The majority of FracTracker’s posts are generally considered articles. These may include analysis around data, embedded maps, summaries of partner collaborations, highlights of a publication or project, guest posts, etc.

Re-imagine Beaver County meeting - Photo by Sophie Riedel
FracTracker Alliance

Mapping a new vision in PA: Alternatives to petrochemical development

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At a Re-Imagine Beaver County gathering in Pennsylvania earlier this month, static maps became dynamic in the hands of those who live in and around the region depicted. Residents of this area in the greater Pittsburgh region gathered to depict a new vision for Beaver County, PA. This county is currently faced with the proposal of a massive Shell-owned petrochemical facility – also called a “cracker” – and further build-out that could render the area a northern version of Louisiana’s “Chemical Corridor.” Participants at this event, from Beaver County and beyond, were encouraged to collectively envision a future based on sustainable development. The picture they created was one that welcomes change – but requires it to be sustainable and for the benefit of the community that makes it happen.

Re-Imagine Beaver County Group Mapping - by Sophie Riedel

Figure 1: Participants study a map of Beaver County. Photo credit: Sophie Riedel.

Re-Imagine Beaver County Participants

Panelists from municipal government, organic agriculture, and leaders and entrepreneurs of sustainable initiatives started off the event, sponsored by the League of Women Voters of Pennsylvania and endorsed by the Beaver County Marcellus Awareness Committee. After an hour, the room of 60 or so participants dove into the lively de- and re-construction of large format maps of the area. They were invited to markup the maps, created by Carnegie Mellon University graduate student of the School of Architecture, Sophie Riedel. Each table worked from a different base map of the same area – centering on the confluence of the Ohio and Beaver rivers, including the already heavily-industrialized riverside and the site of Shell’s proposed petrochemical facility.

Massive shell processing plant under construction in Beaver County PA and across the Ohio River from the town of Beaver. This massive processing plant, near residential areas, schools and hospitals, will be a serious threat to the health of the those living in the region.

Figure 2: The site of the proposed petrochemical facility in Beaver County (on left) and the Ohio River that participants hope to see reinvented as a recreational waterway buttressed by public parks. Photo credit: Garth Lenz, iLCP.

Much more than a thought exercise, the gathering represented a timely response to a growing grassroots effort around the proposed petrochemical inundation. Changes are already underway at the site, and those who live in this region have the right to give input. This right is especially salient when considering the risks associated with the petrochemical industry – including detrimental health impacts on babies before they are even born, asthma exacerbation, and increased cancer rates.

Charting a new vision

The re-invented Beaver County would be one of increased connectivity and mobility, well-equipped to provide for local needs with local means.

Many ideas included on the maps reflected a longing for transportation options independent of personal vehicles – including better, safer, more connected bike trails and walking paths, use of existing rail lines for local travel, and even the inventive suggestion of a water taxi. These inherently lower-impact means of transport coincide with preferences of millennials, according to several of the panelists, who want more walkable, bikeable communities. Ushering in such sustainable suggestions would welcome more young families to an area with an aging population. More than just about moving people, transportation ideas also included ways to get locally grown foods to those who need it, such as the elderly.

sophie-riedel-visioning-map-close-up

Figure 3: Participants modify maps to reflect a new vision. Photo credit: Sophie Riedel.

The value of beauty was a subtheme in many of the ideas to connect and mobilize the population and goods, ideas which often held a dual aim of protecting open space, creating new parks, and offering recreation possibilities. Participants ambitiously reimagined their river, the Ohio, from its current status as a closed-off corridor for industrial usage and waste, to a recreational resource for kayaking and fishing walleye.

Participants marked up the maps to show the resources that help sustain this community, and voiced a strong desire for development that would enable additional self-reliance. These forward-thinking changes included increased agriculture and use of permaculture techniques, and community gardens for growing food near the people who currently lack access. Ideas for powering the region abounded, like harnessing wind power and putting solar panels on every new building.

Participants were firm on local sourcing for another key resource: the labor required for these efforts, they insisted, must come from the local populace. Educational programs designed to channel learners into workers for sustainability might include training to rebuild homes to “greener” standards, and programs aimed at bringing a new generation of farmers to the fields. Perhaps a nod to the world-wide plastic glut that a petrochemical facility would add to, suggestions even included local ways of dealing with waste, like starting a composting program and establishing more recycling centers.

Whose vision?

Who is a part of this vision, both in creating it and living it out? Inevitably, the selection of panelists and the interests of the audience members themselves influenced the vision this group crafted. The question of inclusion and representation found articulation among many participants, and the hosts of the event welcomed suggestions on reaching a broader audience moving forward. Looking around the room, one man asked, “Where are all the young people, and families with kids?” Indeed, only several members of this demographic were present. Though indicative of the racial makeup of Beaver County, the audience appeared to be primarily white, meaning that the racially diverse communities in the region where not represented. Others pointed out that going forward, the audience should also include those residents struggling with un- and underemployment, who have a major stake in whatever vision of Beaver County comes to fruition. Another said he would like to see more elected officials and leaders present. Notably, Potter Township Board of Supervisors Chairperson, Rebecca Matsco, who is a strong advocate for the proposed petrochemical project in her township, was present for the first half of the event.

Local means for meeting local needs

People who welcome petrochemical development in Beaver County might believe that those who voice concerns about the proposed Shell plant aren’t forward-thinking, or simply oppose change. Quite in contrast, participants at Re-Imagine Beaver County went to work reinventing their community with optimism and enthusiasm. They didn’t seem to be resisting change, but instead, wanting to participate in the process of change and to ultimately see benefits to their community. For example, discussion of solar power generated substantial excitement. According to panel speaker Hal Saville, however, the biggest challenge is making it affordable for everyone, which suggests that the estimated $1.6 billion in tax breaks going to Shell for the petrochemical plant could be better allocated.

A key narrative from supporters of the ethane cracker centers on the pressing need for jobs in this area, though some locals have expressed concern about how many of Shell’s promised jobs would go to residents. Whoever gets hired, these jobs come with serious dangers to workers. Participants at this event proposed alternative initiatives – both ambitious and small – for creating jobs within the community, like providing “sprout funds” to encourage new business start-ups, and launching a coordinated effort to rehab aging housing stock. These ideas suggest that the people of this region feel their energy and ingenuity would be best spent making Beaver County a better place to live and work, in contrast to producing disposable petrochemical products for export around the world. The fact that so many participants emphasized local means for meeting their needs in no way downplays the need for good jobs. Rather, it points to the fact that people want jobs that are good for them and for the future of their community.

Moving the vision forward

Where do we go from here? Can the momentum of this event draw in greater representation from the region to have a voice in this process? Will these visions become animated and guide the creation of a new reality? Broader and deeper planning is in order; participants and panelists alike pointed to tools like comprehensive community plans and cleaner, “greener” industrial policies. More than anything, the group articulated a need for more deliberation and participation. As panelist and farm co-owner Don Kretschmann put it, when it comes to change, we need to “think it through before we go ahead and do it.”

The maps themselves, bearing the inspirations scrawled out during the event, have not reached the end of the road. From here, these maps will accompany an upcoming exhibition of the artworks in Petrochemical America, which locals hope to bring to the greater Pittsburgh area in the coming months. League of Women Voters, for their part, continue to move the vision forward, inviting input from all on next steps, with an emphasis on pulling in a broader cross-section of the community.

To voice your vision, and to stay in the loop on future Re-Imagine Beaver County events, contact reimaginelwvpa@gmail.com.

Many thanks to Sophie Riedel for sharing photographs from the event, and to the International League of Conservation Photographers and the Environmental Integrity Project for sharing the aerial photograph of the Shell site from their joint project, “The Human Cost of Energy Production.”

By Leann Leiter, Environmental Health Fellow

 

34 states with active drilling activity in US map
FracTracker Alliance

34 states have active oil & gas activity in U.S. based on 2016 analysis

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Each year, FracTracker Alliance compiles a national well file to try to assess how many wells have been drilled in the U.S. We do this by extracting data from the various state regulatory agencies that oversee drilling in oil and gas producing states. We’re a little late posting the results of our 2016 analysis, but here it is.

Based on data from 2014-2015, 34 states * saw drilling activity, amounting to approximately 1.2 million facilities across the U.S. – from active production wells, to natural gas compressor stations, to processing plants.

The process we used to count these wells and related facilities for the 2016 analysis changed a bit this time around, which obviously impacts the total number of wells in the dataset. 2016’s compilation was created in consultation with Earthworks, for the purpose of informing the Oil and Gas Threat Map project. The scope was more restrictive than previous editions (see our 2014 and 2015 analyses), focusing only on wells that we were reasonably confident were actively producing oil and gas wells, thus excluding wells with inactive or uncertain statuses, as well salt water disposal (SWD) and other Class II injection (INJ) well types.

There are facilities included in this dataset that we don’t normally tally, as well (See Table 1 below). Earthworks was able to determine the latitude and longitude coordinates of a number of compressors and other processing plants, which are included in the dataset below and final map.

In all, the facility counts are reduced from about 1.7 million in 2015 to about 1.2 million in 2016, but this is more a reflection of the definition than substantial changes in the active well inventory in the U.S. You can explore this information by state, and additional results of this project, using Earthworks’ Threats Maps. Additionally, the national well file is available to download below.

Download 2016 National Well File Data

* The zip file separates out TX wells from the rest of the states due to the significant number of TX facilities.

You’ll notice that we don’t refer to the wells in this analysis as “fracked” wells. The primary reason for not using such terminology is because no one common definition exists across those states for what constitutes a hydraulically fractured well. In PA, for example, such wells are considered “unconventional” because drilling occurs in an unconventional formation and usually involves some sort of well stimulation. Contrastingly, in CA, often drillers use “acidizing” not fracking – a similar process that breaks up the ground using acidic injected fluids instead of the high pressure seen in traditional fracking. As such, we included all active oil and gas production instead of trying to limit the analysis to just wells that have been stimulated. We will likely continue to use this process until a federal or national definition of what constitutes a “fracked” well is determined.

