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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/03/TAuch_Transportation-RoverPipeline_Construction-EnergyTransferPartners-Woodsfield_OH_May2017.jpg5761500Karen Edelsteinhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKaren Edelstein2022-11-30 17:50:122022-11-30 17:52:48A Contentious Landscape of Pipeline Build-outs in the Eastern US
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/11/DSC_1359_HighRes.jpg10001500FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2022-11-23 15:15:112023-03-03 10:28:05Coursing Through Gasland: A Digital Atlas Exploring Natural Gas Development in the Towanda Creek Watershed
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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2022/08/51119572588_132e0366c1_k_1-e1663254774314.jpg6071364Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2022-08-31 14:33:482022-09-15 16:29:45Carbon Capture and Storage: Developments in the Law of Pore Space in North Dakota
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.
Figure 1. The interconnected relationship between fracking operations, landscape changes and decreasing access to outdoor recreation, 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.
Figure 2. Examples of changes in the physical landscape caused from fracking operations in Greene County (A) and Washington County (B), Pennsylvania. Images taken from Google Earth.
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.”
Figure 4. Aerial view of oil and gas infrastructure next to a home in Scenery Hill, PA. Image courtesy of Lois Bower-Bjornson from the Clean Air Council.
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.
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
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/08/Fracking-SW-PA-feature-Lois-Bower-Bjornson-scaled.jpg6671500Intern FracTrackerhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngIntern FracTracker2020-08-20 11:07:572021-04-28 11:54:19Landscape Changes and Mental Health Impacts in Southwestern Pennsylvania Communities: A Qualitative Study
Challenges have plagued Shell’s construction of the Falcon Pipeline System through Pennsylvania, Ohio, and West Virginia, according to documents from the Pennsylvania Department of Environmental Protection (DEP) and the Ohio Environmental Protection Agency (EPA).
Records show that at least 70 spills have occurred since construction began in early 2019, releasing over a quarter million gallons of drilling fluid. Yet the true number and volume of spills is uncertain due to inaccuracies in reporting by Shell and discrepancies in regulation by state agencies.
A drilling fluid spill from Falcon Pipeline construction near Moffett Mill Road in Beaver County, PA. Source: Pennsylvania DEP
Releases of drilling fluid during Falcon’s construction include inadvertent returns and losses of circulation – two technical words used to describe spills of drilling fluid that occur during pipeline construction.
Drilling fluid, which consists of water, bentonite clay, and chemical additives, is used when workers drill a borehole horizontally underground to pull a pipeline underneath a water body, road, or other sensitive location. This type of installation is called a HDD (horizontal directional drill), and is pictured in Figure 1.
Figure 1. An HDD operation – Thousands of gallons of drilling fluid are used in this process, creating the potential for spills. Click to expand. Source: Enbridge Pipeline
Here’s a breakdown of what these types of spills are and how often they’ve occurred during Falcon pipeline construction, as of March, 2020:
Loss of circulation
Definition: A loss of circulation occurs when there is a decrease in the volume of drilling fluid returning to the entry or exit point of a borehole. A loss can occur when drilling fluid is blocked and therefore prevented from leaving a borehole, or when fluid is lost underground.
Cause: Losses of circulation occur frequently during HDD construction and can be caused by misdirected drilling, underground voids, equipment blockages or failures, overburdened soils, and weathered bedrock.
Construction of the Falcon has caused at least 49 losses of circulation releasing at least 245,530 gallons of drilling fluid. Incidents include:
15 losses in Ohio – totaling 73,414 gallons
34 losses in Pennsylvania – totaling 172,116 gallons
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)
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.
Our investigation into these incidents began early this year when we received an anonymous tip about a release of drilling fluids in the range of millions of gallons at the SCIO-06 HDD over Wolf Run Road in Jefferson County, Ohio. The source stated that the release could be contaminating drinking water for residents and livestock.
Working with Clean Air Council, Fair Shake Environmental Legal Services, and DeSmog Blog, we quickly discovered that this spill was just the beginning of the Falcon’s construction issues.
Documents from the Ohio EPA confirm that there were at least eight losses of circulation at this location between August 2019 and January 2020, including losses of unknown volume. The SCIO-06 HDD location is of particular concern because it crosses beneath two streams (Wolf Run and a stream connected to Wolf Run) and a wetland, is near groundwater wells, and runs over an inactive coal mine (Figure 2).
Figure 2. Losses of circulation that occurred at the SCIO-06 horizontal directional drill (HDD) site along the Falcon Pipeline in Jefferson County Ohio. Data Sources: OH EPA, AECOM
According to Shell’s survey, the coal mine (shown in Figure 2 in blue) is 290 feet below the HDD crossing. A hazardous scenario could arise if an HDD site interacts with mine voids, releasing drilling fluid into the void and creating a new mine void discharge.
