they were unsure, and one responded no. However, all participants felt fracking had a negative impact on their surrounding environment. When discussing outdoor recreation, eight of nine respondents stated they felt fracking limited their access to outdoor recreation opportunities.
Next, respondents indicated that the level of concern related to the changing landscape brought about by fracking was equal to concerns about air pollution, water and soil contamination, noise, and truck traffic (using a 5-point likert scale). Lastly, one respondent stated that they closed their outdoor recreation tourism business due to blowdown emission (the release of gas from a pipeline to the atmosphere in order to relieve pressure in the pipe so that maintenance or testing can take place) and noise from fracking operations.
Conclusion and future directions
In summary, fracking operations have deeply impacted these individuals living in Washington County, Pennsylvania. Not only do residents experience deteriorating air quality, water contamination, and physical health effects, but the mental and emotional toll of witnessing multigenerational farms become forever changed can be overbearing. Other mental health impacts included rising social tensions, feelings of powerlessness, and continuous emotional distress. Fracking operations continue to change the physical landscape, tarnishing Southwest Pennsylvania’s natural beauty and threatening access to outdoor recreation opportunities. Unfortunately, those not living in the direct path of fracking operations struggle to grasp the severity of fracking’s impact on families living with oil and gas infrastructure on or near their property. More widespread awareness of fracking’s impacts is needed to educate communities and call for stricter enforcement of regulations for the oil and gas industry. As one resident summed up their experiences,
“Engines are running full blast, shining lights, and just spewing toxins out there. And you can’t get away from it. You just can’t. You can’t drink the water. You can’t breathe the air. You can’t farm the ground. And you’re stuck here.”
Hopefully, shedding light on residents’ experiences such as these will bring policymakers to reconsider fracking regulations to minimize the impact on public health and the surrounding environment.
By Emma Vieregge, FracTracker Summer 2020 Environmental and Health Fellow
The 2020 Environmental Health Fellowship was made possible by the Community Foundation for the Alleghenies and the Heinz Endowments.
Many thanks to all participants who took the time to share their experiences with me, Lois Bower-Bjornson with the Clean Air Council, Jessa Chabeau at the Southwest Pennsylvania Environmental Health Project, and the FracTracker team for all of their feedback and expertise.
Feature image courtesy of Lois Bower-Bjornson from the Clean Air Council.
1 Beyer, K., Kaltenbach, A., Szabo, A., Bogar, S., Nieto, F., & Malecki, K. (2014). Exposure to Neighborhood Green Space and Mental Health: Evidence from the Survey of the Health of Wisconsin. International Journal of Environmental Research and Public Health, 11(3), 3453-3472. doi:10.3390/ijerph110303453
2 Berman, M. G., Kross, E., Krpan, K. M., Askren, M. K., Burson, A., Deldin, P. J., . . . Jonides, J. (2012). Interacting with nature improves cognition and affect for individuals with depression. Journal of Affective Disorders, 140(3), 300-305. doi:10.1016/j.jad.2012.03.012
3 Maas, J., Dillen, S. M., Verheij, R. A., & Groenewegen, P. P. (2009). Social contacts as a possible mechanism behind the relation between green space and health. Health & Place, 15(2), 586-595. doi:10.1016/j.healthplace.2008.09.006
Part of the Falcon Public Environmental Impact Assessment – a FracTracker series on the impacts of Falcon Ethane Pipeline System
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
- Loss of circulation
- Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
- Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
- Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
- 15 losses in Ohio – totaling 73,414 gallons
- 34 losses in Pennsylvania – totaling 172,116 gallons
- Inadvertent return
- Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
- Cause: Inadvertent returns are also frequent during HDD construction and are caused by many of the same factors as losses of circulation.
- Construction of the Falcon has caused at least 20 inadvertent returns, releasing at least 5,581 gallons of drilling fluid. These incidents include:
- 18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
- 2,639 gallons into water resources (streams and wetlands)
- 2 inadvertent returns Ohio – totaling 35 gallons
- 35 gallons into water resources (streams and wetlands)
- 18 inadvertent returns in Pennsylvania – totaling 5,546 gallons
- Definition: An inadvertent return occurs when drilling fluid used in pipeline installation is accidentally released and migrates to Earth’s surface. Oftentimes, a loss of circulation becomes an inadvertent return when underground formations create pathways for fluid to surface. Additionally, Shell’s records indicate that if a loss of circulation is large enough, (releasing over 50% percent of drilling fluids over 24-hours, 25% of fluids over 48-hours, or a daily max not to exceed 50,000 gallons) it qualifies as an inadvertent return even if fluid doesn’t surface.
However, according to the Ohio EPA, Shell is not required to submit reports for losses of circulation that are less than the definition of an inadvertent return, so many losses may not be captured in the list above. Additionally, documents reveal inconsistent volumes of drilling mud reported and discrepancies in the way releases are regulated by the Pennsylvania DEP and the Ohio EPA.
Very few of these incidents were published online for the public to see; FracTracker obtained information on them through a public records request. The map below shows the location of all known drilling fluid releases from that request, along with features relevant to the pipeline’s construction. Click here to view full screen, and add features to the map by checking the box next to them in the legend. For definitions and additional details, click on the information icon.
Jefferson County, Ohio
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
- when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
- when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
- whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.” In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
Despite the issues Shell experienced during construction, work on the Falcon continued over the past months during state shelter-in-place orders, while many businesses were forced to close.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
A Digital Atlas Examining Over a Decade of Unconventional Natural Gas Development in Pennsylvania’s Pine Creek Watershed
Pine Creek compressor station FLIR camera footage by Earthworks (May 2019).
“The Iroquois…called Pine Creek ‘Tiadaghton’ meaning either ‘The River of Pines’ or ‘The Lost or Bewildered River’.”[i] The river’s iconic watershed in North Central Pennsylvania spans 979 square miles, spanning parts of Clinton, Lycoming, Potter, and Tioga counties, and an infamous 47-mile gorge through which the Pine Creek flows. At 87 miles in length, it is the largest tributary to the West Branch Susquehanna River.[ii]
In 1964, Congress included Pine Creek as one of 27 rivers under study for inclusion in the National Wild and Scenic River System.[iii] Four years later, the US Department of the Interior designated twelve miles of the canyon a National Natural Landmark. In 1992, Pine Creek was recognized as a Pennsylvania Scenic River.[iv] These accolades underscore its vibrant beauty, ecological value, and cultural significance.
A rugged landscape carved into the Allegheny Plateau, the watershed contains extensive public lands and the highest concentrations of exceptional value (EV) and high quality (HQ) streams anywhere in Pennsylvania. It is a prized recreational attraction in the region known as the Pennsylvania Wilds, a destination for nature-based tourism. The area has endured episodes of resource extraction – logging, coal mining, and shallow gas development – but nothing quite the same as the assault from hundreds of new unconventional gas wells and the sprawling pads, pipelines, impoundments, compressor stations, and access roads accompanying such development.
Modern extraction is heavy industry – loud, dusty, and dirty. It is incongruent with the thick forests, sensitive habitats, hushed solitude, and star-drenched skies one expects to experience in many wilderness pursuits. Threats to air, water, and wildlife are manifest. Landscape fragmentation and forest loss are collateral damage. Ecological impacts, while sometimes immediate, are often insidious as they slowly degrade environmental health over time. The Oil and Gas Program of the Pennsylvania Department of Conservation and Natural Resources (DCNR) acknowledged in a 2012 presentation: “…that Marcellus Shale will be a long-term influence on the character of Pennsylvania landscapes.”[v] To what extent remains to be determined.
Writer and conservationist Samuel P. Hayes noted “The Pennsylvania Administrative Code of 1929 identified watershed protection as the primary purpose of the state forests.”[vi] Enduring more than 10 years of fracking history, and with more planned, the Pine Creek watershed is an experiment for this tenent and overdue for the geospatial examination that follows.
According to the NOAA, a watershed is a land area that channels rainfall and snowmelt to creeks, streams, and rivers, and eventually to outflow points such as reservoirs, bays, and the ocean.