Table 1. Facilities by State and Type

State Count of Facilities by Type Grand Total
Compressor Processor Well
AK 7 3,356 3,363
AL 17 7,016 7,033
AR 231 8 13,789 14,028
AZ 40 40
CA 7 21 92,737 92,765
CO 426 49 50,881 51,356
FL 2 102 104
ID 6 6
IL 5 48,748 48,753
IN 7,374 7,374
KS 9 90,526 90,535
KY 5 11,769 11,774
LA 6,486 94 2,555 9,135
MI 19 16,525 16,544
MO 2 687 689
MS 6 4,556 4,562
MT 5 9,768 9,773
ND 19 13,024 13,043
NE 1 16,202 16,203
NM 902 37 57,839 58,778
NV 176 176
NY 12,244 12,244
OH 29 10 90,288 90,327
OK 856 96 29,042 29,994
OR 56 56
PA 452 11 103,680 104,143
SD 408 408
TN 15,956 15,956
TX 758 315 397,776 398,849
UT 18 20,608 20,626
VA 9,888 9,888
WI 1 1
WV 20 16,118 16,138
WY 325 48 38,538 38,911
Grand Total 10,472 825 1,182,278 1,193,575
* NC facilities are not included because the state did not respond to multiple requests for the data. This exclusion likely does not significantly affect the total number of wells in the table, as historically NC only had 2 oil and gas wells.
For schools and hospitals analysis, 2017
Ted Auch, PhD

How close are schools and hospitals to drilling activity in West Virginia and Ohio?

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A review of WV and OH drilling activity and its proximity to schools and medical facilities

Schools and hospitals represent places where vulnerable populations may be put at risk if they are located close to oil and gas activity. Piggybacking on some elegant work from PennEnvironment (2013) and Physicians, Scientists, and Engineers (PSE) Healthy Energy (PDF) in Pennsylvania, below is an in-depth look at the proximity of unconventional oil and gas (O&G) activity to schools and hospitals in Ohio and West Virginia.

Ohio Schools and Medical Facilities

In Ohio, presently there are 13 schools or medical facilities within a half-mile of a Utica and/or Class II injection well and an additional 344 within 2 miles (Table 1 and map below). This number increases to 1,221 schools or medical facilities when you consider those within four miles of O&G related activity.

Map of OH Drilling and Disposal Activity Near Schools, Medical Facilities


View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Table 1. Number of OH schools and hospitals within certain distances from Utica wells

Utica Class II Injection
Well Distance (Miles) Schools Medical Facilities Schools Medical Facilities
0.5 3 1 9 0
0.5-1 19 (22) 9 (10) 16 (25) 13 (13)
1-2 79 (101)  41 (51) 88 (113) 79 (92)
2-3 84 (185) 49 (100) 165 (278) 122 (214)
3-4 85 (270) 79 (179) 168 (446) 112 (326)
4-5 92 (362) 63 (242) 196 (642) 166 (492)
5-10 388 (750) 338 (580) 796 (1,438) 584 (1,076)

Ohio’s rate of Utica lateral permitting has jumped from an average of 39 per month all-time to 66 per month in the last year. OH’s drilling activity has also begun to spread to outlying counties[1]. As such, we thought a proactive analysis should include a broader geographic area, which is why we quantified the number of schools and medical facilities within 5 and 10 miles of Utica and Class II activity (Figures 1 and 2). To this end we found that ≥50% of Ohio’s schools, both public and private, are within 10 miles of this industry. Similarly 50% of the state’s medical facilities are within 10 miles of Utica permits or Class II wells.

Footnote 1: Eleven counties in Ohio are currently home to >10 Utica permits, while 23 are home to at least 1 Utica permit.

Ohio’s oil production in 2011
Ohio’s oil production in 2011
Ohio’s oil production in Q3-2014
Ohio’s oil production in Q3-2014

Figures 1, 2a, 2b (above). Click to expand.

Grade Level Comparisons

With respect to grade level, the majority of the schools in question are elementary schools, with 40-50 elementary schools within 2-5 miles of Ohio Utica wells. This number spikes to 216 elementary schools within ten miles of Utica permits along with an additional 153 middle or high Schools (Figure 3). Naturally, public schools constitute most of the aforementioned schools; there are approximately 75 within five miles of Utica permits and 284 within ten miles of Utica activity (Figure 4).

Ohio schools by grade level
Ohio schools by grade level
Ohio schools across school type
Ohio schools across school type

Figures 3 and 4 (above). Click to expand.

Public Schools in Ohio

We also found that ~4% of Ohio’s public school students attend a school within 2 miles of the state’s Utica and/or Class II Injection wells (i.e., 76,955 students) (Table 2). An additional 315,362 students or 16% of the total public school student population, live within five miles of O&G activity.

Table 2. Number of students in OH’s public schools within certain distances from Utica and Class II Injection wells

Utica Class II Injection
Well Distance (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 3 1,360 453 7 3,312 473
<1 21 7,910 377 19 7,984 420
<2 96 35,390 376 90 41,565 462
<3 169 67,713 401 215 104,752 487
<4 241 97,448 404 350 176,067 503
<5 317 137,911 435 505 254,406 504
<10 600 280,330 467 1,126 569,343 506

(Note: Ohio’s population currently stands at 11.59 million people; 2,007,667 total students).

The broadest extent of our study indicates that 42% of Ohio students attend school within ten miles of a Utica or Class II Injection well (Figure 5). As the Ohio Utica region expands from the original 11 county core to include upwards of 23-25 counties, we expect these 5-10 mile zones to be more indicative of the type of student-Utica Shale interaction we can expect to see in the near future.

Softball field and Injection well
Softball field and Injection well
Guernsey County Schools and Utica/Injection wells
Guernsey County Schools and Utica/Injection wells
Ed Lyons Class II SWD WEll and baseball field
Ed Lyons Class II SWD WEll and baseball field

Photos of drilling activity near schools, and Figure 5 (above). Click to expand.

Private Schools in Ohio

At the present time, less than one percent of Ohio’s private school students attend a school within 2 miles of Utica and/or Class II Injection wells (specifically, 208 students). An additional 11,873 students or 11% of the total student population live within five miles. When you broaden the extent, 26% of Ohio’s private primary and secondary school students attend school daily within ten miles of a Utica or Class II Injection well. Additionally, the average size of schools in the immediate vicinity of Utica production and waste activity ranges between 11 and 21 students, while those within 2-10 miles is 112-159 students. Explore Table 3 for more details.

Table 3. Number of students in Ohio’s private schools within certain distances from Utica and Class II Injection.

Utica Class II Injection
Distance from Well (Miles) # Schools # Students Avg # Schools # Students Avg
0.5 . . . 1 . .
<1 . . . 2 25 13
<2 2 22 11 9 186 21
<3 7 874 125 30 4,460 149
<4 12 1,912 159 45 6,303 140
<5 21 2,471 118 61 9,610 158
<10 60 6,727 112 135 20,836 154

West Virginia Schools and Students

Twenty-eight percent (81,979) of West Virginia’s primary and secondary school students travel to a school every day that is within two miles of the state’s Marcellus and/or Class II Injection wells.

Map of WV Marcellus Activity and Schools


View map fullscreen | How FracTracker maps work
Explore the data used to make this map in the “Data Downloads” section at the end of this article.

Compared with Ohio, 5,024 more WV students live near this industry (Table 4). An additional 97,114 students, or 34% of the West Virginia student population, live within 5 miles of O&G related wells. The broadest extent of our study indicates that more than 90% of West Virginia students attend school daily within 10 miles of a Marcellus and/or Class II Injection well.

figure6

Figure 6. West Virginia primary and secondary schools, Marcellus Shale wells, and Class II Injection wells (Note: Schools that have not reported enrollment figures to the WV Department of Education are highlighted in blue). Click image to expand.

It is worth noting that 248 private schools of 959 total schools do not report attendance to the West Virginia Department of Education, which means there are potentially an additional 69-77,000 students in private/parochial or vocational technology institutions unaccounted for in this analysis (Figure 6). Finally, we were not able to perform an analysis of West Virginia’s medical facility inventory relative to Marcellus activity because the West Virginia Department of Health and Human Resources admittedly did not have an analogous, or remotely complete, list of their facilities. The WV DHHR was only able to provide a list of Medicaid providers and the only list we were able to find was not verifiable and was limited to hospitals only.

Table 4. Number of students in WV schools within certain distances from Shale and Class II Injection wells

Marcellus Class II Injection
Distance from Well (Miles) # Sum Avg # Sum Avg
0.5 19 5,674 299 1 . .
<1 52 (71) 16,992 (22,666) 319 5 (6) 1,544 257
<2 169 (240) 52,737 (75,403) 314 16 (22) 5,032 (6,576) 299
<3 133 (373) 36,112 (111,515) 299 18 (40) 6,132 (12,708) 318
<4 88 (461) 25,037 (136,552) 296 21 (61) 5,235 (17,943) 294
<5 56 (517) 15,685 (152,237) 295 26 (87) 8,913 (26,856) 309
<10 118 (635) 37,131 (189,368) 298 228 (315) 69,339 (96,195) 305
Note: West Virginia population currently stands at 1.85 million people; 289,700 total students with 248 private schools of 959 total schools not reporting attendance, which means there are likely an additional 69-77,000 students in Private/Parochial or Vocational Technology institutions unaccounted for in this analysis.

Conclusion

A Trump White House will likely mean an expansion of unconventional oil and gas activity and concomitant changes in fracking waste production, transport, and disposal. As such, it seems likely that more complex and broad issues related to watershed security and/or resilience, as well as related environmental concerns, will be disproportionately forced on Central Appalachian communities throughout Ohio and West Virginia.

Will young and vulnerable populations be monitored, protected, and educated or will a Pruitt-lead EPA pursue more laissez-faire tactics with respect to environmental monitoring? Stay Tuned!