A similar situation occurred in 2018, when EQT Corp. was fined $294,000 after the pipeline it was installing under a road in Forward Township, Pennsylvania hit an old mine, releasing four million gallons of mine drainage into the Monongahela River.
The Ohio EPA’s Division of Drinking and Ground Waters looked into the issues around this site and reported, “GIS analysis of the pipeline location in Jefferson Co. does not appear to risk any vulnerable ground water resources in the area, except local private water supply wells. However, the incident location is above a known abandoned (pre-1977) coal mine complex, mapped by ODNR.”
While we cannot confirm if there was a spill in the range of millions of gallons as the source claimed, the reported losses of circulation at the SCIO-06 site total over 60,000 gallons of drilling fluid. Additionally, on December 10th, 2019, the Ohio EPA asked AECOM (the engineering company contracted by Shell for this project) to estimate what the total fluid loss would be if workers were to continue drilling to complete the SCIO-06 crossing. AECOM reported that, in a “very conservative scenario based on the current level of fluid loss…Overall mud loss to the formation could exceed 3,000,000 gallons.”
Despite this possibility of a 3 million+ gallon spill, Shell resumed construction in January, 2020. The company experienced another loss of circulation of 4,583 gallons, reportedly caused by a change in formation. However, in correspondence with a resident, Shell stated that the volume lost was 3,200 gallons.
Whatever the amount, this January loss of circulation appears to have convinced Shell that an HDD crossing at this location was too difficult to complete, and in February 2020, Shell decided to change the type of crossing at the SCIO-06 site to a guided bore underneath Wolf Run Rd and open cut trench through the stream crossings (Figure 3).
Figure 3. The SCIO-06 HDD site, which may be changed from an HDD crossing to an open cut trench and conventional bore to cross Wolf Run Rd, Wolf Run stream (darker blue), an intermittent stream (light blue) and a wetland (teal). Click to expand.
An investigation by DeSmog Blog revealed that Shell applied for the route change under Nationwide Permit 12, a permit required for water crossings. While the Army Corps of Engineers authorized the route change on March 17th, one month later, a Montana federal court overseeing a case on the Keystone XL pipeline determined that the Nationwide Permit 12 did not meet standards set by federal environmental laws – a decision which may nullify the Falcon’s permit status. At this time, the ramifications of this decision on the Falcon remain unclear.
Inconsistencies in Reporting
In looking through Shell’s loss of circulation reports, we noted several discrepancies about the volume of drilling fluid released for different spills, including those that occurred at the SCIO-06 site. As one example, the Ohio EPA stated an email about the SCIO-06 HDD, “The reported loss of fluid from August 1, 2019 to August 14, 2019 in the memo does not appear to agree with the 21,950 gallons of fluid loss reported to me during my site visit on August 14, 2019 or the fluid loss reported in the conference call on August 13, 2019.”
In addition to errors on Shell’s end, our review of documents revealed significant confusion around the regulation of drilling fluid spills. In an email from September 26, 2019, months after construction began, Shell raised the following questions with the Ohio EPA:
when a loss of circulation becomes an inadvertent return – the Ohio EPA clarifies: “For purposes of HDD activities in Ohio, an inadvertent return is defined as the unintended return of any fluid to the surface, as well as losses of fluids to underground formations which exceed 50-percent over a 24-hour period and/or 25-percent loss of fluids or annular pressure sustained over a 48-hour period;”
when the clock starts for the aforementioned time periods – the Ohio EPA says the time starts when “the drill commences drilling;”
whether Shell needs to submit loss of circulation reports for losses that are less than the aforementioned definition of an inadvertent return – the Ohio EPA responds, “No. This is not required in the permit.”
How are these spills measured?
A possible explanation for why Shell reported inconsistent volumes of spills is because they were not using the proper technology to measure them.
Shell’s “Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan” states that drilling rigs must be equipped with “instruments which can measure and record in real time, the following information: borehole annular pressure during the pilot hole operation; drilling fluid discharge rate; the spatial position of the drilling bit or reamer bit; and the drill string axial and torsional loads.”
In other words, Shell should be using monitoring equipment to measure and report volumes of drilling fluid released.
Despite that requirement, Shell was initially monitoring releases manually by measuring the remaining fluid levels in tanks. After inspectors with the Pennsylvania DEP realized this in October, 2019, the Department issued a Notice of Violation to Shell, asking the company to immediately cease all Pennsylvania HDD operations and implement recording instruments. The violation also cited Shell for not filing weekly inadvertent return reports and not reporting where recovered drilling fluids were disposed.