A LEGACY OF EXTRACTION
Humans have left their mark on Pine Creek for thousands of years, but the effects of timber and fossil fuel extraction in the last 220 years are most notable. Historical accounts and agency records provide substantial documentation of these impacts.
In 1799, Pine Creek’s first sawmill was set up near the confluence with Little Pine Creek. By 1810, eleven saw mills were in operation. In the next 30 years, that number rose to 145. Pine Creek earned the moniker of “Lumber Capital of the World,” but by the end of the Civil War, the great pine forests along Pine Creek were depleted due to clearcutting. By the end of the Civil War, the great pine forests along Pine Creek were depleted. Underappreciated for lumber, eastern hemlocks remained, but were eventually felled as well, their bark prized for tanning leather. The advent of logging railroads accelerated the forest’s demise. By the first years of the 20th century, the trees were all but gone, “…branches and stumps littered the mountainsides and sparks from locomotives created fires of holocaustal proportions.”[vii]
Sadly, much of the wildlife was gone too. Bounties, market hunting, and habitat loss had taken a toll. The area’s last timber wolf was killed in 1875. The beaver, otter, fisher, martin, lynx, and wolverine were exterminated by the early 1900s. The remaining solitary panthers lasted until the 1930s, then “faded into oblivion.”[viii]
While not often thought of as a part of Pennsylvania’s coal country, the Pine Creek Watershed has seen its share of coal mining and related activity. Coal was first discovered along the Babb Creek portion of the watershed in 1782, and mining operations began in earnest in the 1860s. By 1990, the area was so impacted by mine drainage and other pollution that there were no fish found in Babb Creek. Efforts to rehabilitate the stream have made some progress, raising the pH of the stream and restoring fish populations, to the point where Babb Creek was officially removed from the list of impaired streams in 2016.
Within the watershed’s abandoned mine areas, 68 specific sites totaling nearly 500 acres are flagged as “containing public health, safety, and public welfare problems created by past coal mining.” This represents more than 11% of the total mined area. Only five of these 68 sites – all strip mines – have completed the reclamation process.
Table 1. Problematic coal mine areas in the Pine Creek Watershed
|SITE TYPE||ABANDONED||RECLAMATION COMPLETE||TOTAL FACILITIES||TOTAL ACRES|
|Dry Strip Mine||31||5||36||322.0|
|Flooded Strip Mine||2||–||2||1.7|
|Known Subsidence Prone Area||2||–||2||0.4|
|Coal Processing Settling Basin||3||–||3||1.5|
OIL & GAS
The oil and gas industry in Pennsylvania started with the Drake Well near Titusville in 1859, before the onset of the Civil War. In the years since, perhaps as many as 760,000 such wells have been drilled statewide.[ix] While the Pennsylvania Department of Environmental Protection (DEP) is the current state agency with regulatory oversight of the industry, it estimates that there could be as many as 560,000 wells drilled that they have no record of in their database. Given the lack of data for these early wells, it is not possible to know exactly how many wells have been drilled in the Pine Creek Watershed.[x]
Over a century ago, pollution was seen as the price to be paid for a job in timbering or mining. Some politicians seem to want a return to those bad old days by gutting some of our reasonable regulations that protect our air and water. Here, as in the rest of the Marcellus gas play, our politicians are not protecting our air and water as mandated in Article 1, Section 27 of our State Constitution.
-Dick Martin Coordinator for the Pennsylvania Forest Coalition and board member of Pennsylvania Environmental Defense Foundation, PEDF
A Wealth of Public Lands & Recreational Opportunity
The Pine Creek Watershed is in the heart of the Pennsylvania Wilds, a 12-county region in North Central Pennsylvania focused on nature-based tourism. “Adventure to one of the largest expanses of green between New York City and Chicago,” touts the initiative’s website.[xi] The area includes over two million acres of public land, and is marketed for its notorious starry skies, quaint towns, large elk herd, and other attractions, like Pine Creek.
The watershed and its trails and public lands contribute substantially to the PA Wilds estate and offerings, including:
- 1,666 stream miles (187.6 miles Exceptional Value and 1,011.5 miles High Quality)
- Eight state parks, spanning 4,713 acres (7.36 sq. miles)
- Four state forests, covering 264,771 acres (414 sq. miles)
- Eight natural areas
- Three wild areas
- Seven state game lands, totaling 51,474 acres (80.42 sq. miles)
- And 31 trails, traversing 789 miles
These largely remote and rugged spaces are relished for their idyllic and pristine qualities. Modern extraction brings discordant traffic, noise, lights, and releases of pollutants into the air and water. Stream waters – ideal for trout, anglers, and paddlers – are siphoned for the fracturing process. Trails are interrupted by pipelines and access roads. The erosion of outdoor experiences is piecemeal and pervasive.
A recent study lends credence to the concern that shale gas development is incongruent with the region’s ecotourism and recreational goals. “The Impacts of Shale Natural Gas Energy Development on Outdoor Recreation: A Statewide Assessment of Pennsylvanians” found that “only a small population of Pennsylvania outdoor recreationists were impacted by [shale natural gas energy development (SGD)] related activities. In the regions of Pennsylvania where SGD was most prominent (e.g., North Central and Southwest), outdoor recreation impacts were considerably higher.”[xii]
A recent study lends credence to the concern that shale gas development is incongruent with the region’s ecotourism and recreational goals. “The Impacts of Shale Natural Gas Energy Development on Outdoor Recreation: A Statewide Assessment of Pennsylvanians” found that “only a small population of Pennsylvania outdoor recreationists were impacted by [shale natural gas energy development (SGD)] related activities. In the regions of Pennsylvania where SGD was most prominent (e.g., North Central and Southwest), outdoor recreation impacts were considerably higher.”[xii]
Weak rules favor the gas companies and allow them to waste resources, pollute our air, and destroy our climate. Continued exploitation of our public lands diminishes the value of this common good.
–Leann Leiter, OH/PA Field Advocate, Earthworks
Read more about Leann’s view on fracking in Pine Creek and using FLIR photography to expose polluting emissions. Go to this post on Earthworks’ blog.
Fracking Comes to Pine Creek
Natural resource extraction in the Pine Creek Watershed did not stop with timber, coal, and traditional oil and gas. The drilling landscape in Pennsylvania changed dramatically around 2005, as operators began to develop the Marcellus Shale, a carbon-rich black shale that had eluded the industry for decades, because the rock formation was reluctant to release the large quantities of gas trapped within it. Based on successes in other shale formations, the Marcellus began to be drilled with a combination of horizontal drilling and high volume hydraulic fracturing – now using millions of gallons of fluids, instead of tens of thousands – and built upon multi-acre well pads. Operators were successful in releasing the gas, and this type of well, known as “unconventional” drilling, took off in vast swaths of Pennsylvania. Similar techniques were extended to other formations, notably the Utica shale formation.
The map below shows the cumulative footprint of extractive practices in Pine Creek, with the exclusion of timber.
In 2018, unconventional wells in the Pine Creek Watershed produced 203 billion cubic feet of gas, which is more than the entire state of West Virginia consumed in 2017, not including electricity generation. To get all of that gas to market requires an extensive network of pipelines, and multi-acre compressor stations are required to push the gas through those pipes.
Pipeline data for the region, largely based on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) public pipeline viewer map, includes over 85 miles of pipelines in the watershed. However, this data does not include any of the gathering lines that crisscross the watershed, connecting the drilling sites to the midstream network.
Among other concerns, gas pipelines need to be placed in areas where they will not be impacted by tree roots, and so operators clear a 50-foot wide right-of-way, at minimum. This width results in the clearing of more than 6 acres per linear mile of pipe, which would be a total of 515 acres for the known pipeline routes in the region. However, the 50-foot width is a minimum, and some rights-of-way exceeding 300 feet were observed in the watershed, which would require the clearing of more than 36 acres per linear mile. These land clearing impacts are in addition to those required for well pads, access roads, and other infrastructure.