Analysis Methods

The radii we used to conduct this assessment ranged between ≤ 0.5 and 5-10 miles from a Utica or Marcellus lateral. This range is larger than the aforementioned studies. The point of using larger radii was to attempt to determine how many schools and students, as well as medical facilities, may find themselves in a more concentrated shale activity zone due to increased permitting. Another important, related issue is the fact that shale O&G exploration is proving to be more diffuse, with the industry exploring the fringes of the Utica and Marcellus shale plays. An additional difference between our analysis and that of PennEnvironment and PSE Healthy Energy is that we looked at identical radii around each state’s Class II Injection well inventory. We included these wells given the safety concerns regarding:

  1. their role in induced seismicity,
  2. potential water and air quality issues, and
  3. concomitant increases in truck volumes and speeds.

Data Downloads for Maps Above

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Kyle Ferrar, MPH

Oil and Gas Wastes are Radioactive – and Lack Regulatory Oversight

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Highlighting the maps of radioactive oil and gas exploration and production wastes created in collaboration with the Western Organization of Research Councils

By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
Scott Skokos, Western Organization of Research Councils

Oil and gas waste can be radioactive, but it is not considered “hazardous,” at least according to the federal government. In this article, we summarize several of the hazardous risks resulting from the current federal policy that fails to regulate this massive waste stream, and the gaps left by states. Of the six states mapped in this assessment, only the state of Montana has initiated any type of rule-making process to manage the waste.

When it comes to unconventional oil and gas waste streams:

Nobody can say how much of any type of waste is being produced, what it is, and where it’s ending up. – Nadia Steinzor, Earthworks

To address some of these gaps, FracTracker Alliance has been working with the Western Organization of Resources Councils (WORC) to map out exactly where radioactive oil and wastes are being dumped, stored, and injected into the ground for disposal. The work is an extension to WORC’s comprehensive No Time to Waste report.

Why is accurate waste data so hard to come by? The Earthworks report, Wasting Away explains that the U.S. EPA intentionally exempted oil and gas exploration and production wastes from the federal regulations known as the Resource Conservation and Recovery Act (RCRA) despite concluding that such wastes “contain a wide variety of hazardous constituents.” As a result, there is very little waste tracking and reporting of oil and gas waste data nationally.

State Waste Management Maps

Some data is available at the state level, so we at FracTracker have compiled, cleaned, and mapped what little data we could find.

State-specific maps have been created for Montana, North Dakota, Colorado, and Wyoming – see below:

mt-radioactive-featureMontana – View map fullscreen

ND Radioactive Waste mapNorth Dakota – View map fullscreen

co-radioactive-featureColorado – View map fullscreen

WY Radioactive Waste mapWyoming – View map fullscreen

Sources of Radioactivity

When we hear about “radioactive waste” associated with the energy industry, nuclear power stations and fission reactors are usually what come to mind. But, as the EPA explains, fracking has transformed the nature of the oil and gas waste stream. Components of fracking waste differ from conventional oil and gas exploration and production wastes in a number of ways:

  • In general, the waste stream has additional hazardous components, and that transformation includes increased radioactivity.
  • Fracking has allowed for more intrusive drilling, penetrating deep sedimentary formations using millions of gallons of fluid.
  • Drilling deeper produces more drill cuttings.
  • The process of hydraulic fracking introduces millions more gallons of fluid into the ground that then return to the surface. These returns are ultimately contaminated and require disposal.
  • The formations targeted for unconventional development are mostly ancient seabeds still filled with salty “brines” known as “formation waters.”
  • In addition to the hazardous chemicals in the fracking fluid pumped into the wells for fracking, these unconventional formations contain larger amounts of heavy metals, carcinogens and other toxics. This also includes more radioisotopes such as Uranium, Thorium, Radium, Potassium-40, Lead-210, and Polonium-210 than the conventional formations that have supplied the majority of oil and gas prior to the shale boom.

A variety of waste products make up the waste stream of oil and gas development, and each is enhanced with naturally occurring radioactive materials (NORM). This waste stream must be treated and disposed of properly. All the oil and gas equipment – such as production equipment, processing equipment, produced water handing equipment, and waste management equipment – also need to be considered as sources of radioactive exposure.

Figure 1 below explains where the waste from fracking goes after it leaves the well pad.

Radioactive Oil and Gas Pathway Life Cycle

Figure 1. Breakdown of the radioactive oil and gas waste life-cycle

Three facets of the waste stream particularly enhanced with NORMs by fracking include scales, produced waters, and sludges.

A. Scales

When injected into the ground, fracking fluid mixes with formation waters, dissolving metals, radioisotopes and other inorganic compounds. Additionally the fracking liquids are often supplemented with strong acids to reduce “scaling” from precipitate build up (to prevent clogging up the well). Regardless, each oil well generates approximately 100 tons of radioactive scale annually. As each oil and gas reservoir is drained, the amount of scale increases. The EPA reports that lead-210 and polonium-210 are commonly found in scales along with their decay product radon at concentrations estimated to be anywhere from 480 picocuries per gram (pCi/g) to 400,000 pCi/g). Scale can be disposed of as a solid waste, or dissolved using “scale inhibitors.” These radioactive elements then end up in the liquid waste portion of the waste stream, known as produced waters.

B. Produced Waters

In California, strong acids are used to further dissolve formations to stimulate additional oil production. Acidic liquids are able to dissolve more inorganic elements and compounds such as radioisotopes. While uranium and thorium are not soluble in water, their radioactive decay products such as radium dissolve in the brines. The brines return to the surface as “produced water.” As the oil and gas in the formation are removed, much of what is pumped to the surface is formation water.

Consequently, declining oil and gas fields generate more produced water. The ratio of produced water to oil in conventional well was approximately 10 barrels of produced water per barrel of oil. According to the American Petroleum Institute (API), more than 18 billion barrels of waste fluids from oil and gas production are generated annually in the United States. There are several options for managing the liquid waste stream. The waste could be treated using waste treatment facilities, reinjected into other wells to enhance production (a cheaper option), or injected for disposal. Before disposal of the liquid portion, all the solids in the solution must be removed, resulting in a “sludge.”

C. Sludges

The U.S. EPA reports that conventional oil production alone produces 230,000 million tons – or five million ft3 (141 cubic meters) – of TENORM sludge each year. Unconventional processes produce much more sludge waste than conventional processes. The average concentration of radium in sludges is estimated to be 75 pCi/g, while the concentration of lead-210 can be over 27,000 pCi/g. Sludges present a high risk to the environment and a higher risk of exposure for people and other receptors in those environments because sludges are typically very water soluble.

Federal Exemptions

According to the EPA, “because the extraction process concentrates the naturally occurring radionuclides and exposes them to the surface environment and human contact, these wastes are classified as Technologically Enhanced Naturally Occurring Radioactive Material (TENORM).” Despite the conclusions that oil and gas TENORM pose a risk to the environment and humans, the EPA exempts oil and gas exploration and production wastes from the definition of “hazardous” under Resource Conservation and Recovery Act (RCRA) law. In fact, most wastes from all of the U.S. fossil fuel energy industry, including coal-burning and natural gas, are exempt from the disposal standards that hazardous waste normally requires.

The Center for Public Integrity calls this radioactive waste stream “orphan waste,” because no single government agency is fully managing it.

Fortunately, the EPA has acknowledged that federal regulations are currently inadequate, though this is nothing new. A U.S. EPA report from the 1980’s reported as much, and gave explicit recommendations to address the issue. For 30 years nothing happened! Then in August, 2015, a coalition of environmental groups (including the Environmental Integrity Project, Natural Resources Defense Council, Earthworks, Responsible Drilling Alliance, West Virginia Surface Owners’ Rights Organization, and the Center for Health, Environment and Justice) filed a lawsuit against the EPA, and has since reached a settlement.

Just last month (January 10, 2017) the U.S. EPA agreed to review federal regulations of oil and gas waste – a process they were meant to do every 3 years for the last 30 years. The EPA has until March 15, 2019, to determine whether or not regulatory changes are warranted for “wastes associated with the exploration, development, or production of crude oil, natural gas, or geothermal energy.” With the recent freeze on all U.S. EPA grants, however, it is not clear whether these regulations will receive the review they need.

State Regulations

Regulation of this waste stream is left up to the states, but most states do not require operators to manage the radioactivity in oil and gas wastes, either. Because of the federal RCRA exemptions most state policies ignore the radioactive issue altogether. Operators are free to dispose of the waste at any landfill facility, unless the landfill tells them otherwise. For detailed analyses of state policies, see pages 10-45 of the No Time to Waste report. FracTracker has also covered these issues in Pennsylvania and Ohio.

Another issue that screams for federal consideration of this waste stream is that states do not have the authority to determine whether or not the wastes can cross their borders. States also do not have the jurisdiction to decide whether or not facilities in their state can accept waste from across state lines. That determination is reserved for federal jurisdiction, and there are not any federal laws regulating such wastes. In fact, these wastes are strategically exempt from federal regulation for just these reasons.

Why can’t the waste be treated?

This type of industrial waste actually cannot be treated, at least not entirely. Unlike organic pollutants that can be broken down, inorganic constituents of the waste cannot be simply disintegrated out of existence. Inorganic components include heavy metals like arsenic and bromides, as well as radioactive isotopes of radium, lead, and uranium. Such elements will continue to emit radiation for hundreds-to-thousands of years. The best option available is to find a location to “isolate” and dispose of these wastes – a sacrifice zone.

Current management practices do their best to separate the liquid portions from the solid portions, but that’s about it. Each portion can then be disposed independently of each other. Liquids are injected into the ground, which is the cheapest option where it is available. If enough of the dissolved components (heavy metals, salts, and radioisotopes) can be removed, wastewaters are discharged into surface waters. The compounds and elements that are removed from the liquid waste stream are hyper-concentrated in the solid portion of the waste, described as “sludge” in the graphic above. This hazardous material can be disposed of in municipal or solid waste landfills if the state regulators do not require the radioactivity or toxicity of this material to be a consideration for disposal. There are not federal requirements, so unless there is a specific state policy regarding the disposal, it can end up almost anywhere with little oversight. These chemicals do not magically disappear. They never disappear.