In Ohio, there is no record of a similar request from the Ohio EPA. The anonymous source that originally informed us of issues at the SCIO-6 HDD stated that local officials and regulatory agencies in Ohio were likely not informed of the full volumes of the industrial waste releases based on actual meter readings, but rather estimates that minimize the perceived impact.
While we cannot confirm this claim, we know a few things for sure: 1) there are conflicting reports about the volume of drilling fluids spilled in Ohio, 2) according to Shell’s engineers, there is the potential for a 3 million+ gallon spill at the SCIO-06 site, and 3) there are instances of Shell not following its permits with regard to measuring and reporting fluid losses.
The inconsistent ways that fluid losses (particularly those that occur underground) are defined, reported, and measured leave too many opportunities for Shell to impact sensitive ecosystems and drinking water sources without being held accountable.
What are the impacts of drilling fluid spills?
Drilling fluid is primarily composed of water and bentonite clay (sodium montmorillonite), which is nontoxic. If a fluid loss occurs, workers often use additives to try and create a seal to prevent drilling fluid from escaping into underground voids. According to Shell’s “Inadvertent Returns From HDD” plan, it only uses additives that meet food standards, are not petroleum based, and are consistent with materials used in drinking water operations.
However, large inadvertent returns into waterways cause heavy sedimentation and can have harmful effects on aquatic life. They can also ruin drinking water sources. Inadvertent returns caused by HDD construction along the Mariner East 2 pipeline have contaminated many water wells.
Losses of circulation can impact drinking water too. This past April in Texas, construction of the Permian Highway Pipeline caused a loss that left residents with muddy well water. A 3 million gallon loss of circulation along the Mariner East route led to 208,000 gallons of drilling mud entering a lake, and a $2 million fine for Sunoco, the pipeline’s operator.
Our Falcon Public EIA Project found 240 groundwater wells within 1/4 mile of the pipeline and 24 within 1,000 ft of an HDD site. The pipeline also crosses near surface water reservoirs. Drilling mud spills could put these drinking water sources at risk.
But when it comes to understanding the true impact of the more than 245,000+ gallons of drilling fluid lost beneath Pennsylvania and Ohio, there are a lot of remaining questions. The Falcon route crosses over roughly 20 miles of under-mined land (including 5.6 miles of active coal mines) and 25 miles of porous karst limestone formations (learn more about karst). Add in to the mix the thousands of abandoned, conventional, and fracked wells in the region – and you start to get a picture of how holey the land is. Where or how drilling fluid interacts with these voids underground is largely unknown.
Other Drilling Fluid Losses
In addition to the SCIO-04 HDD, there are other drilling fluid losses that occurred in sensitive locations.
In Robinson Township, Pennsylvania, over a dozen losses of circulation (many of which occurred over the span of several days) released a reported 90,067 gallons of drilling fluid into the ground at the HOU-04 HDD. This HDD is above inactive surface and underground mines.
The Falcon passes through and near surface drinking water sources. In Beaver County, Pennsylvania, the pipeline crosses the headwaters of the Ambridge Reservoir and the water line that carries out its water for residents in Beaver County townships (Ambridge, Baden, Economy, Harmony, and New Sewickley) and Allegheny County townships (Leet, Leetsdale, Bell Acres, and Edgeworth). The group Citizens to Protect the Ambridge Reservoir, which formed in 2012 to protect the reservoir from unconventional oil and gas infrastructure, led efforts to stop Falcon Construction, and the Ambridge Water Authority itself called the path of the pipeline “not acceptable.”In response to public pressure, Shell did agree to build a back up line to the West View Water Authority in case issues arose from the Falcon’s construction.
Unfortunately, a 50-gallon inadvertent return was reported at the HDD that crosses the waterline (Figure 4), and a 160 gallon inadvertent return occurred in Raccoon Municipal Park within the watershed and near its protected headwaters (Figure 5). Both of these releases are reported to have occurred within the pipeline’s construction area and not into waterways.
Figure 4) HOU-10 HDD location on the Falcon Pipeline, where 50 gallons were released on the drill pad on 7/9/2019
Figure 5) SCIO-05 HDD location on the Falcon Pipeline, where 160 gallons were released on 6/10/19, within the pipeline’s LOD (limit of disturbance)
Farther west, the pipeline crosses through the watershed of the Tappan Reservoir, which provides water for residents in Scio, Ohio and the Ohio River, which serves over 5 million people.
A 35- gallon inadvertent return occurred at a conventional bore within the Tappan Lake Protection Area, impacting a wetland and stream. We are not aware of any spills impacting the Ohio River.