Many of the compressor stations in the Pine Creek Watershed are considered major pollution sources, and therefore require a Title V permit from the US Environmental Protection Agency (EPA). This means that they either produce at least 10 tons per year of any single hazardous air pollutant, or at least 25 tons of any combination of pollutants on the list.
Missing pipeline data is evidenced by FracTracker’s records of many compressor stations that are not along documented pipeline routes. Of the 26 compressors in the watershed that we have records for, only six are within 250 meters of known pipeline routes. Similarly, only 29 of the 594 drilled unconventional wells in the watershed are within the quarter-kilometer radius of known pipeline routes. One way or another, all compressors and well sites have to be connected to pipelines.
Table 2. Oil & Gas Well Status in the Pine Creek Watershed
|Oil & Gas Well Status||# of Wells|
|Operator reported not drilled||404|
|Proposed but never materialized||111|
The PA DEP has records for 1,374 oil and gas wells within the watershed, although not all of these were actually drilled. Of these wells, 404 wells have an official status of “operator reported not drilled,” while an additional 111 have a similar status of “proposed but never materialized.” Of the remaining 859 wells, 554 are currently considered active (including 25 conventional and 529 unconventional wells). An active status is given once the well is proposed — even before it is officially permitted by DEP, let alone drilled. The status remains until some other status applies.
Seventy-four wells are considered to be “regulatory inactive” (four conventional, 71 unconventional), meaning that the well has not been in production for at least a year, and must meet several other requirements. The remainder of the wells in the watershed have reached the end of their functional life, of which 168 have been plugged (119 conventional, 49 unconventional). This is done by filling the well bore with concrete, and is considered permanent, although the plugs have been known to fail from time to time. Fifty-seven additional conventional wells are considered abandoned, meaning that they are at the end of their useful life but have not been appropriately plugged, neither by the operator nor DEP. Five additional conventional wells are considered to be orphaned, which is a similar status to abandoned, but these wells are no longer linked to an operator active in the state. Given the lack of recordkeeping in the early part of the industry’s history in PA, the number of plugged, abandoned, and orphaned wells in the Pine Creek Watershed is likely significantly underrepresented.
Conventional drilling activity has essentially ceased in the watershed. A single well categorized as conventional, the Bliss 3H well, has been drilled in 2019. In fact, this well is almost certainly miscategorized. Not only does its well name follow conventions for horizontal unconventional wells, but the DEP’s formation report indicates that it is in fact drilled into the Marcellus Shale. Prior to Bliss 3H, the two most recent conventional wells were drilled in 2011.
Unconventional drilling is a different story altogether. In terms of the number of wells drilled, the peak within the Pine Creek Watershed was in 2011, with 186 wells drilled. That represented 9.5% of the statewide total that year, and Pine Creek is just one of 35 comparably sized watersheds targeted for unconventional development in Pennsylvania.
More recently, there were 16 wells drilled in the watershed in 2018, and 17 wells through the halfway point of 2019, indicating that the extraction efforts are once again on the upswing.
Table 3. Number of unconventional wells drilled in Pennsylvania and the Pine Creek Watershed
|YEAR||STATEWIDE||PINE CREEK WATERSHED||PCT. TOTAL|
On May 9, 2019, nearly two dozen people descended upon the Pine Creek Watershed for the purpose of chronicling the impacts that the oil and gas industry is currently wreaking on the landscape. The documentation began early in the morning at the William T. Piper Memorial Airport in the town of Lock Haven, located in Clinton County. FracTracker Alliance organized the blitz with numerous partner organizations, including EarthWorks, Sierra Club, Save Our Streams PA, Responsible Drilling Alliance, Pennsylvania Forest Coalition, Environeers, Pine Creek Headwaters Protection Group, and Lebanon Pipeline Awareness.
The massive watershed was broken up into 10 impact zones, which were mostly determined by concentrations of known sites such as well pads, compressor stations, retention ponds, and pipeline corridors.
Some people brought cameras and specialized equipment to Pine Ceek, such methane sensors and global positioning system devices. Participants were encouraged to try out the FracTracker Mobile App, which was designed to allow users to communicate and share the location of oil and gas concerns. Earthworks brought a FLIR infrared camera, which can capture volatile organic compounds and other pollutants that are typically invisible to the human eye, but that still pose significant risks to health and the environment. Others participants brought specialized knowledge of oil and gas operations from a variety of perspectives, from those who had previously interacted with the industry professionally, to those who have been forced to live in close proximity of these massive structures for more than a decade.
While we knew that it would not be possible to photograph every impact in the watershed, the results of this group effort were tremendous, including hundreds of photos, dozens of app submissions, and numerous infrared videos. All of these have been curated in the map above. In our exuberance, we documented a number of facilities that wound up not being in the Pine Creek Watershed – still impactful but beyond the scope of this project. In some cases, multiple photos were taken of the same location, and we selected the most representative one or two for each site. Altogether, the map above shows 22 aerial images, 84 app submissions, 46 additional photos, and nine infrared FLIR videos.
FracTracker also collaborated with a pilot from LightHawk, a nonprofit group that connects conservation-minded pilots with groups that can benefit from the rare opportunity to view infrastructure and impacts from the air. Together, LightHawk and FracTracker’s Ted Auch flew in a mostly clockwise loop around the watershed, producing the aerial photography highlighted in this article, and in the map below.
The benefits of being able to see these impacts from the air is incalculable. Not only does it give viewers a sense of the full scope of the impact, but in some cases, it provides access to sites and activities that would otherwise be entirely occluded to the public, such as sites with active drilling or hydraulic fracturing operations, or when the access roads are behind barriers that are posted as no trespassing zones.
It can be difficult to maintain a sense of the massive scale of these operations when looking at aerial images. One thing that can help to maintain this perspective is by focusing on easily identifiable objects, such as nearby trees or large trucks, but it is even more useful to cross-reference these aerial images with those taken at ground level.
Water – A Precious Resource
Drilling unconventional wells requires the use of millions of gallons of water per well, sometimes as high as 100 million gallons. Unconventional drilling operations in Pennsylvania are required to self-report water, sand, and chemical quantities used in the hydraulic fracturing stage of well production to a registry known as FracFocus. Because of this, we have a pretty good idea of water used for this stage of the operation.
This does not account for all of the industry’s water consumption. The amount of water required to maintain and operate pipelines, compressor stations and other processing facilities, and to suppress dust on well pads, access roads, and pipeline rights-of-way is unknown, but likely significant. Much of the water used for oil and gas operations in this watershed is withdrawn from rivers and streams and the groundwater beneath the watershed.
Table 3. Water consumption by well in the Pine Creek Watershed
|CATEGORY||GALLONS||EQUIVALENT PERSONS (ANNUAL USAGE)|
|Average Single Well||6,745,697||246|
|Maximum Single Well||13,313,916||486|
|All Wells (2013-2017)||850,648,219||31,074|
There are 60 water-related facilities for oil and gas operations active within the watershed in 2019, including two ground water withdrawal locations, 20 surface water withdrawal locations, and 38 interconnections, mostly retention ponds. This dataset does not include limits on the 22 withdrawal locations, however, one of the surface withdrawal sites was observed with signage permitting the removal of 936,000 gallons per day. If this amount is typical, then the combined facilities in the watershed would have a daily capacity of about 20.6 million gallons, which is about 27 times the daily residential consumption within the watershed.
Predictably, water withdrawals ebb and flow with fluctuations in drilling activity, with peak consumption exceeding 1.2 billion gallons in the three-month period between April and June 2014, and an aggregate total of nearly 20.4 billion gallons between July 2008 and December 2016. It is not known what fraction of these withdrawals occurred in the Pine Creek Watershed.