Risks

There are multiple pathways for contamination from facilities that are not qualified to manage radioactive and hazardous wastes. At least seven different environmental pathways provide potential risks for human exposure. They include:

  1. Radon inhalation,
  2. External gamma exposure,
  3. Groundwater ingestion,
  4. Surface water ingestion,
  5. Dust inhalation,
  6. Food ingestion, and
  7. Skin beta exposure from particles containing the radioisotopes.

According to the EPA, the low-level radioactive materials in drilling waste present a definitive risk to those exposed. High risk examples include dust suppression and leaching. If dust is not continuously suppressed, radioactive materials in dust pose a risk to people at these facilities or those receptors or secondary pathways located downwind of the facilities. Radioactive leachate entering surface waters and groundwaters is also a significant threat. A major consideration is that radioactive waste can last in these landfills far longer than the engineered lifespans of landfills, particularly those that are not designed to retain hazardous wastes.

Cases of Contamination

North Dakota

In North Dakota, the epicenter of the Bakken Oil Fields, regulators were not ready for the massive waste streams that came from the fast growing oil fields. This  allowed thousands of wastewater disposal wells be drilled to dispose of salty wastewater without much oversight, and no places in state for companies to dispose of radioactive solid waste. Many of the wastewater disposal wells were drilled haphazardly, and as a result many contaminated surrounding farmland with wastewater. With regard to radioactive solid waste, the state until recently had a de facto ban on solid radioactive waste disposal due to their radioactivity limit being 5 picocuries per gram. The result of this de facto ban made it so companies either had to make one of two decisions: 1. Haul their radioactive solid waste above the limit out of state to facilities in Idaho or Colorado; or 2. Risk getting caught illegally dumping waste in municipal landfills or just plain illegal dumping in roadsides, buildings, or farmland.

In 2014, a massive illegal dumping site was discovered in Noonan, ND when North Dakota regulators found a gas station full of radioactive waste and filter socks (the socks used to filter out solid waste from wastewater, which contain high levels of radioactivity). Following the Noonan, ND incident North Dakota regulators and politicians began discussions regarding the need for new regulations to address radioactive solid waste.

In 2015, North Dakota moved to create rules for the disposal of solid radioactive waste. Its new regulations increase the radioactivity limit from 5 picocuries per gram to 50 picocuries per gram, and sets up new requirements for the permitting of waste facilities accepting radioactive waste and the disposal of radioactive waste in the waste facilities. Dakota Resource Council, a member group of WORC, challenged the rules in the courts, arguing the rules are not protective enough and that the agency responsible for the rules pushed through the rules without following the proper procedures. Currently the rules are not in effect until the litigation is settled.

Pennsylvania

In Pennsylvania, the hotbed of activity for Marcellus Shale gas extraction, the regulatory body was ill equipped and uninformed for dealing with the new massive waste stream when it first arrived on scene. Through 2013, the majority of wastewater was disposed of in commercial and municipal wastewater treatment facilities that discharge to surface waters. Numerous facilities engaged in this practice without amending their federal discharge permits to include this new waste stream.

Waste treatment facilities in Pennsylvania tried to make the waste streams less innocuous by diluting the concentrations of these hazardous pollutants. They did this by mixing the fracking wastes with other waste streams, including industrial discharges and municipal waste. Other specialized facilities also tried to remove these dissolved inorganic elements and filter them from the discharge stream.

As a result of site assessments by yours-truly and additional academic research, these facilities realized that such hazardous compounds do not simply dilute into receiving waters such as the Allegheny, Monongahela, and Ohio rivers. Instead, they partition (settle) into sediments where they are hyper-concentrated. As a result of the lawsuits that followed the research, entire river bottoms in Pennsylvania had to be entirely dug up, removed, and disposed of in hazardous waste landfills.

Action Plans Needed

Massive amounts of solid and liquid wastes are still generated during drilling exploration and production from the Marcellus Shale. There is so much waste, operators don’t know what to do with it. In Pennsylvania, there is not much they can do with it, but it is not just Pennsylvania. Throughout the Ohio River Valley, operators struggle to dispose of this incredibly large waste stream.

Ohio, West Virginia, and Pennsylvania have all learned that this waste should not be allowed to be discharged to surface waters even after treatment. So it goes to other states – those without production or the regulatory framework to manage the wastes. Like every phase of production in the oil and gas industry, operators (drillers) shop around for the lowest disposal costs. In Estill County, Kentucky, the State Energy and Environment Department just recently cited the disposal company Advance Disposal Services Blue Ridge Landfill for illegally dumping hydraulic fracturing waste. The waste had traveled from West Virginia Marcellus wells, and ended up at an ignorant or willfully negligent waste facility.

In summary, there is inadequate federal oversight of potentially hazardous waste coming from the oil and gas industry, and there are serious regulatory gaps within and between states. Data management practices, too, are lacking. How then, is the public health community supposed to assess the risk that the waste stream poses to people? Obviously, a more thorough action plan is needed to address this issue.

Feature image: Drill cuttings being prepared to be hauled away from the well pad. Photo by Bill Hughes, OVEC

Koontz Class II Injection Well, Trumbull County, Ohio, (41.22806065, -80.87669281) with 260,278 barrels (10,020,704 gallons) of fracking waste having been processed between Q3-2010 and Q3-2012 (Note: Q1-2016 volumes have yet to be reported!).
Ted Auch, PhD

Ohio Shale Activity, Waste Disposal, and Public Water Supplies

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Ohio is unique relative to its Appalachian neighbors in the Marcellus and Utica Shale Basins in that The Buckeye State chose to “diversify” when it came to planning for the hydraulic fracturing revolution. One of the first things financial advisers tell their clients is to “diversify, diversify, diversify.” However, this strategy is usually meant to buffer investors when certain sectors of the economy underperform. Columbus legislators took this strategy to mean that we should drill and hydraulically fracture our geology to extract oil and gas (O&G), as well as taking in vast quantities of liquid and solid O&G waste from Pennsylvania and West Virginia.

Accepting significant quantities of out-of-state waste raises several critical questions, however. How will these materials will be contained? Will such volumes require more and larger waste landfills? And will the injection of liquid brine waste into our geology (photo below) make Ohio the “Oklahoma of Appalachia” with respect to induced seismicity?


Above: Example Class II salt water disposal (SWD) wells in Ohio

Risks to Public Water Supplies

There are also mounting concerns about public water supply (PWS) security, quality, and resilience. These concerns stem from the growing uncertainty surrounding the containment of hydraulically fractured and Class II injection wells.

To begin to assess the risks involved in locating these wells near PWS’s, we compiled and incorporated as many of the state’s PWS’s into our primary Ohio maps. In this post, we explore PWS proximity to Utica drilling activity and Class II salt water disposal (SWD) wells in Ohio.

Waste Disposal & Drilling Near PWS’s

Public water chartJust how close are public water supplies to Class II waste disposal wells and permitted Utica wells? As of January 15, 2017, there are 13 PWS’s within a half-mile of Ohio’s Class II SWD wells, and 18 within a half-mile of permitted Utica wells. These facilities serve approximately 2,000 Ohioans each, with an average of 112-153 people per PWS (Tables 1 and 5). Within one mile from these wells there are 64 to 66 PWSs serving 18 to 61 thousand Ohioans. That’s an average of 285-925 residents.

Above: Photos of SWD wells from the sky

While PWSs on the 5-mile perimeter of our analysis don’t immediately conjure up water quality/quantity concerns, they may in the future; the rate of Utica and Class II permitting is likely to accelerate under a new White House administration more friendly to industry and averse to enforcing or enhancing regulatory hurdles.

A total of 960 and 699 PWSs are currently within five miles of Ohio Class II and Utica wells. These facilities service roughly 1.5 million and one-half million Ohioans each day, which is ~13% and 4% of the state, respectively. The average PWS within range of Class II wells is 37% to 330 times the average PWS within range of Utica wells.

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Roland Marily Kemble Class II Salt Water Disposal Well, Muskingum County, Ohio, Muskingum River Watershed, 39.975, -81.845, 1,984,787 Barrels of Waste Disposed Between 2010 and Q3-2016

Fifty-eight (58%) to 69% of the PWSs within range of Class II wells are what the Ohio EPA calls Transient Non-Community (TNC) (Table 2). TNC’s are defined by the OH EPA and OH Department of Agriculture as serving[1]:

…at least 25 different persons over 60 days per year. Examples include campgrounds, restaurants and gas stations. In addition, drinking water systems associated with agricultural migrant labor camps, as defined by the Ohio Department of Agriculture, are regulated even though they may not meet the minimum number of people or service connections.

Meanwhile 60-89% of PWS’s in the shadow of Ohio’s permitted Utica wells are of the TNC variety. Even larger percentages of these PWS’s are either Groundwater or Purchased Groundwater types. Most of the PWS’s within the range gradient we looked at are privately owned, with only handful owned by federal or state agencies (Table 6).

Above: Example Class II salt water disposal (SWD) wells in Ohio

Of the 24 hydrologic unit codes (HUCs)/watersheds that contain Class II SWD wells, the lion’s share of PWS’s within the shadow of injection wells are the Tuscarawas, Mahoning, and Walhonding (Table 3). Even the Cuyahoga River, which feeds directly in the Great Lakes, is home to up to 138 PWS’s within 5 miles of Class II SWD wells. Conversely, only 13 HUCs currently contain Ohio’s Utica wells. Like Class II-affected HUCs, we see that the Mahoning, Tuscarawas, and Cuyahoga PSW’s contain most of the PWSs of interest (Table 7).

Conclusion

Watershed security/resilience concerns are growing in Eastern Ohio. Residential and agricultural water demands are increasingly coming into conflict with the drilling industry’s growing freshwater demand. Additionally, as oil and gas drilling uses more water, we will see more brine produced (Figures 1 and 2).