Pipelines in a Pandemic
This investigation makes it clear that weak laws and enforcement around drilling fluid spills allows pipeline construction to harm sensitive ecosystems and put drinking water sources at risk. Furthermore, regulations don’t require state agencies or Shell to notify communities when many of these drilling mud spills occur.
The problem continues where the 97-mile pipeline ends – at the Shell ethane cracker. In March, workers raised concerns about the unsanitary conditions of the site, and stated that crowded workspaces made social distancing impossible. While Shell did halt construction temporarily, state officials gave the company the OK to continue work – even without the waiver many businesses had to obtain.
The state’s decision was based on the fact it considered the ethane cracker to “support electrical power generation, transmission and distribution.” The ethane cracker – which is still months and likely years away from operation – does not currently produce electrical power and will only provide power generation to support plastic manufacturing.
This claim continues a long pattern of the industry attempting to trick the public into believing that we must continue expanding oil and gas operations to meet our country’s energy needs. In reality, Shell and other oil and gas companies are attempting to line their own pockets by turning the country’s massive oversupply of fracked gas into plastic. And just as Shell and state governments have put the health of residents and workers on the line by continuing construction during a global pandemic, they are sacrificing the health of communities on the frontlines of the plastic industry and climate change by pushing forward the build-out of the petrochemical industry during a global climate crisis.
This election year, while public officials are pushing forward major action to respond to the economic collapse, let’s push for policies and candidates that align with the people’s needs, not Big Oil’s.
By Erica Jackson, Community Outreach & Communications Specialist, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2020/06/FalconPipelineFrontPage-scaled.jpg4301500Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngErica Jackson2020-06-16 11:47:062021-04-15 14:16:44Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/DSC_0624_LowRes-scaled.jpg9821500Shannon Smithhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngShannon Smith2019-08-07 09:36:032020-03-20 17:32:33Wildness Lost – Pine Creek
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.
Residents of southwest PA gather along the Falcon route
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.
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.
Figure 1. Water table depth in Greene Township
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.
Figure 2. Tappan Reservoir and the Falcon route in Harrison County, Ohio
Figure 3. Ambridge Reservoir and the Falcon route in Beaver County, Pennsylvania
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.
Figure 4. Wetlands and streams in Potter Township, PA
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.
Figure 5. Wetlands and Raccoon Creek in Independence Township, PA
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).
Figure 6. Coal mines and are located in Cadiz Township, OH
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.
Figure 7. Coal mines in Imperial, Pennsylvania
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.
Figure 8. “High Quality/Cold Water Fishes” streams identified as habitat for the Southern Redbelly Dace
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.
Figure 9. Surveyed areas for Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species)
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.
Figure 10. Bald Eagle nest in Potter Township, Pennsylvania
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.
Figure 11. Northern long-eared bat roost trees in Raccoon Township, Pennsylvania
For more information on the wildlife impacts of the Falcon Pipeline, click here.
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.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/05/PipelineConstructionFeature.png6671500Erica Jacksonhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngErica Jackson2019-05-08 08:27:302021-04-15 14:56:31The Falcon Public Monitoring Project
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.
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%!
Table 1. Nonmetallic or operator-owned frac sand parcels and their total and average acreage in 14 West Central Wisconsin counties
Number of Parcels
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.
Figure 1. Cranberry bog parcels and frac sand mines in the Wisconsin counties of Monroe, Jackson, and Wood
Figure 2. Current and potential extent of Smart Sand’s Fairview Cranberry frac sand mine, Tomah, Monroe County, Wisconsin
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
Thompson Hills Mine
Rice Lake Mine
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:
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).
Figure 5. Unimin’s current 560-acre frac sand mine parcel in Kasota, Le Sueur County
Figure 6. The potential 6,500 extent of Unimin mining by way of parcel ownership search
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).
Figure 7. US Silica’s current (642 acres) and potential (1,341 acres) frac sand mine footprint in Monroe County, Michigan.
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
Public health and safety (drinking water & trails)
Geological concerns (including mining issues)
A = Allegheny County, B = Beaver County, W = Washington County. The numbers reference the number listed in the deficiencies letter.
1. Wetlands, Rivers, & Streams
Water withdrawal from rivers and discharge
B2A2W2 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 becausethey 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 A4W5 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 A5W6 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 A10W11 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 A8W9 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:
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
South Side Memorial Post 952
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.
A17W17 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.
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 16A16W 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 A1414W 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 A23W23 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.”
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.
Of note: The DEP’s letters and Shell’s response to them are available to the public in separate documents for Allegheny, Beaver, and Washington Counties.
By Erica Jackson, Community Outreach and Communications Specialist