Between October 22, 2007, and April 24, 2019, the Pennsylvania DEP issued 949 violations to unconventional oil and gas operations within the Pine Creek Watershed.[xiii] It can be difficult to know precisely what happened in the field based on the notations in the corresponding compliance reports. For example, if an operator failed to comply with the terms of their erosion and sediment control permit, it is unclear whether there was a sediment runoff event that impacted surface waters or not. However, as these rules were put into place to protect Pennsylvania’s waterways, there is no question that the potential for negative water impacts exists. Therefore, erosion and sedimentation violations are included in this analysis.
Other violations are quite explicit, however. The operator of the Hoffman 2H well in Liberty Township, Tioga County was cited for failing to prevent “gas, oil, brine, completion and servicing fluids, and any other fluids or materials from below the casing seat from entering fresh groundwater,” and failing to “prevent pollution or diminution of fresh groundwater.” A well on the Tract 007 – Pad G well pad was left unplugged. “Upon abandoning a well, the owner or operator failed to plug the well to stop the vertical flow of fluids or gas within the well bore.”
The violation description falls into more than 100 categories for sites within the watershed. We have simplified those as follows:
Table 4. Oil and gas violations in the Pine Creek Watershed
|Casing / Cement Violation||31||Yes|
|Clean Streams Law Violation||32||Yes|
|Erosion & Sediment||84||Yes|
|Failed to Control / Dispose of Fluids||279||Yes|
|Failure to Comply With Permit||3||No|
|Failure to Plug Well||1||Yes|
|Failure to Prevent Pollution Event||23||Yes|
|Failure to Protect Water Supplies||8||Yes|
|Failure to Report Pollution Event||20||Yes|
|Failure to Restore Site||8||No|
|Industrial Waste / Pollutional Material Discharge||229||Yes|
|Rat Hole Not Filled||7||Yes|
|Residual Waste Mismanagement||2||Yes|
|Restricted Site Access to Inspector||1||No|
|Site Restoration Violation||9||No|
|Unmarked Plugged Well||1||No|
|Unpermitted Residual Waste Processing||73||Yes|
|Waste Analysis Not Completed||1||No|
|Water Obstruction & Encroachment||7||Yes|
Altogether, 816 out of the 949 violations (86%) issued in the Pine Creek Watershed were likely to have an impact on either surface or ground water in the region. Two sites have more than 50 violations each, including the Phoenix Well Pad, with 116 violations in Duncan Township, Tioga County, and the Bonnell Run Hunting & Fishing Corp Well Pad in Pine Township, Lycoming County, with 94 violations.
When things go wrong with oil and gas operations, it is often residents in the surrounding areas that are exposed to the impacts. There are limited actions that affected neighbors can take, but one thing that they can do is register a complaint with the appropriate regulatory agency, in this case the Pennsylvania DEP.
A thorough file review was conducted by Public Herald for complaints related to oil and gas operations in PA, yielding 9,442 complaints between 2004 and 2016. While this includes all oil and gas related complaints, Public Herald’s analysis show that the frequency is highly correlated with the unconventional drilling boom that occurred within that time frame, with the number of new wells and complaints both peaking in 2011.
Many of these complaints occurred in the Pine Creek Watershed. It is impossible to know the exact number, as the precise location of the events was redacted in the records provided by DEP. Most of the records do include the county and in some cases, the municipality. Altogether, there were complaints in 32 municipalities that are either partially or entirely within the watershed, for a total of 185 total complaints. Of those, 116 of (63%) specifically indicate water impacts, spread out over 25 municipalities throughout the watershed.
Additional complaints with unspecified municipalities were received by DEP in Lycoming County (n=4), Potter County (n=4), and Tioga County (n=3). These counties substantially overlap with the Pine Creek Watershed, but the data is unclear as to whether or not these impacts were noted within the watershed or not.
It is worth remembering that complaints are dependent upon observation from neighbors and other passersby. As Pine Creek is composed of rugged terrain with vast swaths of public land, it is relatively sparsely populated. It is likely that if these drilling sites were placed in more densely populated areas, the number of complaints related to these operations would be even higher.
“It was 2007, and my water well was fine. I mean, I didn’t have any problem with it. I was cooking, drinking, bathing with it and everything else. Well, then after they drilled I thought it was kind of…it didn’t taste like it did before.”[xiv]
– Judy Eckhart
A Waste-Filled Proposition
Since the Pine Creek Watershed has been the site of considerable oil and gas extraction activity, it has also been the site of significant quantities of waste generated by the industry, which is classified as residual waste in Pennsylvania. This category is supposedly for nonhazardous industrial waste, although both liquid and solid waste streams from oil and gas operations pose significant risks to people exposed to them, as well as to the environment. Oil and gas waste is contaminated with a variety of dangerous volatile organic compounds and heavy metals, which are frequently highly radioactive. There are also a large number of chemicals that are injected into the well bore that flow back to the surface, the content of which is often kept secret, even from workers who make use of them onsite.
There were 37 sites in the Pine Creek Watershed that accepted liquid waste between 2011 and 2018. Of these sites, 30 (81%) were well pads, where flowback from drilling may be partially reused. While this reduces the overall volume of waste that ultimately needs to be disposed of, it frequently increases the concentration of hazardous contaminants that are found in the waste stream, which can make its eventual disposal more challenging. Most of the sites that accept waste do reuse that waste. However, the largest quantity of waste are from the remaining seven sites.
Table 5. Disposal of liquid gas waste in the Pine Creek Watershed
|Reuse at Well Pads||2,042,662||85,791,801||23%|
One single site – the Hydro Recovery LP Antrim Facility in Pine Township, Lycoming County – accounted for the majority of liquid waste disposed in the watershed, with 6,622,255 barrels (278,134,704 gallons.) has This amounts to 98.8% of all liquid waste that was not reused at other well pads.
Wastewater is also spread on roads in some communities, as a way to suppress dust on dirt roads. 3,001 barrels (126,050 gallons) of liquid waste have been used for road spreading efforts in regions intersecting the watershed in Ulysses Township, Potter County, and across private lots and roads throughout Potter and Tioga counties. Note that these figures include waste generated from conventional wells, which have different legal requirements for disposal than waste from unconventional wells, despite a similar chemical profile.
There are three facilities that have accepted solid oil and gas waste in the watershed, including a small one operated by Environmental Products and Services of Vermont (55 tons), Hydro Recovery LP Antrim Facility (10,415 tons), and Phoenix Resources Landfill (900,094 tons). This includes 200,808 tons in 2018, which is close to the previous peak value of 216,873 tons accepted in 2012.
Figure 1. Tons of solid O&G waste accepted at the Phoenix Resources Landfill
Recap: How has a decade of fracking impacted the Pine Creek Watershed?
1,374 recorded oil and gas wells in the watershed
554 are currently considered active
including 25 conventional and 529 unconventional wells
949 violations to unconventional oil and gas operations within the Pine Creek Watershed, 86% of which were likely to have an impact on either surface or ground water
185 complaints in 32 municipalities that are either partially or entirely within the watershed
A minimum of 515 acres cleared for the known gas pipeline routes in the region
26 compressor stations in the watershed
850,648,219 gallons of water used to frack wells in the watershed between 2013-2017
60 water-related facilities for oil and gas operations active within the watershed active in 2019, including two ground water withdrawal locations, 20 surface water withdrawal locations, and 38 interconnections (mostly retention ponds)
37 sites in the Pine Creek Watershed that accepted liquid waste between 2011 and 2018
And When It’s Over?
In the last ice age, glaciers came from the finger lakes area into Pine Creek. This made the soil there very deep and rich– in fact, people come from all over to study that soil. The Pine Creek area could be a mecca for sustainable agriculture. There is great soil, excellent water, and plenty of space for wind and solar. Under the right leadership, this region of Pennsylvania could feed people in a time when climate resilience is so urgently needed.
–Melissa Troutman, Research & Policy Analyst, Earthworks. Director of “Triple Divide.” Journalist, Public Herald
The Pine Creek region retains a primeval grandeur – an alluring wild spirit of great pride and significance to our state. Natural gas development has – and will further – compromise the natural and experiential qualities of this special place. For the benefit of Pennsylvanians today and tomorrow, extraction must be replaced by cleaner forms of energy and conservation values made preeminent.