This, in turn, will create more demand – on top of an already exponential trend (Figure 3) – for Ohio’s existing Class II wells from across Northern Appalachia, stretching from Southeast Ohio and West Virginia to North Central Pennsylvania.

An understanding of the links between watershed security, O&G freshwater demand, brine production, and frack waste disposal is even more critical in areas like Southeast Ohio’s Muskingum River Watershed (Figure 4).

A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz, E. 2015

Figure 4. A Dynamic Model of Water Demand Between 2000 and 2020 within the Muskingum River Watershed, Southeast Ohio, Kurtz and Auch 2015

This is a region of the state where we have seen new water withdrawal agreements like the one below between the Muskingum River Watershed Conservancy District (MWCD) and Antero described in last week’s Caldwell Journal-Leader, Noble County, Ohio:

The [MWCD], which oversees 10 lakes in east central Ohio, approved a second short-term water sale from Seneca Lake last week. The deal, with Antero Resources, Inc., could net the district up to $9,000 a day over about a three month period, and allows Antero to draw up to 1.5 million gallons of water a day during the months of August, September and October for a total of 135 million gallons; less than one percent of the lake’s estimated volume of 14.2 billion gallons. Antero plans to use the water in its fracking operations in the area and will pay $6 per 1000 gallons drawn.

Consol Energy's Cowgill Road Impoundment, Sarahsville, Wills Creek, Noble County, Ohio, 39.8212, -81.4061

Consol Energy’s Cowgill Road Impoundment, Sarahsville, Wills Creek, Muskingum River Watershed, Noble County, Ohio, 39.8212, -81.4061

This agreement will mean an increase in new Class II SWD permits and/or discussion about converting Ohio’s thousands of other Class II wells into SWD wells. What does this change means for communities that have already seen the industry extract the equivalent of nearly 14% – and even 25-80% in several counties – of residential water from their watersheds, only to inject it 6,000+ feet into the state’s geology is unknown? (Figure 5)

It is critical that we establish and frequently revisit the spatial relationship between oil and gas infrastructure the water supplies of Appalachian Ohio. The state of national politics, federal agency oversight and administrations, growing concerns around climate change, and the fact that Southeast Ohio is experiencing more intense and infrequent precipitation events are testaments to that fact. We will be tracking these changes to Ohio’s landscape as they develop. Stay tuned.

Kleese Disposal Class II Salt Water Disposal Well, Trumbull County, Shenango/Mahoning River, 41.244, -80.641, 3,548,104 Barrels of Waste Disposed Between 2010 and Q3-2016

Kleese Disposal Class II Salt Water Disposal well from the sky, Trumbull County, Shenango/Mahoning River, 41.244, -80.641. Data suggest 3,548,104 barrels of waste have been disposed of there between 2010 and Q3-2016.

Supplemental Tables

Public Water and Class II Wells

Table 1. Number of Ohio public water supplies and population served at several intervals from Class II Injection wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 13 1,992 153 (±120) 446
<1 66 60,539 917 (±4,702) 37,456
<2 198 278,402 1,406 (±4,374) 37,456
<3 426 681,969 1,601(±8,187) 148,000
<4 681 1,086,463 1,596 (±8,284) 148,000
<5 960 1,450,865 1,511 (±7,529) 148,000

 

Table 2. Ohio public water supplies by system type, source, and ownership at several intervals from Class II Injection wells

 

Well Distance (Miles)

 System Type† Source†† Ownership
 

NTNC

  

TNC

  

C

  

G

  

GP

  

S

  

SP

  

Private

  

Local

  

Fed

  

State
0.5 3 9 1 13 13
<1 11 47 8 65 1 61 5
<2 30 118 50 177 16 5 164 34
<3 76 245 105 385 32 8 351 75
<4 122 392 167 628 40 12 574 106 1
<5 162 564 234 878 30 32 19 823 135 1 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

Table 3. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from Class II Injection wells

 

HUC Name

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula-Chagrin, 799 1 5 18 18 22
Black-Rocky, 859 1 1 2 2 9
Cuyahoga, 832 1 8 20 92 92 138
Grand, 811 12 30 71 71 81
Hocking, 1081 4 18 18 22
Licking, 1010 1 2 17 17 29
Little Muskingum-Middle Island, 1062 1 2 2 6
Lower Maumee, 856 2 2 4
Lower Scioto, 1091 6 6 9
Mahoning, 831 9 17 48 129 129 161
Mohican, 919 1 3 3 4
Muskingum, 1006 1 3 15 15 33
Raccoon-Symmes, 1128 1
Sandusky, 862 3 19 19 27
Shenango, 815 1 2 6 10 10 11
St. Mary’s, 934 3 5 5 7
Tiffin, 837 4 4 7
Tuscarawas, 889 1 9 76 147 147 213
Upper Ohio, 901 3 15 15 23
Upper Ohio-Shade, 1120 4 8 8 9
Upper Ohio-Wheeling, 984 1 1 4 4 5
Upper Scioto, 959 5 13 13 23
Walhonding, 906 1 11 26 69 69 101
Wills, 1009 2 3 12 12 14

 

Table 4. Ohio public water supplies by county at several intervals from Class II Injection wells

 

County

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 4 9 16 19 22
Athens 1 2 2 3
Auglaize 3 5 5 7
Belmont 1 4 5 6
Carroll 2 9 20
Columbiana 1 2 6 13 20 32
Coshocton 7 8 10 13
Crawford 1
Cuyahoga 1
Delaware 1
Fairfield 4
Franklin 1 3 7
Fulton 2 4 8
Gallia 1
Geauga 8 19 33 60 71
Guernsey 2 4 10 11 11
Harrison 1 1
Henry 2 3 3
Henry 2 3
Hocking 3 10 11 13
Holmes 1 11 34 25 38 47
Jefferson 1 3 3 5
Knox 2 6 8 9
Lake 1 4 7 17 18
Licking 1 2 10 14 26
Lorain 1 4
Mahoning 3 4 13 25 37 48
Medina 1 1 1 2 5
Meigs 4 5 6 7
Morgan 1 1 1 6 17
Morrow 3 8 11 11
Muskingum 3 8 15
Noble 1 2 2 3
Perry 5 6 8
Pickaway 2 3 7 10
Portage 3 12 41 62 90 113
Seneca 1 12 17 21
Stark 1 4 20 52 121 161
Summit 2 12 26 51
Trumbull 3 7 24 32 45 61
Tuscarawas 6 10 22 24 26
Washington 1 2 4 9
Wayne 1 1 9 18 24 54
Wyandot 2 2 2 3

Public Water and Hydraulically Fractured Wells

Table 5. The number of Ohio public water supplies and population served at several intervals from hydraulically fractured Utica Wells

Well Distance (Miles) # Total Population Ave Served Per Well Max People Per Well
0.5 18 2,010 112 (±72) 31
<1 64 17,879 279 (±456) 2,598
<2 235 116,682 497 (±1,237) 8,728
<3 433 257,292 594 (±2,086) 29,787
<4 572 380,939 666 (±2,404) 29,787
<5 699 496,740 711 (±2,862) 47,348

 

Table 6. Ohio public water supplies by system type, source, and ownership at several intervals from hydraulically fractured Utica Wells

 

Well Distance (Miles)

 System Type† Source†† Ownership
 

NTNC

  

TNC

  

C

  

G

  

GP

  

S

  

SP

  

Private

  

Local

  

Fed

  

State
0.5 1 16 1 17 1 18
<1 9 45 10 59 3 1 1 58 6
<2 50 137 48 216 6 3 10 206 29
<3 83 265 85 400 14 5 14 381 51 1
<4 109 352 111 534 16 7 15 504 67 1
<5 141 421 137 652 19 9 18 621 77 1

† NTNC = Non-Transient Non-Community; TNC = Transient Non-Community; C = Community

†† G = Groundwater; GP = Purchased Groundwater; S = Surface Water; SP = Purchased Surface Water

 

 

Table 7. Ohio public water supplies by hydrologic unit code (HUC) at several intervals from hydraulically fractured Utica wells

 

HUC Name

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Black-Rocky, 859 1 4 4 4
Cuyahoga, 832 2 12 31 54 82
Grand, 811 1 15 18 23
Licking, 1010 2 2 3 3
Little Muskingum-Middle Island, 1062 2 5 10 11 11
Mahoning, 831 2 5 48 105 142 175
Muskingum, 1006 3 7 9 11
Shenango, 815 2 5 10 13 14
Tuscarawas, 889 8 28 87 140 178 220
Upper Ohio, 901 7 20 45 66 72 73
Upper Ohio-Wheeling, 984 1 13 23 27 28
Walhonding, 906 10 15 34 47
Wills, 1009 2 3 5 7 8

 

 

Table 8. Ohio public water supplies by county at several intervals from hydraulically fractured Utica wells

 

County

 Well Distance (Miles)
0.5 <1 <2 <3 <4 <5
Ashtabula 1 1
Belmont 1 2 7 14 15 16
Carroll 6 20 36 43 43 43
Columbiana 4 15 45 72 80 81
Coshocton 7 10 10
Geauga 14 20 25
Guernsey 1 1 2 4 5
Harrison 2 6 16 16 16 16
Holmes 5 13 31 43
Jefferson 2 3 11 22 25 25
Knox 1 1 2 2
Licking 1 1 1 1
Mahoning 2 10 32 44 55
Medina 1 4 5 7
Monroe 2 4 6 6 6
Muskingum 1 1 1 2 3
Noble 2 2 2 2
Portage 2 8 25 49 84
Stark 2 5 40 85 110 122
Summit 6 10
Trumbull 3 23 36 53 65
Tuscarawas 1 2 15 22 28 43
Washington 3 10 12 13
Wayne 5 5 7 21

Footnote

  1. Community (C) = serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents. Examples include cities, mobile home parks and nursing homes; Non-Transient, Non-Community (NTNC) = serve at least 25 of the same persons over six months per year. Examples include schools, hospitals and factories.