– Brook Lenker, Executive Director, FracTracker Alliance
The Pine Creek Watershed in Pennsylvania’s Susquehanna River Basin has seen more than its fair share of industrial impacts in the centuries since European contact, from repeated timber clearcutting, to coal extraction, to the development of unconventional oil and gas resources in the 21st century. Despite all of this, Pine Creek remains one of the Commonwealth’s natural gems, a cornerstone of the famed Pennsylvania Wilds.
Many of the impacts to the watershed could be thought of as temporary, in that they would likely stop occurring when the oil and gas developers decide to pack up and leave for good. This includes things like truck traffic, with all of the dust and diesel exhaust that accompanies that, pollution from compressor stations and leaky pipe junctions, and even most surface spills.
And yet in some ways, the ability of the land to sustain this industry becomes substantially impaired, and impacts become much more prolonged. Consider, for example, that prior logging efforts have permanently changed both the flora and fauna of the region. Similarly, while there is no more active coal mining in Pine Creek, almost 500 acres of sites deemed to be problematic remain, and some streams impacted by contaminated runoff and mine drainage have yet to return to their former pristine state, even decades later.
Unconventional drilling in the watershed will have similarly permanent impacts. While there is a legal threshold for site restoration, these multi-acre drill sites will not resemble the heavily forested landscape that once stood there when they reach the end of their useful life. Access roads and gathering lines that crisscross the landscape must be maintained until all well pads in the area are out of service, and then the aging infrastructure will remain in situ. Contaminated groundwater supplies are likely to take centuries to recover, if it is even possible at all.
Thousands of feet of rock once separated the unconventional formations from the surface. That distance was a barrier not just to the gas, but also to salty brines, toxic heavy metals, and naturally occurring radioactive materials that are present at those depths. To date, 593 holes have been drilled in the Pine Creek Watershed, creating 593 pathways for all of these materials to move to the surface. The only things keeping them in place are concrete and steel, both of which will inevitably fail over the course of time, particularly in the highly saline environment of an old gas well.
Even if the industry were to leave today and properly plug all of the wells in the Pine Creek Watershed, impacts from the drilling are likely to remain for many years to come.
[i] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P. 11.
[ii] Wikipedia. Pine Creek (Pennsylvania). https://en.wikipedia.org/wiki/Pine_Creek_(Pennsylvania)
[iii] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P. 11.
[iv] DCNR. History of Colton Point State Park, 2019. https://www.dcnr.pa.gov/StateParks/FindAPark/ColtonPointStatePark/Pages/History.aspx
[v] DCNR, Bureau of Forestry. Marcellus Shale Management Field Tour, 2012. http://www.paforestcoalition.org/documents/Marcellus_Shale_Management_Field_Tour_5-14-12.pdf
[vi] Hayes, Samuel P. Wars in the Woods: The Rise of Ecological Forestry in America. Pittsburgh, PA. University of Pittsburgh Press, 2006. (2007). P 120-121.
[vii] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P.58-60.
[viii] Owlett, Steven. Seasons Along the Tiadaghton: An Environmental History of the Pine Creek Gorge. Wellsboro, PA: Steven E. Owlett, 1993. P.61.
[ix] Pennsylvania Department of Environmental Protection, Oil Gas Locations – Conventional Unconventional, 2019. https://www.pasda.psu.edu/uci/DataSummary.aspx?dataset=1088
[x] Pennsylvania Department of Environmental Protection. Abandoned and Orphan Oil and Gas Wells and the Well Plugging Program, 2018. http://www.depgreenport.state.pa.us/elibrary/PDFProvider.ashx?action=PDFStream&docID=1419023&chksum=&revision=0&docName=ABANDONED+AND+ORPHAN+OIL+AND+GAS+WELLS+AND+THE+WELL+PLUGGING+PROGRAM&nativeExt=pdf&PromptToSave=False&Size=411528&ViewerMode=2&overlay=0
[xii] Ferguson et al. The impacts of shale natural gas energy development on outdoor recreation: A statewide assessment of pennsylvanians, September 2019. Journal of Outdoor Recreation and Tourism. Volume 27.
[xiii]Pennsylvania Department of Environmental Protection. Oil and Gas Compliance Report Viewer. 2019. http://www.depreportingservices.state.pa.us/ReportServer/Pages/ReportViewer.aspx?/Oil_Gas/OG_Compliance
[xiv] Joshua Pribanic & Melissa Troutman. Triple Divide, 2013.
All aerial photography by Ted Auch with flight support by LightHawk (May 2019).
Pine Creek compressor station FLIR camera footage by Earthworks (May 2019).
In March of 2019, two and a half years after Shell Pipeline Co. announced plans for the Falcon Ethane Pipeline System, the imported pipes arrived at the Port of Philadelphia. As tree clearing and construction begins, we share frustration with residents that the project is underway while many of our concerns remain unaddressed.
Between 2010 and 2018, over 280 pipeline incidents were reported in Ohio, West Virginia, and Pennsylvania (the three states the Falcon crosses). Of those incidents, 70 were fires and/or explosions. As regulatory agencies and operators fail to protect the public, communities are taking the reins.
Environmental organizations are training the public to spot construction violations and appealing inadequate pipeline permits. Impacted residents are running for office, testifying in court, and even spending time in prison to protect their communities.
These grassroots efforts are contributing to a shift in public perception about the safety and need of pipelines. In some cases, including with the Northeast Energy Direct Pipeline and the Constitution Pipeline, organizing efforts are helping stop projects before they begin.
We invite all residents along the Falcon route to get involved in ongoing efforts to monitor construction. Below, you’ll find a guide to reporting violations as well as high-risk areas along the Falcon route that require close monitoring.
Be a citizen watchdog
Taking photos of pipeline development and recording your observations is a great way to monitor impacts. One tool to use while monitoring is the FracTracker mobile app (search “FracTracker” in the App Store or Google Play to download for free). The app allows the public to submit geolocated photos and descriptions of development, such as pipelines and wells, and concerns, such as spills and noise pollution. These reports help FracTracker crowdsource data and alert us to concerns that need follow up action. The app also contains a map of wells, pipelines, and compressor stations, including the Falcon pipeline route for reference in the field.
Click on the images below to view app reports of Falcon construction.
During the construction phase, incidents often occur when companies cause erosion of the ground and release sediment, equipment, or discharge into waterways. Mountain Watershed Association and Clean Air Council have provided the following information on the process of looking for and documenting violations.
Step 1) Document baseline conditions. Documenting the pre-construction status of an area is crucial for understanding how it’s been impacted down the road. Document baseline conditions by taking photos, videos, and notes at different sites, and include the location and date on these materials (the Fractracker app does this for you automatically). Observing sites at different times and in different weather (such as during or after a storm) will give you the best data.
Step 2) Know what to look for. Below are images and descriptions of common construction violations.
For more violations, checkout Pipeline CSI’s list of Top Ten Observable Non-Compliance Issues.
3) File a Report. File an official complaint to your state environmental regulatory agency.
Your concerns can be sent to regulatory agencies using the following contact information:
- Pennsylvania Department of Environmental Protection Environmental Complaint Form (or call the number listed here)
- Ohio Environmental Protection Agency
- West Virginia Department of Environmental Protection Complaint Form or email: firstname.lastname@example.org
4) Contact support organizations. There are several organizations ready to take action once violations have been confirmed. For confirmed violations in Beaver County, PA, contact Alex Bomstein, at the Clean Air Council (215-567-4004 x118) and for confirmed violations in Allegheny or Washington Counties, PA, contact Melissa Marshall at the Mountain Watershed Association (724-455-4200 x7#). For violations in Ohio or West Virginia, reach out to FracTracker (412-802-0273).
Reports made on the FracTracker App are shared with any app user and the FracTracker team, who look through the reports and contact users for any required follow up. App reports can also be submitted to regulatory agencies electronically. Simply visit the web version of the app, click on your report, and copy the URL (web address) of your report. Then “paste” it into the body of an email or online complaint form. The receiver will see the exact location, date, and any notes or photos you included in the report.