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance

Dunes, Great Lakes Barrens at Risk
Guest Author

World Class Dunes and Great Lakes Barrens at Risk at Ludington

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By Dave Dister, Consulting Ecologist, Ludington, MI

One of the prime reasons I moved to the Ludington, Michigan area in 2008 was the aesthetic and biological diversity evident at Ludington State Park (LSP). As a field biologist nearing the end of his formal career, I was eager to conduct a study of the vascular plants within the 5,300-acre park. That study consumed six years of exploring all habitats and ecosystems, and documenting (by vouchers) the flora I encountered. Although the unfortunate presence of the Sargent Sand Company operation was obvious as it cut through the south end of the park, it was not until the fracking boom a few years ago that I took special notice as a residential neighbor.

US Frac Sands and Silica Geology Map


View map fullscreen | How FracTracker maps work

Above is a dynamic map of silica sands and frac sand mines, drying facilities, and other related facilities. Zoom and click on the map to explore various aspects of frac sand mining infrastructure. Click here to view the map full screen along with its legend.

Expanding Sand Mining

That “sleepy” sand mining operation suddenly turned into a 24-hour, seven-days-a-week operation, with associated noise that irritated a very light-sleeping biologist. Hamlin Township officials were only partially effective in addressing residential impacts “after hours,” and had no interest in developing reasonable ordinances upon a commercial operation. Although increased noise and truck traffic were a tangible nuisance, only when a renewal of the company’s sand mining permit was announced did it become clear that biological resources within the 372-acre private in-holding were afforded virtually no protection at all. And the more research I did into the regulatory permitting process, the more incredulous the situation appeared.


Above – Photos of Sargent Sands frac sand mining operations taken by Ted Auch, FracTracker Alliance

1979 Environmental Impact Report

My expertise as a wetlands biologist and botanist were well suited to scrutinizing the 1979 Environmental Impact Report (EIR), which was a hastily-compiled poorly-researched 24-page document.

From my perspective, there was a poor level of protection afforded to the Federal and State Threatened Pitcher’s Thistle (Cirsium pitcheri). As far as is known, Sargent Sand has no records of relocating this plant in proposed or active mining cells in its 100-year history of mining, although the Michigan Department of Natural Resources (MDNR) has known about plants on the property for more than 20 years. The MDNR and US Fish and Wildlife Service (USFWS) have been complicit in not adequately protecting this species, which has had minimal research into the success (or not) of transplanting individual plants. Young plants appear to transplant well, but long-term studies are not available. Older plants are much less likely to survive transplanting, as they depend on numerous minute root hairs to absorb moisture in a xeric habitat, and removal from a dune would strip-off most such root hairs. It requires about seven years for these plants to mature, so reproductive rates are slow.

Yep, it’s a fact of life – plants simply are not nearly as charismatic as animals, and consequently are treated as “second-class organisms” in the world of environmental protection. Sadly, the Michigan Department of Environmental Quality (MDEQ) just renewed the sand mining permit that allows Sargent Sand to “self-monitor” for this threatened species, and to “move plants” encountered in areas proposed for development. Does anyone really think a mining company will give two hoots about a thistle plant?!

Great Lakes Barrens Ecosystem

The rarity and value of Great Lakes Barrens (GLB) was not addressed when the 1979 EIR was written, though such ecosystems are clearly visible on aerial photographs of Sargent Sand Company property and surrounding LSP. These natural communities are known to be imperiled ecosystems at both the state and global levels. The Michigan Natural Features Inventory classifies “Great Lakes Barrens” – that include jack pine stands with associated xeric-loving shrubs and forbs – as S2 natural communities:

Imperiled in the state because of rarity due to very restricted range, very few occurrences, steep declines, or other factors making it very vulnerable to extirpation from the state. – Michigan Natural Features Inventory

Globally, Great Lakes Barrens have a similar designation. Consequently, mitigation measures must be strengthened and avoidance of impacts considered. Any Restoration Plan of such habitats must include high quality GLB plants such as buffaloberry (Shepherdia canadensis), bearberry (Arctostaphylos uva-ursi), ground juniper (Juniperus communis), sand cherry (Prunus pumila), sand-dune willow (Salix cordata), blueleaf willow (Salix myricoides), beach-heath (Hudsonia tomentosa), harebell (Campanula rotundifolia), white camas (Anticlea elegans), and wild wormwood (Artemisia campestris), among others.

Again, unfortunately the MDNR has not enforced strong protections against the destruction of Great Lakes Barrens. The “reclamation” of destroyed dunes and jack pine barrens for a mere “one-year period at 80 percent vegetative cover” comes nowhere close to a viable mitigation plan, as trees and shrubs impacted in such areas take decades to recover.

Furthermore, other state-listed plants, such as ram’s head lady-slipper orchid (Cypripedium arietinum) are known to be adjacent to Sargent Sand property but are not legally protected as they are only “Special Concern” species. Lastly, the Lake Huron locust (Trimerotropsis huroniana) is a state Threatened insect known to occur within Ludington State Park, and suitable “sparsely vegetated dune” habitat is common within Sargent Sand’s property. If you thought rare plants get little respect, try to protect a threatened grasshopper!

Great Lakes Barrens often include seasonal wetlands that are protected under Section 404 of the Clean Water Act of 1972, but which often lack surface waters much of the year. Not surprisingly, the 1979 EIR does not mention “wetlands” at all. At best, there is a comment that “There are three or four very small swamp areas on the property…”  However, a review of recent aerial photography indicates many Interdunal Wetlands remain within the northern half of Sargent Sand property. The largest of these appears to be at least 0.5 acre in size, and it is likely that several acres of such wetlands exist on the property.

Consequently, a formal Wetland Delineation is needed to determine the exact location and amount of Jurisdictional Wetlands on Sargent Sand property. Any impact to such wetlands requires mitigation measures that include avoidance, minimization, and/or wetland creation elsewhere within the watershed. Additionally, Interdunal Wetlands are ranked S2 Natural Communities by the State of Michigan, and have a rank of G2 globally. Both of these designations indicate these areas are “Imperiled,” so mitigation ratios should be high (e.g., 10:1 or 20:1).

Current Political Climate in Ludington

The current political leadership in Michigan, as well as the nation, has presented a formidable challenge for environmentalists and scientists. Additionally, the system certainly appears rigged when the agency – the MDEQ – that issues permits and permit renewals is also a lobbyist for the oil, gas, and minerals industry. Nevertheless, the battle to protect this natural heritage is a noble and vital one that will persist. As with every other sensitive and rare environmental resource, if no one scrutinizes the lax protection of our natural heritage, before you know it, it will be gone.

Northern Access Project - pipeline map
Karen Edelstein

Northern Access Project: Exporting PA’s Marcellus Gas Northward

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In March 2015, the National Fuel Gas Supply Corporation and Empire Pipeline Company filed a joint application with the Federal Energy Resource Commission (FERC) to construct a new natural gas pipeline and related infrastructure, known collectively as the Northern Access Project (NAPL). The pricetag on the project is $455 million, and is funded through international, as well as local, financial institutions. The Public Accountability Initiative recently produced a report detailing the funding for this pipeline project, entitled “The Power Behind the Pipeline“.

The proposed Northern Access Project consists of a 97-mile-long, 24” pipe that would carry Marcellus Shale gas from Sergeant Township (McKean County), PA, to the Porterville Compressor Station in the Town of Elma (Erie County), NY. Nearly 69% of the proposed main pipeline will be co-located in existing pipeline and power line rights-of-way, according to FERC. The agency says this will streamline the project and reduce the need to rely on eminent domain to most efficiently route the project.

A $42 million, 15,400 horsepower Hinsdale Compressor Station along the proposed pipeline route was completed in 2015. In addition to the pipeline itself, the proposed project includes:

  • Additional 5,350 HP compression at the existing Porterville Compressor Station, a ten-fold increase of the capacity of that station
  • A new 22,214 HP compressor station in Pendleton (Niagara County), NY
  • Two miles of pipeline in Pendleton (Niagara County), NY
  • A new natural gas dehydration facility in Wheatfield (Niagara County), NY
  • An interconnection with the Tennessee Gas Pipeline in Wales (Erie County), NY, as well as tie-ins in McKean, Allegany, and Cattaraugus counties
  • A metering, regulation and delivery station in Erie County
  • Mainline block valves in McKean, Allegany, Cattaraugus and Erie counties; and
  • Access roads and contractor/staging yards in McKean, Allegany, Cattaraugus and Erie counties

Map of Proposed Northern Access Project


View map fullscreen | How FracTracker maps work

The above map shows the proposed pipeline (green) and related infrastructure (bright pink). The pale yellow and pink lines on the map are the existing pipelines that the Northern Access Project would tie into. Click here to explore the map fullscreen.

Project Purpose

National Fuel maintains that the goal of the proposed project would be to supply multiple markets in Western New York State and the Midwest. The project would also supply gas for export to Canada via the Empire Pipeline system, and New York and New England through the Tennessee Gas Pipeline 200 Line. The company anticipates that the project would be completed by late 2017 or early 2018. Proponents are hoping that NAPL will keep fuel prices low, raise tax revenues, and create jobs.

Push-back against this project has been widespread from citizens and environmental groups, including Sierra Club and RiverKeeper. This is despite an environmental assessment ruling in July 2016 that FERC saw no negative environmental impacts of the project. FERC granted a stamp of approval for the project on February 4, 2017.

Concerns about the Proposed Pipeline

The Bufffalo-Niagara Riverkeeper, asserts that the project presents multiple threats to environmental health of the Upper Lake Erie and Niagara River Watersheds. In their letter to FERC, they disagreed with the Commission’s negative declaration that the project would result in “no significant impact to the environment.” The pipeline construction will require crossings of 77 intermittent and 60 perennial streams, 19 of which are classified by the New York State Department of Environmental Conservation (NYS DEC) as protected trout streams. Twenty-eight of the intermittent streams impacted also flow into these protected streams. Resulting water quality deterioration associated with bank destabilization, increased turbidity, erosion, thermal destabilization of streams, and habitat loss is likely to impact sensitive native brook trout and salamanders. Riverkeeper found that National Fuel’s plan on how to minimize impacts to hundreds of wetlands surround the project area was insufficient. FERC’s Environmental Assessment of the project indicated that approximately 1,800 acres of vegetation would affected by the project.