Where should you be monitoring?
Monitoring efforts must be limited to publicly accessible land. In general, areas that are most at-risk for environmental impact include stream and wetland crossings, steep slopes (particularly those near water crossings), flood-prone zones, and areas where storm water runoff will reach waterways. View a map of the Falcon’s water crossings here, and continue reading for more vulnerable locations to monitor.
The information below identifies high-risk areas along the pipeline route where monitoring efforts are extra necessary due to their impacts on drinking water, wetlands, undermined areas, and vulnerable species.
We found 240 private water wells within 1/4 mile of the Falcon.
While all of these wells should be assessed for their level of risk with pipeline construction, the subset of wells nearest to horizontal directional drilling (HDD) sites deserve particular attention. HDD is a way of constructing a pipeline that doesn’t involve digging a trench. Instead, a directional drilling machine is used to drill horizontally underground and the pipe is pulled through.
While an HDD is designed to avoid surface impacts, if rushed or poorly executed, it can damage surface water, groundwater, and private property. The Mariner East 2 pipeline construction left several families without water after construction crews punctured an aquifer at an HDD site.
Shell’s data highlights 24 wells that are within 1,000 feet of a proposed HDD site.
We’ve isolated the groundwater wells and HDDs in a standalone map for closer inspection below. The 24 most at-risk wells are circled in blue.
Testing your groundwater quality before construction begins is crucial for determining impacts later on. Two upcoming workshops in Washington County, PA and another in Beaver County, PA will discuss how to protect your water and property.
The Falcon’s HDD locations offer disturbing similarities to what caused the Mariner East pipeline spills. Many of Sunoco’s failures were due to inadequately conducted (or absent) geophysical surveys that failed to identify shallow groundwater tables, which then led to drilling mud entering streams and groundwater.
Figure 1 below shows Greene Township, Beaver County, just south of Hookstown, where the “water table depth” is shown. The groundwater at this HDD site averages 20ft on its western side and only 8ft deep on the eastern side.
The Falcon also crosses the headwaters of two drinking water reservoirs: the Tappan Reservoir in Harrison County, OH (Figure 2) and the Ambridge Reservoir in Beaver County, PA (Figure 3). The Falcon will also cross the raw water line leading out of the Ambridge Reservoir.
The Ambridge Reservoir supplies water to five townships in Beaver County (Ambridge, Baden, Economy, Harmony, and New Sewickley) and four townships in Allegheny County (Leet, Leetsdale, Bell Acres & Edgeworth). The Tappan Reservoir is the primary drinking water source for residents in Scio.
Wetlands that drain into Raccoon Creek in Beaver County, PA will be particularly vulnerable in 2 locations. The first is in Potter Township, off of Raccoon Creek Rd just south of Frankfort Rd, where the Falcon will run along a wooded ridge populated by half a dozen perennial and intermittent streams that lead directly to a wetland, seen in Figure 4. Complicating erosion control further, Shell’s survey data shows that this ridge is susceptible to landslides. This area is also characterized by the USGS as having a “high hazard” area for soil erosion.
The other wetland area of concern along Raccoon Creek is found in Independence Township at the Beaver County Conservation District (Figure 5). Here, the Falcon will go under the Creek using HDD (highlighted in bright green). 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.
Shell’s analysis shows that 16.8 miles of the Falcon pipeline travel through land that historically has or currently contains coal mines. Our analysis using the same dataset suggests the figure is closer to 20 miles. Construction through undermined areas poses a risk for ground and surface water contamination and subsidence.
Of these 20 miles of undermined pipeline, 5.6 miles run through active coal mines and are located in Cadiz Township, OH (Harrison Mining Co. Nelms Mine, seen in Figure 6); Ross Township, OH (Rosebud Mining Co. Deep Mine 10); and in Greene Township, PA (Rosebud Mining Co. Beaver Valley Mine).
For a complete map of mined areas, click here.
More than 25 of the Falcon’s 97 pipeline miles will be laid within karst landscapes, including 9 HDD sites. Karst is characterized by soluble rocks such as limestone prone to sinkholes and underground caves. A cluster of these are located in Allegheny and Washington counties, PA, with extensive historical surface mining operations.
The combination of karst and coal mines along Potato Garden Run, in Figure 7, make this portion of the pipeline route particularly risky. At this HDD site, the Falcon will cross a coal waste site identified in the permits as “Imperial Land Coal Slurry” along with a large wetland.
Southern Redbelly Dace
The Southern Redbelly Dace, a threatened species, is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PA Fish and Boat Commission explicitly notes in their correspondence with Shell 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 designated “High Quality/Cold Water Fishes” streams of the Service Creek watershed (Figure 8). PFBC stated that that no in-stream work in these locations should be done between May 1 and July 31.
Northern Harriers & Short-Eared Owls
Portions of the Falcon’s workspace are located near 6 areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species). Pennsylvania Game Commission requested a study of these areas to identify breeding and nesting locations, which were 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. PGC’s determined 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.
A known Bald Eagle nest is located in Beaver County. Two potential “alternate nests” are 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. The 1 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.
U.S. Fish and Wildlife Service requested that Shell only implement setback buffers for the one active nest at Montgomery Dam (Figure 10). 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.
The Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia. In pre-construction surveys, 17 Northern Long-eared Bats were found at 13 of the survey sites, but no Indiana Bats were captured.
A total of 9 Northern Long-eared Bat roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace. Figure 11 below shows a cluster of roost trees in Raccoon Township, PA. For a map of all the roost trees, click here. The U.S. Fish and Wildlife Service 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.”
The Pennsylvania Game Commission noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). 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.
For more information on the wildlife impacts of the Falcon Pipeline, click here.
To continue reading about this pipeline, visit the Falcon Public EIA Project.
By documenting the impacts of the Falcon Pipeline, you’re contributing to a growing body of work that shows the risks of fossil fuel pipelines. Not only does this evidence protect drinking water and vulnerable species, it serves as evidence against an inherently dangerous project that will contribute to climate change and the global plastics crisis.
We hope you’re inspired to take action and add your voice to a growing team in the region committed to safer and healthier environments. Thank YOU for your dedication to the cause!
By Erica Jackson, Community Outreach and Communications Specialist, FracTracker Alliance.
Portions of this article were adapted from previous posts in the Falcon Public EIA Project, written by Kirk Jalbert.
How the frac sand industry is circumventing local control, plus where the industry is migrating
What is nonmetallic mineral mining?
It was more than a year and half ago that anti-frac sand organizer – and movement matriarch – Pat Popple published a white paper by attorney Elizabeth Feil in her Frac Sand Sentinel newsletter. The paper outlined potential impacts of something the Wisconsin Department of Natural Resources (DNR) calls the “Marketable Nonmetallic Mineral Deposit Registration” (MNMDR) program.
The program, passed in 2000, is outlined in Wisconsin’s administrative code under Subchapter VI “Registration of Marketable Nonmetallic Mineral Deposits (NR 135.53-NR 135.64). This program allows landowners to register parcels that sit atop marketable nonmetallic mineral deposits, such as frac sand, according to a licensed professional geologist. The geologist uses “logs or records of drilling, boring, geophysical surveys, records of physical inspections of outcrops or equivalent scientific data” to outline the quality, extent, depth, accessibility, and current market value of the minerals.
If a mine operator is not the landowner, it must first coordinate registration with the landowner to:
… provide protection against present or future land uses, such as the erection of permanent structures, that would impede their development…to promote more orderly future development of identified nonmetallic mineral resources and minimize conflict among land uses.
Where is frac sand mining occurring in Wisconsin?
Photos by Ted Auch, Fractracker Alliance, and aerial support provided by LightHawk
Limitations of the registration program
The only requirement under this program is that the landowner “provide evidence that nonmetallic mining is a permitted or conditional use for the land under zoning in effect on the day in which notice is provided to the zoning authorities.” All registrations must be recorded in the county’s registrar of deeds 120 days before filing the registration. This process results in zoning authorities having a 60-day window to determine if they support or object to registrations in circuit courts.
Once counties are notified, they have no recourse for objection aside from proving that the deposit is not marketable or the parcel is not zoned for mining.
As Ms. Feil wrote, this program “preserves…[parcel] eligibility for nonmetallic mining in the future, even if a local governing body later passes new mining restrictions.” The former will have already been proven by the licensed geologist, and the latter is highly unlikely given lax or non-existent zoning in rural Wisconsin, where many land parcels are outside incorporated townships. Any parcel registered on this program remains in the program for a 10 year period and may be automatically re-registered under the initial geological assessment for another 10 year term “at least 10 days and no more than one year before registration expires.”
After this 20-year period, parcels start from scratch with respect to the registration process.
Initial inquiry and map methodology
As part of her white paper, Ms. Feil noted that in a quick check of her home county’s register of deeds, she found six nonmetallic mineral deposit registrations since 2000 in Trempealeau County and nine in neighboring Chippewa County. As a result of Ms. Feil’s initial inquiry, we decided it would be worth conducting a sweeping search for all nonmetallic parcel registrations in the nine most heavily frac sand-mined Wisconsin counties: Trempealeau, Barron, Crawford, Chippewa, Monroe, Jackson, Clark, Dunn, and Eau Claire.
“Wisconsin Nonmetallic Mineral Deposit Parcel Registrations and Likely Mine Parcels” Map
We were fortunate enough to receive funding from the Save The Hills Alliance (STHA) to conduct this research. We received “boots on the ground” assistance from the likes of Ms. Feil, Ms. Popple, and several other volunteers for acquiring hard copies of registrations as of the summer of 2018.
Our goal was to construct a map that would provide a predictive and dynamic tool for residents, activists, non-profits, researchers, local governments, and journalists to understand the future scale and scope of frac sand mining across West Central Wisconsin. We hope this will inspire a network of citizen scientists and mapping tools that can serve as a model for analogous efforts in Illinois, Minnesota, and Southeastern Michigan.
In addition to identifying parcels falling under Wisconsin DNR’s MNMDR registration program, we also used Wisconsin’s State Cartographer’s Office and Land Information Program “V4 Statewide Parcel Data” to extract all parcels:
- Currently owned by active or historically relevant frac sand mine operators and their subsidiaries,
- Owned by families or entities that have allowed for mining to occur on their property and/or have registered parcels under the MNMDR program, and,
- All cranberry production parcels in Wisconsin frac sand counties – namely Monroe, Jackson, Clark, Wood, and Eau Claire, with Monroe, Jackson, and Wood the state’s top producing counties by acreage.
The latter were included in the map because Wisconsin DNR identified the importance of cranberry bogs in their Silica Sand Mining in Wisconsin January 2012 report. The report defined the “Cranberry Exemption” as follows:
Some of the counties in central Wisconsin that are seeing an increase in frac sand mining are also home to much of the state’s cranberry farming. Mining sand is a routine practice in the process of raising cranberries. Growers use sand in the cranberry beds to provide adequate drainage for the roots of the cranberry plants. The sand prevents root rot and fosters plant growth. Chapter 94.26, Wis. Stats, was established in 1867 and exempts cranberry growers from much of the laws applying to waters of the state under Chapter 30, Wis. Stats. With this exemption in place cranberry growers can, in theory, mine sand wherever and however they desire for use in cranberry production. Some cranberry growers are taking advantage of the high demand for sand and are selling their sand on the frac sand market (emphasis added). However, the Department has recently determined that the exemption in Ch. 94.26, Wis. Stats., from portions of Chapters 30 and 31, Wis. Stats., for cranberry culture is not applicable to non-metallic mining sites where a NR 216, W is. Adm. Code, stormwater permit is required. For those non-metallic mining operations where the material is sold and hauled off site, Chapters 30 and 31, Wis. Stats., jurisdiction will be applied.
Finally, the last data layer we’ve included in this map speaks to the enormous volumes of subsurface water that the industrial sand mining industry has consumed since 2010. This layer includes monthly and annual water volume withdrawals by way of 137 industrial sand mine (i.e., IN 65) high capacity wells (Our thanks to Wisconsin DNR Water Supply Specialist – Bureau of Drinking Water and Groundwater’s Bob Smail for helping us to compile this data.)
We have coupled that data to annual tonnages in order to quantify gallons per ton ratios for several mines across several years.
Below is the completed map of current and potential frac sand mines in West Central Wisconsin, as well as high capacity wells. Click on the features of the map for more details.
We identified 4,049 nonmetallic parcel registration and existing sand mine operator parcels totaling 113,985 acres or 178 square miles spread across 14 counties in West Central Wisconsin (Table 1). The largest parcel sizes were U.S. Silica’s 398-acre parcel in Sparta, Monroe County and Badger Mining’s 330-acre parcel in St. Marie, Green Lake County. The average parcel is a mere 28 acres.
To put these figures in perspective, back in 2013 we quantified the full extent of land-use change associated with frac sand mining in this same region and found that the 75 active mines at the time occupied a total of 5,859 acres and averaged roughly 75 acres in size. This means that if current parcel ownership and nonmetallic parcel registrations run their course, the impact of frac sand mining from a land-use perspective could potentially increase by 1,900%!
This is an astounding development and would alter large chunks of West Central Wisconsin’s working landscape, dairy industry, and “Badger State” mentality forever.
Table 1. Nonmetallic or operator-owned frac sand parcels and their total and average acreage in 14 West Central Wisconsin counties
|County||Number of Parcels||Total Acreage||Average Parcel Acreage|
As for the “Cranberry Exemption” identified by Wisconsin DNR, we identified an additional 3,090 cranberry operator or family-owned parcels totaling 98,217 acres or 153 square miles – nearly equal to the acreage identified above. Figure 1 shows the extent of cranberry bog parcels and frac sand mines in Monroe, Wood, and Jackson Counties. The two largest parcels in this inquiry were the 275-acre parcel owned by Fairview Cranberry in Monroe County and a 231 acre-parcel owned by Ocean Spray in Wood County. Interestingly, the former is already home to a sizeable (i.e., 266 acres) frac sand mine operated by Smart Sand pictured and mapped in Figure 2.
In total, the potential for mine expansion in West Central Wisconsin could consume an additional 212,202 acres or 331 square miles. Characterized by dairy farms, and also known as The Driftless Area, this region is where Aldo Leopold penned his masterpiece, A Sand County Almanac. To give a sense of scale to these numbers, it is worth noting that this type of acreage would be like clearing an area the size of the Dallas-Fort Worth metropolis.
Project limitations and emerging concerns
After completing this project, Liz Feil, Pat Popple, and I got on the phone to discuss what we perceived to be its limitations, as well as their concerns with the process and the implications of the MNMDR program, which are listed below:
1. Both Liz and Pat found that when they visited certain counties to inquire as to parcel registrations, most of the registrars of deeds had very little, if any, idea as to what they were talking about, which begged the questions:
- Why does Wisconsin not have a uniform protocol and archival process for such registrations?
- What are the implications of this program with respect to county and township taxable lands, future zoning, and/or master planning?
- What does this program mean for surface and mineral rights ownership in Wisconsin, a state where these two are coupled or decoupled on a parcel by parcel basis?
2. Liz and Pat felt they ended up teaching county registrars more about this registration process during this exercise than they ended up learning themselves.
3. Given the potential ramifications of these types of programs, such registrations should be centrally archived rather than archived at disparate sites across the state. Registrations should be explicitly bolted onto efforts like the aforementioned statewide V4 Statewide Parcel Data, given the fact that the MNMDR parcels are registered for 10 years.
The footprint of frac sand mining at any one point is just a glimpse into how vast its influence could be in the future. Mapping parcel ownership like we’ve done gives people a more realistic sense for the scale and scope of mining in the future and is a more realistic way to analyze the costs/benefits of such an industry. This type of mapping exercise would have greatly benefited those that live in the coal fields of Appalachia and the Powder River Basin as they began to debate and regulate mining, rather than the way they were presented with proposals as smaller discrete operations.