Several groups have also taken issue with the proposed project’s plan to use the “dry crossing” method of traversing waterways. Only three crossings will be accomplished using horizontal directional drilling under the stream bed — a method that would largely protect the pipes from dynamic movement of the stream during floods. The rest will be “trenched” less than 5 feet below the stream bed. Opponents of the project point out that NYSDEC, federal guidelines, and even industry itself discourage pipe trenching, because during times of high stream flow, stream scour may expose the pipes to rocks, trees, and other objects. This may lead to the pipes leaking, or even rupturing, impacting both the natural environment, and, potentially, the drinking water supply.

A December 2016 editorial to The Buffalo News addressed the impacts that the proposed Northern Access Project could have to the Cattaraugus Creek Basin Aquifer, the sole source of drinking water for 20,000 residents in surrounding Cattaraugus, Erie, and Wyoming counties in New York. In particular, because the aquifer is shallow, and even at the surface in some locations, it is particularly vulnerable to contamination. The editorial took issue with the absence of measures in the Environmental Assessment that could have explored how to protect the aquifer.

Other concerns include light and noise pollution, in addition to well-documented impacts on climate change, created by fugitive methane leakage from pipelines and compressors.

NYSDEC has held three public hearings about the project already: February 7th at Saint Bonaventure University (Allegany, NY), February 8th at Iroquois High School (Elma, NY), February 9th at Niagara County Community College (Sanborn, NY). The hearing at Saint Bonaventure was attended by nearly 250 people.

While FERC approved the project on February 4, 2017, the project still requires approvals from NYSDEC – including a Section 401 Water Quality Certification. These decisions have recently been pushed back from March 1 to April 7.

Proponents for the project – particularly the pipefitting industry – have emphasized that it would create up to 1,700 jobs during the construction period, and suggested that because of the experience level of the construction workforce, there would be no negative impacts on the streams. Other speakers emphasized National Fuel’s commitment to safety and environmental compliance.

Seneca Nation President Todd Gates expressed his concerns about the gas pipeline’s impacts on Cattaraugus Creek, which flows through Seneca Nation land (Cattaraugus Indian Reservation), and is downstream from several tributaries traversed by the proposed pipeline. In addition, closer to the southern border of New York State, the proposed pipeline cuts across tributaries to the Allegheny River, which flows through the Allegany Indian Reservation. One of New York State’s primary aquifers lies beneath the reservation. The closest that the proposed pipeline itself would pass about 12 miles from Seneca Nation Territory, so National Fuel was not required contact the residents there.

Concerns about Wheatfield dehydration facility & Pendleton compressor station

According to The Buffalo News, National Fuel has purchased 20 acres of land from the Tonawanda Sportsmen’s Club. The company is building two compressors on this property, totaling 22,000 HP, to move gas through two miles of pipeline that are also part of the proposed project, but 23 miles north of the primary stretch of newly constructed pipeline. Less than six miles east of the Pendleton compressor stations, a dehydration facility is also proposed. The purpose of this facility is to remove water vapor from the natural gas, in accordance with Canadian low-moisture standards. According to some reports from a National Fuel representative, the dehydration facility would run only a few days a year, but this claim, has not been officially confirmed.

Residents of both Pendleton and Wheatfield have rallied to express their concerns about both components of the project, citing potential impacts on public health, safety, and the environment relating to air and water quality.

Northern Access Project Next Steps

The deadline for public comment submission is 5 pm on February 24, 2017 — less than two weeks away. To file a comment, you can either email NYS DEC directly To Michael Higgins at NFGNA2016Project@dec.ny.gov, or send comments by mail to NYS DEC, Attn. Michael Higgins, Project Manager, 625 Broadway, 4th Floor, Albany, NY 12233.

 

Note: this article originally stated that the Porterville Compressor Station would double its capacity as a result of the NAPL project. In fact, the capacity increase would be ten-fold, from 600 hp to about 6000 hp. We regret this error.

by Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

Ted Auch, PhD

Power Plants & Other Facilities Now on Ohio Oil & Gas Map

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Over the last few months we’ve been busy working on some updates to our Ohio Oil & Gas Map. Check out what we’ve added recently and explore the map below!

New: Power Plants & ATEX Pipeline

We now have the locations of eight of the credible natural gas power plants proposed in Ohio, along with the jobs they cite during construction and operations. We also now have a complete inventory of 118 existing power plants, including 25 natural gas facilities. Together, these plants would produce 7,660 megawatts, around 957 per facility.

Six of these plants are either in the heart of Ohio’s Utica Shale or within several miles of the 1,200+ mile Appalachia-to-Texas (ATEX) pipeline. ATEX was installed to transport 190,000 barrels per day (BPD) of natural gas liquids (NGLs) from the Marcellus and Utica region to the Texas and Louisiana Gulf Goast refinery corridor. The 360 mile segment of this pipeline that runs from Pennsylvania to south central Jackson County, Indiana is also now shown on the Ohio Oil & Gas Map.

Late Permitting Increases

Cumulative and Monthly Ohio Utica Hydraulic Fracturing Well Permits

Figure 1. Cumulative and monthly hydraulic fracturing well permits in Ohio’s Utica Shale

While many shale plays across the United States are experiencing a period of contraction (with low gas prices often cited as the primary reason), drilling activity in Ohio’s Utica Shale has been experiencing a slow and steady expansion. The region has seen more than 2,700 permitted wells as of the end of January 2017. Incidentally, roughly 59% of these wells are producing either oil or gas as of Q3-2016. For more information on that subject, explore our production map.

The permitting trajectory hit a low of 13-16 permits per month between February and January of 2016. Since the presidential election in November, however, permitting rates have more than doubled (Figure 1).

Ohio Oil & Gas Map

Ohio sits on the western edge of both the Utica and Marcellus Shale formations, but conditions are such that the Marcellus Shale is all but being ignored in Ohio. Explore our updated map of OH drilling activity and related facilities below:


View map fullscreen | How FracTracker maps work

Map Layers

The map above is made up of various datasets, from the location of permits to compressor stations. These “map layers” make up the legend. Below we describe each layer on the map, as well as the data source and date range.

Horizontal Marcellus Permits, Laterals
There have been 40+ permits issued for horizontal wells in Ohio’s Marcellus Shale.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

Horizontal Utica Permits
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time Ohio is home to 2,160+ permitted Utica Wells with the wells broken out by status. Additionally this layer contains depth, water usage, sand usage, HCl, and Gelling Agent percentage for 249 wells based on data provided to FracFocus. Finally, we have incorporated production in various units from individual industry press releases and the ODNR annual report.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

Horizontal Utica Permits actual and straight line laterals
An aggregate of ODNR’s monthly cumulative Utica and Marcellus permits as well as a more detailed weekly Risk Based Data Management System (RBDMS) Microsoft Access inventory. At the present time we have straight line laterals for all drilled, drilling, and producing wells as well as actual PLAT laterals for 341 of the wells.

Source:   Ohio Department of Natural Resources
Date Range:  December 2009 – Present

High Volume Hydraulic Fracturing Gathering Lines
All gathering lines servicing Ohio’s inventory of High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

High Volume Hydraulic Fracturing Well Pads
The well-pads of all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) wells.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

High Volume Hydraulic Fracturing Well Pad’s Limits Of Disturbance (LOD)
Limits Of Disturbance (LOD) for all Ohio’s drilled or producing High Volume Hydraulic Fracturing (HVHF) well-pads.

Source: Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

Compressor Stations and Cracking Facilities
Boundaries of several confirmed High Volume Hydraulic Fracturing (HVHF) servicing cracking and compressor station facilities.

Source:   Herbert Hoover Foundation grant
Date Range:  December 2009 – 2015

Ohio Active Class II Injection Wells
This data speaks to the state’s “Active” Class II Injection wells able to accept hydraulic fracturing waste. There are 240+ Active Wells with 51 having yet to receive waste from hydraulic fracturing. For more on Ohio’s Class II Inventory in depth refer to our recent Ohio Fracking Waste Transport & Disposal Network article.

Source:   Ohio Department of Natural Resources
Date Range:  Historical to October, 2015

Earthquakes of >2.0 Magnitude
This data speaks to the state’s 258 earthquakes with current updates from the Ohio Seismic Network and historical quakes – all >2.0 magnitude. These data come from the department’s inventory. Additionally, we present Ohio earthquakes with <2.0 magnitude courtesy of Environment Canada’s Search the Earthquake Database platform.

Source: Ohio Department of Natural Resources, Division of Geological Survey, The Ohio Seismic Network
Date Range:  Historical to Present

Mariner East Technical Difficulties map
FracTracker Alliance

Remaining Questions on Mariner East Technical Deficiencies

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In the summer of 2015, Sunoco Logistics submitted applications to the Pennsylvania Department of Environmental Protection (DEP) to build its massive Mariner East 2 pipeline. The ME 2 pipeline would have the capacity to transport 275,000 barrels a day of propane, ethane, butane, and other hydrocarbons from the shale fields of Western Pennsylvania to the Marcus Hook export terminal, located on the Delaware River.

Sunoco’s applications were to satisfy the state’s Chapter 105 (water obstruction and encroachment) and Chapter 102 (erosion/sediment control and earth disturbance) permitting requirements. The DEP responded to Sunoco’s application, issuing 20 deficiency letters totaling more than 550 pages. Sunoco resubmitted their application in the summer of 2016 and the DEP again rejected many of its plans to disturb streams, ponds, and wetlands. In December, Sunoco resubmitted its revised application for a third time, hoping for final approval.

FracTracker Alliance first wrote about ME 2’s risks to watershed in August 2016, following Sunoco’s second application. Readers who want a general overview of the issues may find that article worth reading. In this new article, we dig deeper into the subject. Along with its December application, Sunoco also supplied the DEP with revised GIS files illustrating ME 2’s new route and documents summarizing its impacts to nearby water bodies. We have created a new map utilizing newly available data and provide contextual analysis valuable in determining how Sunoco responds to the DEP’s review of its prior rejected applications.

Detailed Mapping of Water Body Impacts

At the end of December, the DEP finally released Sunoco’s GIS files detailing water bodies that will be impacted by ME 2, as well as Sunoco’s data tables outlining alternative methods that might mitigate certain impacts. Our map (below) combines these new datasets to show the locations where ME 2’s route has changed since Sunoco’s initial application, presumably in response to the DEP’s technical deficiency letter.

Also on this map are water bodies: 1) implicated in ME 2’s environmental impact assessment, 2) determined by the DEP as likely impacted by construction, and 3) identified by Sunoco as having viable construction alternatives to mitigate impacts.

Mariner East 2 Technical Deficiencies Map


View map fullscreen | How FracTracker maps work

By viewing the map fullscreen and zooming in, one can click on a water feature to reveal its data tables (see below example). These tables contain information on the water body’s flow regime, the extent of permanent and temporary impacts, alternative crossing methods that could be used, and what benefits might come from those alternate methods. Also in the tables are a number of designations such as:

  • USGS Fish and Wildlife wetland classification (see guide). Most common are PEM (palustrine emergent wetland), PSS (palustrine scrub-shrub wetland), PFO (palustrine forested wetland), and PuB (palustrine unconsolidated bottom – i.e. ponds).
  • PA DEP stream designation (see guide). Most common are WWF (warm water fishes), CWF (cold water fishes), HQ (high quality), and EV (exceptional value).
  • PA Fish and Boat Commission classifications (see guide). Most common are ATW (approved trout water), STS (stocked trout stream), Class A (class A water), and WTS (wilderness trout stream).

An example water body data table that can be found on the map:
me2-zoom-screenshot2

Our analysis of this new data reveals the number of water crossings in question is significantly higher than what we estimated in August: now totaling 1,222 streams, 34 ponds, and 708 wetlands crossings. This increase is primarily due to Sunoco’s data also containing information on ephemeral and intermittent waters that are not typically accounted for in USGS data (all that was available at the time of our prior analysis).

Defining Impacts

The DEP’s Chapter 105 Joint Permit Application Instructions break down “impacts” into two broad categories: permanent and temporary. These are primarily used to assess environmental impact fees, but are also valuable in determining what parameters Sunoco will be held to during and after ME 2’s construction.

Permanent impacts: are “areas affected by a water obstruction or encroachment that consist of both direct and indirect impacts that result from the placement or construction of a water obstruction or encroachment and include areas necessary for the operation and maintenance of the water obstruction or encroachment located in, along or across, or projecting into a watercourse, floodway or body of water.”

Permanent impacts are calculated using the pipeline’s 50-foot permanent right-of-way. For streams, all bed and banks are to be restored to pre-construction conditions. For ponds and wetlands, permanent impacts are assumed to remain even if the area is considered restored.

Temporary impacts: are “areas affected during the construction of a water obstruction or encroachment that consists of both direct and indirect impacts located in, along or across, or projecting into a watercourse, floodway or body of water that are restored upon completion of construction.” Temporary impacts consist of areas such as temporary workspaces and access roads.

The below table lists the total impacted acres broken down by county. Of interest here is that more than 175 acres would be permanently impacted — equivalent to 134 football fields — with an additional 82 acres temporarily impacted.

Table 1. Impacted Acres by County

County Permanent Impacts (acres) Temporary Impacts (acre)
Allegheny 1.85 0.39
Berks 11.14 4.88
Blair 11.70 6.72
Cambria 20.21 8.48
Chester 10.30 3.92
Cumberland 24.06 7.61
Dauphin 8.12 6.55
Delaware 5.05 3.33
Huntingdon 18.75 8.04
Indiana 11.42 4.73
Juniata 5.25 3.02
Lancaster 4.65 1.66
Lebanon 6.48 2.53
Perry 5.58 2.63
Washington 9.37 2.94
Westmoreland 17.72 12.36
York 3.46 2.16
Total 175.12 81.93

Viable Options to Reduce Impacts

Example of an open cut wet crossing

An open cut wet crossing (image source)

Pipeline companies cross water bodies using a variety of methods depending on their classification. The DEP maintains three general categories for water crossings: minor (in streams less than or equal to 10 feet wide at the water’s edge at the time of construction), intermediate (perennial stream crossings greater than 10 feet wide but less than 100 feet wide at the water’s edge at the time of construction), and major (crossings of more than 100 feet at the water’s edge at the time of construction).

Minor and intermediate crossings often employ rudimentary trenching along “open cut” crossings where the water is either temporarily diverted (wet crossing) or allowed to flow during construction (wet crossing). After the cuts, the company attempts to repair damage done in the process of trenching.

In more sensitive places, such as in exceptional value streams, wetlands, and always in major crossings, a company uses conventional boring to tunnel under a water feature. When boring over long distances, such as under a lake or river, a company turns to Horizontal Directional Drilling (HDD), a more engineered form of boring. An example of HDD boring is seen below (image source):

hdd_crossing_example

We were surprised by the number of water crossings identified by Sunoco as having options to minimize impact. As the table below shows, more than 44% (869) of Sunoco’s crossings have an alternate method identified in the resubmitted applications. In most of these instances, the intended crossing method is either trenching through open cuts or dry crossings. The majority of identified alternatives would reduce impacts simply by altering the trenching route. 53 of the 869 were shown to have feasible conditions for conventional or HDD boring, but Sunoco categorized all of these as impracticable options despite their environmental benefits.

Table 2. Number of Crossings With and Without Viable Alternate Methods

Crossings Assessed but Unimpacted Impacted with No Alternative Impacted with Alternatives Total
Streams 313 925 297 1,535
Ponds 66 3 31 100
Wetlands 963 167 541 1,671
  1,342 1,095 869 3,306

Absorbing the Costs of Environmental Impacts

If executed, these alternative methods would decrease the length of crossings, limit right-of-way encroachments, prevent land fragmentation, and significantly reduce risks to larger water bodies. More likely, Sunoco will pay the impact fees associated with the less complicated crossing methods. We’ve summarized these fees (found in Sunoco’s resubmitted application) in the table below. In total, Sunoco would pay roughly $1.8 million in exchange for nearly 2,000 water body crossings – a fraction of the project’s $2.5 billion estimated cost:

Table 3. Impact Fees for Sunoco’s Preferred Crossings

County Permanent Impacts area (fees) Temporary Impact area (fees) Admin Fees Total Fees
Allegheny $15,200 $1,600 $1,750 $18,550
Berks $89,600 $19,600 $1,750 $110,950
Blair $94,400 $27,200 $1,750 $123,350
Cambria $162,400 $34,000 $1,750 $198,150
Chester $83,200 $16,000 $1,750 $100,950
Cumberland $192,800 $30,800 $1,750 $225,350
Dauphin $65,600 $26,400 $1,750 $93,750
Delaware $40,800 $13,600 $1,750 $56,150
Huntingdon $150,400 $32,400 $1,750 $184,550
Indiana $92,000 $19,200 $1,750 $112,950
Juniata $42,400 $12,400 $1,750 $56,550
Lancaster $37,600 $6,800 $1,750 $46,150
Lebanon $52,000 $10,400 $1,750 $64,150
Perry $44,800 $10,800 $1,750 $57,350
Washington $75,200 $12,000 $1,750 $88,950
Westmoreland $142,400 $50,000 $1,750 $194,150
York $28,000 $8,800 $1,750 $38,550
$1,408,800 $332,000 $29,750 $1,770,550

Conclusion

This week, acting DEP Secretary Patrick McDonnell met with residents who voiced frustration that the agency failed to provide an additional public comment period following Sunoco’s application resubmission. Nevertheless, the DEP is expected to greenlight Sunoco’s plans any day now, adding another to the list of recent pipeline approvals in the region. Sunoco needs its permits now in order to begin clearing trees prior to endangered species bat nesting season, which begins in April.

Meanwhile, communities along the pipeline’s path are preparing for the sudden wave of disruption that may ensue. Some have threatened lawsuits, arguing that the resubmitted application still contains many deficiencies including missing wetlands and private drinking wells that must be accounted for. Indeed, the map and data presented in this article confirms that there is still a lot that the general public does not know about ME 2 – in particular, the extent of water impacts the DEP seems willing to accept and the range of options at Sunoco’s disposal that might mitigate those impacts if it were forced to do so.

Finally, it is encouraging to see that the DEP is becoming more transparent in sharing datasets, compared to other pipeline projects. However, this data is complex and not easily understood without sufficient technical expertise. We are discouraged to think that it is unlikely the public will learn about additional changes to the construction plan until after permits are issued. In order for data to be useful, it must be made available throughout the process, not at the end stages of planning, and done so in a way that it becomes integrated into the agency’s public participation responsibilities.

by Kirk Jalbert, Manager of Community-Based Research & Engagement

Shell Ethane Cracker
FracTracker Alliance

A Formula for Disaster: Calculating Risk at the Ethane Cracker

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by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project

On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.

As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?

Known Ethane Cracker Risks

A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.

disaster-risk-infographic-websize

Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.

williams-geismar-explosion-websize

U.S. Chemical Safety and Hazard Investigation Board, Williams Geismar Case Study, No. 2013-03-I-LA, October 2016.

We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.

For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.

The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.

Potential Risks & Shell’s Mixed Messages

Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”

However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.

Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)

Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.

 

Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limited accessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.

Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?

Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.

Opening the Floodgates

In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.

Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.

Ethane Cracker Hazards Map


View map fullscreen | How FracTracker maps work

While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.

What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.

Final Calculations

As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.

The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.

Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.

Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.

The Environmental Integrity Project is a nonpartisan, nonprofit watchdog organization that advocates for effective enforcement of environmental laws.