This piecemeal process belies the environmental and social impact of any industrial process, which frac sand mining very much is.
Industrial sand mining and high capacity wells
There is a growing concern, based on a thorough analysis of the data, that the High Volume Hydraulic Fracturing (HVHF) industry’s unquenchable thirst for freshwater is growing at an unsustainable rate. Here at FracTracker, we have been quantifying the exponential increase in HVHF water use, namely in Ohio’s Muskingum River Watershed and northern West Virginia, for more than five years now. More recently, Duke University’s Avner Vengosh has conducted a thorough national analysis of this trend.
While the trends in HVHF water use and waste production are disturbing, such analysis leaves out the water industry uses to mine and process frac sand, or “proppant” in places like Wisconsin, Minnesota, and Illinois. Failure to incorporate such values in an analysis of HVHF’s impact on freshwater, both surface and subsurface, grossly underestimates the industry’s impact on watersheds and competing water uses.
Figure 3 shows monthly and cumulative water demand of frac sand mining. The first thing to point out is the marked seasonal disparities in water withdrawals due to the fact that many of Wisconsin’s frac sand mines go dormant during the winter and ramp up as soon as the ground thaws. The most important result of this work is that we finally have a sense for the total volumes of water permanently altered by the frac sand mining industry:
An astounding 30 billion gallons of water were used between January 2010 and December 2017
This figure is equivalent to the annual demand of ~72,500 US residents (based on an assumption of 418,184 gallons per year). This figure is also equivalent to between 2,179 and 3,051 HVHF wells in Ohio/West Virginia.
Figure 3. Cumulative and monthly water demand by Wisconsin’s frac sand mine Hi-Cap wells, January 2010-December 2017
Figure 4 shows water use by operator. The worst actors with respect to water withdrawals over this period were two wells serving Hi-Crush’s active Wyeville mine that in total used 9.6 billion gallons of subsurface water. Covia Holdings, formerly Unimin and Fairmount Santrol, utilized 5.8 billion gallons in processing an undisclosed amount of frac sand at their Tunnel City mine. Covia’s neighboring mine in Oakdale, owned by Wisconsin White Sand and Smart Sand, used more than 2.5 billion gallons during this period spread across six high-capacity wells.
Figure 4. Total water usage by operator, January 2010-December 2017
These tremendous water volumes prompted us to ask whether we could determine the amount of water needed to mine a typical ton of Wisconsin frac sand. There are numerous issues with data quality and quantity at the individual mine level and those issues stretch from the USGS all the way down to individual townships. However, some townships do collect tonnage records and/or “Fees Tied to Production” from mine operators which allow us to quantify productivity. Using this scant data and the above water volume data we were able to determine “gallons to tons of sand mined” ratios for the years of 2013, 2014, 2015, and/or 2017 for four mines and those ratios range between 30-39 to as much as 521 gallons of water per ton of sand (Table 2).
Table 2. Gallons of water per ton of sand mined for four Wisconsin frac sand mines, 2013-2017
|Gallon Per Ton|
|Wisconsin Industrial Sand||Maiden Rock Facility||Maiden Rock||Pierce||98||90||66||—|
|Thompson, Terry||Thompson Hills Mine||Chetek||Barron||—||30||521||—|
|CSP||Rice Lake Mine||Rice Lake||Barron||—||—||—||104|
For far too long we’ve been monitoring frac sand mining retrospectively or in the present tense. We’ve had very little data available to allow for prospective planning or to model the impact of this industry and its role in the Hydraulic Fracturing Industrial Complex writ large. Given what we are learning about the fracking industry’s insatiable appetite for water and sand, it is imperative that we understand where frac sand mining will occur if this appetite continues to grow (as we expect it may, given the current political environment at the state and federal level).
Three examples of this growing demand can be found in our work across the Great Lakes:
1) With the new age of what the HVHF industry is calling “Super Laterals”, between 2010 and 2017 we saw average proppant demand jump nearly six-fold to roughly 25-30 thousand tons per lateral.
2) In Le Sueur County, MN Covia – which is a recent merger of silica mining giants Unimin and Fairmount Santrol – has plans and/or parcel ownership speaking to the potential for an 11-fold increase in their mining operations, which would increase acreage from 560 to 6,500 acres (if sand demand increases at its current clip) (Figures 5 and 6).
3) As we’ve previously highlighted, the potential outside Detroit, Michigan for US Silica to expand its current frac sand mining operations would displace hundreds of families. The planned expansion would grow their mine from its current 650-acre footprint to nearly 1,400 acres in the town of South Rockwood, Monroe County (Figure 7).
Given our experience mapping and quantifying the current and future impact of frac sand mining in states with limited mining activity, we felt it was critical that we apply this methodology to the state where industry is mining a preponderance of frac sand. However, this analysis was rendered a bit more complicated by the presence of the MNMDR program and Wisconsin DNR’s “Cranberry Exemption.” Adding to the challenge is the fact that many in Wisconsin’s frac sand communities demanded that we address the tremendous volumes of water being used by the industry and work to incorporate such data into any resulting map.
We hope that this map allows Wisconsin residents to act in a more offensive and prospective way in voicing their concerns, or simply to become better informed on how sand mining has impacted other communities, will influence them, and what the landscape could look like in the future.
It is critical that we see sand mining not as discrete mines with discrete water demands but rather as a continuum, or better yet an ecosystem, that could potentially swallow large up sizeable chunks of Western Wisconsin.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance
P.S. We’ll continue to add MNMDR registered parcels periodically. As parcels change ownership, we will be sure to update both the cranberry bog and industry owned parcel inventory in the comings months and years.
In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.
Just a heads up… there are a lot.
Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.
Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.
Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.
Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:
- Wetlands, rivers, streams
- Stormwater control
- Public health and safety (drinking water & trails)
- Conservation areas
- Alternative routes
- Geological concerns (including mining issues)
- Documentation issues
1. Wetlands, Rivers, & Streams
Water withdrawal from rivers and discharge
- B2 A2 W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
- B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.
Wetlands and Streams
- B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline. Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site because they did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
- B6 A4 W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
- B7 A5 W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
- B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
- B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
- A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
- B13 A10 W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
- B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List). Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
- B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
- B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
- B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
- B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
- B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:
2. Stormwater control
- B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
- W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.
3. Public health and safety
- B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
- B10 A8 W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
- Youthtowne Barn
- Beaver County Conservation District
- Independence Elementary School
- Independence Volunteer Fire Department
- McConnell’s Farm and Market, Inc
- Ambridge Water Authority- Independence Township
- Ambridge Water Authority- Raccoon Township
- Hookstown Free Methodist Church
- Hookstown Fair
- Hookstown Grange
- South Side Memorial Post 952
- Jack’s Diner
- NOVA Chemical, Inc
- B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
- B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD 31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
- A17 W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
- B29 A27 W27 Shell needed to revise the “Shell Pipeline HDD Procedure” to include HDD site feasibility analysis, inadvertent return risk assessment, water supply protection, agency contact information, etc. Shell’s response is included in the document, Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan.
- B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.
- B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
- Ambridge Reservoir Valleys Natural Heritage Area
- Lower Raccoon Creek Natural Heritage Area
- Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
- Raccoon Creek Floodplain Biologically Diverse Area
- Raccoon Creek Landscape Conservation Area
- Clinton Wetlands Biologically Diverse Area
- Raccoon Creek Landscape Conservation Area
- Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District. Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.” Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.
5. Alternative locations
- B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
- B18 16A 16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
- B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.
6. Geological concerns
- B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
- B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
- B16 A14 14W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
- B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.
- B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
- B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
- B25 A23 W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
- B34 A32 W32 The DEP asked Shell to include a copy of the Preparedness, Prevention, and Contingency Plan.
- B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.
As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.
By Erica Jackson, Community Outreach and Communications Specialist